A Model for Emergency Service of VoIP Through Certification and Labeling

Voice over Internet Protocol (VoIP) will transform many aspects of traditional telephony service including technology, the business models and the regulatory constructs that govern such service. This transformation is generating a host of technical, business, social and policy problems. The Federal Communications Commission (FCC) could attempt to mandate obligations or specific solutions to the policy issues around VoIP, but is instead looking first to industry initiatives focused on key functionality that users have come to expect of telecommunications services. High among these desired functionalities is access to emergency services that allow a user to summon fire, medical or law enforcement agencies. Such services were traditionally required (and subsequently implemented) through state and federal regulations. Reproducing emergency services in the VoIP space has proven to be a considerable task, if for no other reason then the wide and diverse variety of VoIP implementations and implementers. Regardless of this difficulty, emergency service capability is a critical social concern, making it is particularly important for the industry to propose viable solutions for promoting VoIP emergency services before regulators are compelled to mandate a solution, an outcome that often suffers compromises both through demands on expertise that may be better represented in industry and through the mechanisms of political influence and regulatory capture. While technical and business communities have, in fact, made considerable progress in this area, significant uncertainty and deployment problems still exist. The question we ask is: can an industry based certification and labeling process credibly address social and policy expectations regarding emergency services and VoIP, thus avoiding the need for government regulation at this critical time?1 We hypothesize that it can. To establish this, we developed just such a model for VoIP emergency service compliance through industry certification and device labeling. The intent of this model is to support a wide range of emergency service implementations while providing the user some validation that the service will operate as anticipated. To do this we first examine possible technical implementations for emergency services for VoIP.2 Next, we summarize the theory of certification as self-regulation and examine several relevant examples. Finally, we synthesize a specific model for certification of VoIP emergency services. We believe that the model we describe provides both short term and long-term opportunities. In the short term, an industry driven effort to solve the important current problem of emergency services in VoIP, if properly structured and overseen as we suggest, should be both effective and efficient. In the long term, such a process can serve as a model for the application of self-regulation to social policy goals in telecommunications, an attractive tool to have as telecommunications becomes increasingly diverse and heterogeneous.