To the most honorable Chairman Martin,
On Monday morning I read the announcement of the Open Commission Hearing scheduled to discuss the Universal Service Fund issue and E911. (My initial comments can be found here)
Chairman Martin, I want you to know that I have some pretty high expectations for you, expectations that are probably more based on what I hope you will accomplish rather than what your past voting history or published views might indicate. What I do know is that you are on the younger side, very technically savvy and an extremely sharp gentlemen.
Whenever there is a transition of leadership there is a necessary pause before we can see what direction the new leadership will implement. One policy that I am hopeful will be retained is the openness the FCC has fostered in recent years. If there has been anything that has demonstrated to the American public and the small businessperson that we have a real voice in the crafting of regulations, this is certainly it.
To that end, I would like to take this opportunity to explain my feeling on the E911 issue. I have already detailed my opinion on the Universal Service Fund so I am going to leave that subject alone and instead focus on the E911 issue. It is my understanding that the ILECs are in almost every case the companies who are be terminating calls to the E911 service. I would suggest that this would indicate that the onus of connecting the VoIP providers should squarely rest on their shoulders.
According to this article in Reuters the FCC is going to require VoIP companies to provide E911 service within the next 120 days.
Here is how I look at the situation, we need to let the ILECs know that we believe this responsibility should be shouldered by them – period. That is exactly what the ILECs are supposed to be doing – minding the core of the telephone infrastructure.
Without knowing the actual mechanism the FCC will be proposing it is difficult for anyone to add comment at this time but there is one point I would like to interject, if I may. Over the last several years I believe there is a mountain of evidence that the corporate mindset of the ILECs is one of making it very difficult for anyone the ILECs believe to be their competition to interact with them.
Now, as a alternative suggestion, it would seem trivial to require the manufacturers of telephones to include a “panic button” built right into their equipment. In today's advanced world of telecommunications it should be a very easy feature to set up on any telephone in the United States.
This is how I would envision the system working. A consumer purchases a new E911 ready telephone and when they install it the phone dials into the POTS infrastructure and receives the necessary information to automatically configure the E911 button. Regardless of what kind of connectivity the customer has it should be very easy for the POTS system to coordinate with the VoIP provider and the connectivity supplier to get the physical location from the hardware installed (cable or DSL modem MAC address) and supply the necessary information to the E911 system.
I do understand that this would lead to a number of “accidental” activations but from what I understand the amount of calls to the 911 service that are not emergency related is astronomical anyway.
Let me say this clearly, Chairman Martin, I believe you are a man who has taken on an incredibly difficult job, one that also affords you a fantastic opportunity to move this country ahead in this most critical area. From what I can discern you are a man of integrity along with the experience and capability to see through all of the hype. We (I mean this entire country) needs you to move us forward quickly, in a bold new direction. I do expect that the lobbyists needs to be given access, listened to but also filtered with the aim of only allowing what is good for our entire nation – not just what a largely obsolete network provider needs to continue to deliver miserable and outdated service.
Chairman Martin, sir, if I may, this is what I would like to suggest. We need to provide the ILECs with relief from having to service wide areas of this country that will never be anything but a money losing proposition for them. In order to do this, we need to make it not only possible but easy for alternative connectivity companies to provide essential services in these areas. This is without doubt a winning mechanism for not only the ILEC but more importantly for the American consumer.
It is time for you to chart a new course for our communications infrastructure. We must do something different from what has been our course until now because it is readily apparent that we have fallen so far behind the rest of the industrialized world that this is a source of national disgrace. In order for us to move ahead and reclaim a position that approaches the top of the list we will need to to look at any reasonable method we can reliably employ to deliver not only broadband but VoIP as a REAL substitute for POTs service.
I would also like to go one step farther, at this time I can tell you that the FCC is now under more scrutiny by the public than at any time I can remember in my life. We need to look at how the FCC can remain relevant in the average American's life, something that I have seen firsthand with the FCC.
What I most fear is that if the perception by many that the FCC is pretty much owned by the ILECs. I need you to know that many of us believe the ILECs have completely failed in delivering the broadband connectivity the American public sorely needs. Instead of supporting this culture it is time to force the ILECs to stand on their own feet.
To that end, I ask that you direct the FCC in such a way as to discontinue the Universal Service Fund and require the ILECS to make it possible for anyone who wishes to get access to the E911 service and connectivity to their networks at very reasonable prices.
Thank you for your time.
Respectfully,
Ken DiPietro
New-ISP
NextGenCommunications
Chairman Martin, I want you to know that I have some pretty high expectations for you, expectations that are probably more based on what I hope you will accomplish rather than what your past voting history or published views might indicate. What I do know is that you are on the younger side, very technically savvy and an extremely sharp gentlemen.
Whenever there is a transition of leadership there is a necessary pause before we can see what direction the new leadership will implement. One policy that I am hopeful will be retained is the openness the FCC has fostered in recent years. If there has been anything that has demonstrated to the American public and the small businessperson that we have a real voice in the crafting of regulations, this is certainly it.
To that end, I would like to take this opportunity to explain my feeling on the E911 issue. I have already detailed my opinion on the Universal Service Fund so I am going to leave that subject alone and instead focus on the E911 issue. It is my understanding that the ILECs are in almost every case the companies who are be terminating calls to the E911 service. I would suggest that this would indicate that the onus of connecting the VoIP providers should squarely rest on their shoulders.
According to this article in Reuters the FCC is going to require VoIP companies to provide E911 service within the next 120 days.
“Under pressure from state law-enforcement agencies and Congress, the Federal Communications Commission plans to require VoIP companies to provide 911 services to customers within 120 days of its order being published, two officials familiar with the FCC plan said.”
Here is how I look at the situation, we need to let the ILECs know that we believe this responsibility should be shouldered by them – period. That is exactly what the ILECs are supposed to be doing – minding the core of the telephone infrastructure.
Without knowing the actual mechanism the FCC will be proposing it is difficult for anyone to add comment at this time but there is one point I would like to interject, if I may. Over the last several years I believe there is a mountain of evidence that the corporate mindset of the ILECs is one of making it very difficult for anyone the ILECs believe to be their competition to interact with them.
Now, as a alternative suggestion, it would seem trivial to require the manufacturers of telephones to include a “panic button” built right into their equipment. In today's advanced world of telecommunications it should be a very easy feature to set up on any telephone in the United States.
This is how I would envision the system working. A consumer purchases a new E911 ready telephone and when they install it the phone dials into the POTS infrastructure and receives the necessary information to automatically configure the E911 button. Regardless of what kind of connectivity the customer has it should be very easy for the POTS system to coordinate with the VoIP provider and the connectivity supplier to get the physical location from the hardware installed (cable or DSL modem MAC address) and supply the necessary information to the E911 system.
I do understand that this would lead to a number of “accidental” activations but from what I understand the amount of calls to the 911 service that are not emergency related is astronomical anyway.
Researchers estimate that 60 to 90 percent of 911 calls are not emergency calls. According to a study sponsored by the National Institute of Justice, non-emergency 311 call systems can greatly reduce the 911 burdens.
Let me say this clearly, Chairman Martin, I believe you are a man who has taken on an incredibly difficult job, one that also affords you a fantastic opportunity to move this country ahead in this most critical area. From what I can discern you are a man of integrity along with the experience and capability to see through all of the hype. We (I mean this entire country) needs you to move us forward quickly, in a bold new direction. I do expect that the lobbyists needs to be given access, listened to but also filtered with the aim of only allowing what is good for our entire nation – not just what a largely obsolete network provider needs to continue to deliver miserable and outdated service.
Chairman Martin, sir, if I may, this is what I would like to suggest. We need to provide the ILECs with relief from having to service wide areas of this country that will never be anything but a money losing proposition for them. In order to do this, we need to make it not only possible but easy for alternative connectivity companies to provide essential services in these areas. This is without doubt a winning mechanism for not only the ILEC but more importantly for the American consumer.
It is time for you to chart a new course for our communications infrastructure. We must do something different from what has been our course until now because it is readily apparent that we have fallen so far behind the rest of the industrialized world that this is a source of national disgrace. In order for us to move ahead and reclaim a position that approaches the top of the list we will need to to look at any reasonable method we can reliably employ to deliver not only broadband but VoIP as a REAL substitute for POTs service.
I would also like to go one step farther, at this time I can tell you that the FCC is now under more scrutiny by the public than at any time I can remember in my life. We need to look at how the FCC can remain relevant in the average American's life, something that I have seen firsthand with the FCC.
What I most fear is that if the perception by many that the FCC is pretty much owned by the ILECs. I need you to know that many of us believe the ILECs have completely failed in delivering the broadband connectivity the American public sorely needs. Instead of supporting this culture it is time to force the ILECs to stand on their own feet.
To that end, I ask that you direct the FCC in such a way as to discontinue the Universal Service Fund and require the ILECS to make it possible for anyone who wishes to get access to the E911 service and connectivity to their networks at very reasonable prices.
Thank you for your time.
Respectfully,
Ken DiPietro
New-ISP
NextGenCommunications
posted by Next Generation Communications at
3:03 AM
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