Subject: [NEXTEL-1] APCO COMMENTS ON VoIP / 9-1-1 TO THE FCC

From: [email-masked]
Date: Thu, 30 Oct 2003 22:21:19 -0500

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC  20554
_________________________________________________________________________

In the Matter of
VONAGE HOLDINGS COPORATION
Petition for Declaratory Ruling

WC Docket No. 03-211
_________________________________________________________________________

COMMENTS OF THE
ASSOCIATION OF PUBLIC-SAFETY COMMUNICATIONS OFFICIALS-
INTERNATIONAL, INC.

The Association of Public-Safety Communications Officials-International,
Inc.
(.APCO.) hereby submits the following brief comments in response to the
Commission.s
Public Notice, DA 03-2952, released September 26, 2003, in WC Docket
03-211, seeking
comments regarding a Petition for Declaratory Ruling filed on September
22, 2003, by
Vonage Holdings Corporation (.Vonage.).

APCO is the nation.s oldest and largest public safety communications
organization.   Founded in 1935, APCO has over 16,000 individual
members, most of
whom are state or local government employees who manage and operate
communications
systems for police, fire, emergency medical and other public safety
agencies.   APCO has
been at the forefront of efforts to improve 9-1-1 service and promote
the nationwide
deployment of .Enhanced 9-1-1. for all telephone communications.

The Vonage Petition raises a fundamental question regarding the
regulatory
treatment of Voice over Internet Protocol (VoIP) telephone service.
APCO.s interest in
this matter flows from its concern that VoIP, if not properly regulated,
could seriously
undermine 9-1-1 service as VoIP grows and becomes a common source of
voice
communication.

Today, the public enjoys highly reliable access to .Enhanced 9-1-1.
service over
the vast majority of wireline telephones.  Their calls are routed
automatically to the
correct Public Safety Answering Point (PSAP), along with Automatic
Location
Information (ALI) and Automatic Number Identification (ANI).  This
E9-1-1 service
greatly improves the speed and accuracy of emergency call-taking and
deployment of
emergency personnel.

In recent years, the FCC has recognized the vital role of E911, and has
adopted
comprehensive rules to ensure that wireless telephone service also
provides E911
capability.   Our concern is that VoIP is today where wireless was 5-10
years ago, a
nascent service on the verge of becoming a major vehicle for telephone
communication
and 9-1-1 calls.

APCO has adopted the attached resolution regarding VoIP.  Consistent
with that
resolution, we urge the Commission to take all necessary steps to ensure
that all 9-1-1
calls, whether over traditional wireline, wireless, or VoIP, provide
E9-1-1 capability in an
effective and efficient manner.

Respectfully submitted,
/s/

Robert M. Gurss

October 27, 2003

Association of Public Safety Communications Officials, Inc.
Resolution

Voice Over The Internet Telephone Services

Whereas, Voice over Internet telephone services is a telecommunications
methodology that utilizes the internet to transmit live switched voice
telephone
calls over the internet using Voice over Internet Protocol (VoIP)
(commonly
referred to as Voice on the Net or VON) versus sending them over
conventional
commercial telephone circuits/long distance networks and switching
systems;
and Whereas, When the VON system is utilized, analog voice signals from
the
telephone are converted to digitally  modulated "packets" and
transmitted in
digital format just as computer data or  digital video signals would be
via the
internet to an IP (Internet Protocol) address where the call could be
converted to
analog and completed over the Public Switched Telephone Network or could
be
directly connected to another VoIP telephone; and Whereas, Although this

technology is still emerging and developing, it is growing
in popularity; and Whereas,  Telephone service utilizing the
Voice over the Internet has serious
implications for enhanced 9-1-1 systems;

NOW, THEREFORE BE IT RESOLVED:

That APCO strongly encourage all providers of VON telephone services
take
action to ensure that when an emergency 9-1-1 call is placed from a
telephone
using VON, the call is completed to the appropriate Public  Safety
Answering
Point (PSAP) and the physical address of the caller.s location is
displayed via the
Automatic Location Identification (ALI) database; and be it further
resolved
That APCO recognizes the authority of  state and local government to
assess
9-1-1 fees, where authorized by valid statutes, against VON subscribers
and the
responsibility of VON providers to collect and submit the  9-1-1 fees;
and be it
further resolved

That APCO recognizes the authority of the PSAP to determine 9-1-1 call
routing,
including routing of 9-1-1 calls placed utilizing VON technology, based
upon its
jurisdictional requirements and policies; and be it finally resolved

That APCO does not support routing 9-1-1 calls, including those placed
utilizing
VON, to an agency.s ten-digit administrative lines, except as necessary
in a short
term interim solution, with the agreement of the PSAP.
http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515287380