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pkust
join:2001-08-09
Houston, TX | reply to youngmoore
Re: Grrrr said by youngmoore:
There's nothing like Gov to kill an up and coming industy.
If MN PUC only problem is E-911 then Vonage can simpley not offer it there or just taken 911 off their feature list.
Without 911, Vonage is an inadequate replacement for a primary telephone line, which automatically relegates Vonage to a niche role in the telecom industry.
While I am excited about VoIP's potential to transform the telecommunications industry, I do not want that transformation to include a disruption of the 911 system, or a diminution of people's access to that system. 911 saves lives, and anything which might disrupt its functioning needs to be examined under a microscope.
--
Cordially,
Peter Nayland Kust
pkust@smsysinc.com
Secure Mobile Systems, Inc.
www.smsysinc.com | |
Reviews:
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| Thats just what VOIP is now is a Niche. VOIP no matter what the provider out there can give you 99.8% uptime as the telco's are required to do to quilfy as a "phone company". Since VOIP is soly dependent on your ISP and the quilty of that ISP there's no way they can say YES you will have 911 at any point in time that you need it like a CLEC or ILEC can.
This again takes Vonage out of the "phone company" stance cause they are not able to control your ISP in anyway shape or form. BTW Vonage is the only on out there that has 911 access. Non of the other VOIP providers offer it and for good reason. I think Vonage started off offering 911 not E-911 "which they don't have access to" as a courtsy to its users and now its backfired on them.
as far as USF fund I don't think it appiles to them since they are not a normal phone company. In fact like said before USF has got to go anyway, but thats just my point of view.
Under the USF they would have to provide service to just about everywhere and thats just not possiable without funding. The same funding the ILEC's get via USF and the FCC charge, network access charge, and Gov grants etc.
And even then there still not a phone company since they can't give you 99.8% uptime. This industry is just to small to go hell bound for glory to call them a normal phone company cause there not even close.
ym
spell check not included | |
| VOIP no matter what the provider out there they CAN'T give you 99.8% uptime
sorry left out the CAN'T
ym | |
| said by youngmoore:
VOIP no matter what the provider out there they CAN'T give you 99.8% uptime
sorry left out the CAN'T
ym
To add to that- your phone company does not offer 99.9 up time either. Some people cannot recall the last time the phone went out, however everyday thousands of people call the phone company to report no dialtone. Business users can go out for days.
The PSTN is far more stable.... but VoIP will be as well and should happen much faster than it did with PSTN.
And about relegated to niche industry, ever heard of cell phone? No one ever thought people would replace landlines with them, yet hundreds of thousands maybe even millions have. | |
| its Niche now. It will be the way to go in some form like sip or something else, unless the Gov and ILEC's step in and crush it. It was 99.8% btw. if you add it up it actually makes a difference
ym | |
| reply to pkust
OK, that's enough now... said by pkust:
Without 911, Vonage is an inadequate replacement for a primary telephone line, which automatically relegates Vonage to a niche role in the telecom industry.
Perhaps very few of the "experts" here actually understand the workings of a 9-1-1 center (more accurately known as a PSAP, or Public Safety Answering Point)? Since I actually DO work with PSAPs and 9-1-1, maybe I can clear a few things up...
1.) When a person dials 9-1-1 on a wired phone in most (not all, yet) parts of the US, their call is routed to a PSAP near their geographic location via trunk lines (not 7 digit numbers) from the telco central office, along with data from the 9-1-1 database (usually maintained by folks like Intrado) that displays their number and address info to the dispatch operator.
2.) When a wireless caller dials 9-1-1, it depends entirely upon what part of the country and upon which network they use as to what PSAP their call will be sent to. Hopefully, it will be somewhere that's actually close to their current location, but many times it is not and much time is spent in trying to determine what the correct PSAP is and how to transfer the call there. Wireless 9-1-1 regulations are afoot that will improve this over time, but are not yet implemented in most places.
3.) When a Vonage user applies for 9-1-1 service, Vonage uses the same Intrado (formerly SCC) database that many 9-1-1 centers rely upon to determine the correct PSAP for that user's location. They then program the system such that if that caller dials 9-1-1, the call is routed to the "dial in" (7 or 10 digit) number for the center. This number is answered 24/7 just like the 9-1-1 trunks... it's usually just another button on the same phone... but does not have the phone number/address (ANI/ALI) data as would a call arriving on a 9-1-1 trunk. It will often have caller ID info, however, which a savvy 9-1-1 operator is trained to run a "reverse lookup" on to obtain the address info from the 9-1-1 database. The call DOES get sent quickly to an emergency operator at the correct PSAP, with no intermediate fooling around like many wireless calls.
I actually called 9-1-1 on one of my "9-1-1 enabled" Vonage lines to see what would happen. I announced as soon as they picked up the phone that my call was NOT an emergency, but they were happy to take the time to talk with me about it. In about 15 seconds they told me what my address was (from the reverse lookup they had already started), and then talked about the many other Vonage users in the area and how that they were "no trouble at all for them".
From where I sit, I'm one hell of a lot better off calling 9-1-1 from my Vonage line than from my cell phone if I need help. I don't see any clamor to shut down wireless calling because of the crappy way it processes 9-1-1 calling.
It's all about the money, kids. The politicos don't give a damn if you can reach the fire department or not when your house is on fire... so long as someone is lining their pockets.
Dan | |
| Interesting post Dan.
I wondered if the Vonage 911 may be throwing off the centers because calls come in on that general line. Sounds like they probably arent, which is a good thing. Would these calls add to a higher response time? | | |
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| reply to Good Ol Dan
said by Good Ol Dan:
They then program the system such that if that caller dials 9-1-1, the call is routed to the "dial in" (7 or 10 digit) number for the center.
That is the problem! Federal Law prohibits 911 calls from being sent to PSAP on 7 or 10 digit numbers. In fact the law requires telephone companies to disconnect 7 or 10 digit numbers that are being used to receive emergency calls! The 911 system is independant of the normal telephone system. It has its own dedicated switching centers with dedicated trunks connecting all central offices to the dedicated switching centers and in turn the PSAPs. While your 911 PSAP may respond to calls on these 7 or 10 digit numbers in the same manner as calls on the 911 lines, I can assure you that is not true of all PSAP! Many PSAP turn their "administrative" numbers off during times of high 911 call volume or large scale emergency situations! | |
 calvoiper
join:2003-03-31
Belvedere Tiburon, CA | reply to clecrupt9
Some PSAPs handle these calls better than others.
Gee, Dan, it works great from home. What happens when you take your laptop on the road and call from your motel room in Atlanta?
Calvoiper
--
VoIP--the death knell of remaining voice monopolies! | |
calvoiper
join:2003-03-31
Belvedere Tiburon, CA | reply to mjcrocket
...and maybe the PSAPs need to recognize VoIP is coming, and do some adaptation of their own, rather than just expecting everyone else to fit into the RBOC model, which is circa 1965....
Realistically, when one of these calls gets dropped and somebody dies, it will be interesting to see if the jury pins some of the blame on the recalcitrant PSAP that "shut down a line it knew emergency calls came in on" as well as a company that offered something less than perfect 9-1-1.
And before you say that this is a reason Vonage should be shut down, realize that we could eliminate auto injuries by prohibiting driving....
Calvoiper
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VoIP--the death knell of remaining voice monopolies! | |
pkust
join:2001-08-09
Houston, TX | said by calvoiper:
And before you say that this is a reason Vonage should be shut down, realize that we could eliminate auto injuries by prohibiting driving....
Ummm...who is saying Vonage should be shut down?
The issue is not whether Vonage should or should not be allowed to operate, but whether Vonage should or should not be allowed to represent themselves as a "phone company" without complying with various regulations governing "phone companies".
Minnesota Statutes, §237.16, Subd 1(b) states:
No person shall provide telephone service in Minnesota without first obtaining a determination that the person possesses the technical, managerial, and financial resources to provide the proposed telephone services and a certificate of authority from the commission under terms and conditions the commission finds to be consistent with fair and reasonable competition, universal service, the provision of affordable telephone service at a quality consistent with commission rules, and the commission's rules.
§237.035 exempts "telecommunications carriers" (distinguished within the statute from "telephone companies") from several regulatory requirements generally applied to telecommunications. However, the section does mandate that a telecommunications carrier obtain the certification mandated under §237.16 to the extent the carrier offers local telephone service.
§237.01, Subdivision 6 defines a "telecommunications carrier" as follows:
"Telecommunications carrier" means a person, firm, association, or corporation authorized to furnish one or more of the following telephone services to the public, but not otherwise authorized to furnish local exchange service: (1) interexchange telephone service; (2) local telephone service pursuant to a certificate granted under the authority of section 237.16, subdivision 4, before August 1, 1995; or (3) local service pursuant to a certificate granted under section 237.16, for the first time after August 1, 1995, except if granted to a successor to a telephone company otherwise authorized to furnish local exchange service. Telecommunications carrier does not include entities that derive more than 50 percent of their revenues from operator services provided to transient locations such as hotels, motels, and hospitals. In addition, telecommunications carrier does not include entities that provide centralized equal access services.
It is important to note that the statutory language makes no distinction with regard to the medium of transport. Based on a strict reading of the statute, one can conclude that, under the law, dialtone is dialtone, and telephone service is telephone service. Although Vonage is using a new technology to deliver telephone service, what it is marketing to consumers is still telephone service.
While Minnesota's statutes are somewhat simplistic in their construction, they are hardly out of sync with similar statutes elsewhere in the US. In the State of Texas, §54.001 of the Utilities Code mandates either a certificate of convenience and necessity or a certificate of operating authority in order to offer "local exchange telephone service...." §51.002(5) of the Code defines "local exchange telephone service" as follows:
"Local exchange telephone service" means telecommunications service provided within an exchange to establish connections between customer premises within the exchange, including connections between a customer premises and a long distance provider serving the exchange. The term includes tone dialing service, service connection charges, and directory assistance services offered in connection with basic local telecommunications service and interconnection with other service providers.
This is where Vonage has erred. By advertising its ability to assume a customer's existing LEC-based telephone #, by using marketing language such as "Broadband Phone Company," Vonage has created an opportunity for a state PUC to classify its service offerings as telecommunications service subject to regulation. If Vonage had instead targeted its marketing message more precisely, touting the benefits that differentiate VoIP from traditional POTS, this issue need never have arisen.
For example, Texas offers a number of specific exemptions to the statutory requirements. "Local exchange telephone service" specifically does not include "central office based PBX-type services for systems of 75 stations or more" (§51.002(5)(A)). §51.002(5)(J) empowers the Texas PUC to explicitly classify a service as not being "local exchange telephone service" independent of that services operating characteristics. §54.003(4) removes the certification requirement from "a specialized communications common carrier service." The requirement to support 911 services is a characteristic of the certification process, and so if Vonage is exempt from certification, the 911 issue is moot (in Texas, at least).
Similarly, the Minnesota definition of a "telecommunications carrier" explicitly excludes entities that provide "centralized equal access services." Whether Vonage could fit within this exception I do not pretend to know; I merely call attention to the fact that there are exceptions to regulatory requirements under Minnesota statute.
Whether the law is right or wrong, good or bad, is not relevant. What is relevant is that this is the law. Vonage does its investors and customers a disservice by ignoring the legal landscape within which it chooses to do business. Vonage has not worked to change the laws, nor has it particularly protested them; it has merely ignored them, and that is bad business.
--
Cordially,
Peter Nayland Kust
pkust@smsysinc.com
Secure Mobile Systems, Inc.
www.smsysinc.com | |
calvoiper
join:2003-03-31
Belvedere Tiburon, CA | ...and we end up arguing over whether Vonage is a "telecom service" or an "information service", which is where all this began.
It's fairly clear that Vonage cannot comply with all the Minnesota rules designed to regulate traditional ILECs and CLECs, so classifying it as a CLEC will essentially force it out of MN.
The question is whether or not the MPUC wants to force every provider of anything resembling voice communications to look just like a Baby Bell, or not. If they do the former, new technologies will be outlawed and the incumbent Baby Bell, Qwest, will continue to dominate the market. If, instead, they allow new technologies some running room, we will see great innovation.
Saying blindly "this is the law" ignores the fact that the law may not apply. Under the MN law you so blithely quote, for example, what "connections" does Vonage "establish" in Minnesota? I don't see that they have any facilities in MN with which to establish any connections. It's the interpretation that counts.
What a shame it would have been if the FCC, in its Computer I, II, and III proceedings, had interpreted the law differently and said that any data communication was telecommunications and therefore the exclusive purview of the Bell system. Do you honestly think that the Internet would have developed as it has under a Bell monopoly? Sheesh, we'd all be fighting ISDN!
BTW, I agree that Vonage has been inviting some of this trouble based on its own advertising--but questionable ads do not make regulatory jurisdiction--only actions do.
Calvoiper
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VoIP--the death knell of remaining voice monopolies! | |
pkust
join:2001-08-09
Houston, TX | said by calvoiper:
Saying blindly "this is the law" ignores the fact that the law may not apply. Under the MN law you so blithely quote, for example, what "connections" does Vonage "establish" in Minnesota? I don't see that they have any facilities in MN with which to establish any connections. It's the interpretation that counts.
Your point is well taken. However, I should clarify something. The language regarding establishing connections is from the Texas statutes, not the Minnesota ones. The statutory language in Minnesota speaks only to providing "telephone service." Where and how connections are terminated would not be a relevant factor on that basis.
said by calvoiper:
BTW, I agree that Vonage has been inviting some of this trouble based on its own advertising--but questionable ads do not make regulatory jurisdiction--only actions do.
Perhaps, but advertisement is action in business. If I say I am offering "local exchange telephone service" in Texas, I am inviting a knock on the door from the PUC, regardless of how my actual service offerings may be structured, because I am using language with specific statutory meaning. Minnesota law has an explicit definition for "telephone company," and entities identified as such are subject to various and sundry state regulations. That Vonage provided the initial identification is moot; the moment Vonage became identified in Minnesota as a "telephone company," it became a target for regulatory process.
That, to my way of thinking, is the important message in this brouhaha--newness of technology alone is insufficient to bring about meaningful change. Sound business, financial, and legal planning are also key ingredients to long term success.
--
Cordially,
Peter Nayland Kust
pkust@smsysinc.com
Secure Mobile Systems, Inc.
www.smsysinc.com | |
Anon | reply to pkust
Nice post, but none of that applies to voice over IP. Vonage has one or more call legs that are IP, if that is enough to satisfy an information service, none of those laws apply. | |
| I posted that statement above, stupid keyboard. | |
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