| reply to youngmoore
Re: Grrrr said by youngmoore:
If MN PUC only problem is E-911 then Vonage can simpley not offer it there or just taken 911 off their feature list.
911 is not an optional service, it is a required service that must be provided without exception. Federal Law requires that all telephones must have access to 911 (Pub. L. 106-81, Sec. 2, Oct. 26, 1999, 113 Stat. 1286), this law is known as "Wireless Communications and Public Safety Act of 1999" (47 USC Sec. 615); which was implemented by the FCC by the adoption of order FCC 01-351 (»hraunfoss.fcc.gov/edocs_public/a···51A1.pdf) on November 29, 2001 which required the transition to use of 911 as the national emergency number by September 11, 2002.
The governing body for the 911 system standards is the National Emergency Number Association their guidance on the matter is: service parity is a basic objective; every potential 9-1-1 caller should have the same likelihood of a successful 9-1-1 call connection, regardless of the source of the call, whether from an ILEC, a CLEC, an ISP, or a wireless carrier ( »www.nena9-1-1.org/9-1-1TechStand···plan.htm ) Please note that they very clearly included ISPs along with ILECs and CLECs. |
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| But right now those rules dont apply because Vonage is not any of the above entities. |
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pkust
join:2001-08-09
Houston, TX | said by clecrupt9:
But right now those rules dont apply because Vonage is not any of the above entities.
Merely saying this does not make it so. In fact, Vonage takes great pains to act like an ILEC or CLEC entity:
- Vonage presents itself as "the broadband phone company." Their marketing puts Vonage squarely in competition with ILECs and CLECs.
- Vonage promotes transferring your existing ILEC-based telephone number to Vonage--i.e., number portability
- Media coverage of Vonage regards them as a telephone company.
- Vonage CPE (a Cisco ATA186) works with a traditional analog telephone.
If it walks like a duck, quacks like a duck--it's a duck.
No PUC in the US is likely to permit Vonage to represent themselves as a "phone company" to consumers but "not a phone company" to the government. If Vonage wishes to avoid telco regulations, they must not play the telco to the consumer.
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Cordially,
Peter Nayland Kust
pkust@smsysinc.com
Secure Mobile Systems, Inc.
www.smsysinc.com |
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 calvoiper
join:2003-03-31
Belvedere Tiburon, CA | I have the answer to auto crash deaths!
Let's get rid of auto injuries by mandating that only cars that make it impossible to die in can be driven. That would of course mean putting a 5 mph governor on every auto, but it would work. Some cities tried that early in the 20th century. Guess what happened? Eventually, even government realized that the auto was coming, and they redesigned their roads and systems around it.
Saying Vonage is to risky to be allowed to provide service is like saying that autos should be banned because they scare horses.
The real moving force behind this collective "Let's all stick our heads in the 9-1-1 sand and pretend that there will never be any voice communication outside the PSTN" movement is the entrenched, incumbent telcos.
Will there be change needed? Yes. Should Vonage be more open about the limitations of its 9-1-1 service? Yes. Does it make sense to impose 9-1-1 standards based on a local telephone company model on all voice providers without accounting for technological change? Only if you are a local telco incapable of dealing with change--but about 95% of them are.
Calvoiper
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VoIP--the death knell of remaining voice monopolies! |
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 trisomyPremium
join:2002-05-23
Katy, TX | said by calvoiper:
Will there be change needed? Yes. Should Vonage be more open about the limitations of its 9-1-1 service? Yes. Does it make sense to impose 9-1-1 standards based on a local telephone company model on all voice providers without accounting for technological change?
Calvoiper
Calvo, if you agree changes (or regulations enforced) are required when would you propose they be implemented? |
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calvoiper
join:2003-03-31
Belvedere Tiburon, CA | Let's say that the regulators shouldn't be prohibiting service as a starting point. Then, let the regulators move to impose reasonable requirements on the VoIPers, rather than taking the lazy bureaucrat's approach of prohibiting anything you don't understand or have to work to accommodate.
If, instead of being power hungry, the MPUC had provided for a requirement that non-telcos not represent themselves as full service local phone companies, that would be different. Instead, MPUC shoots first to grab power, and worries about stifling innovation later.
Calvoiper
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VoIP--the death knell of remaining voice monopolies! |
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trisomyPremium
join:2002-05-23
Katy, TX | said by calvoiper:
Let's say that the regulators shouldn't be prohibiting service as a starting point. Then, let the regulators move to impose reasonable requirements on the VoIPers,
Calvo, I asked the question 'when' because if you agree that regulation is necessary but you differ in timing then the question becomes....
said by calvoiper:
...rather than taking the lazy bureaucrat's approach of prohibiting anything you don't understand or have to work to accommodate.
You have provided possibly one explanation but another might be that they quite well understand and recognize that before the unfair competitive advantage develops, they will level the playing field. Certainly their level (taxes) appears self-serving but for every dollar Vonage removes from those who pay their wages, taxes diminish as well. I think it is fair to state that neither of us know for certain what their motivation is.
said by calvoiper:
If, instead of being power hungry, the MPUC had provided for a requirement that non-telcos not represent themselves as full service local phone companies, that would be different. Instead, MPUC shoots first to grab power, and worries about stifling innovation later.
My guess is it has nothing to do with innovation. I suspect revenue although given the FCC's Triennial Review (vesting the State w/Power) you could be correct. |
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