BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C

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1 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C In the Matter of ) ) IP-Enabled Services ) WC Docket No ) E911 Requirements for IP-Enabled ) WC Docket No Service Providers ) ) COMMENTS OF THE TELECOMMUNICATIONS INDUSTRY ASSOCIATION The Telecommunications Industry Association (TIA) hereby submits comments to the Federal Communications Commission (Commission) in response to the Notice of Proposed Rulemaking (NPRM) in the above-captioned proceeding. 1 TIA is a leading trade association for the information and communications technology (ICT) industry, with 600 member companies that manufacture or supply the products and services used in global communications. TIA represents its members on the full range of public policy issues affecting the ICT industry and forges consensus on industry standards. Among their numerous lines of business, TIA member companies design, produce and deploy network and terminal equipment, including equipment used in IP-enabled networks. TIA engineering committees also produce technical standards in 1 IP-Enabled Services and E911 Requirements for IP Enabled Services, WC Docket Nos and , First Report and Order and Notice of Proposed Rulemaking (released June 3, 2005).

2 response to requirements from customers, consumers, and the public safety community. As a result, TIA has a substantial interest in current and future Commission decisions and activities related to the development of IP-enabled networks and services and access to advanced 911 capabilities. TIA applauds the Commission s forward movement in classifying cable modem services and wireline broadband Internet access services as information services under the Communications Act. TIA also applauds the Commission for its diligence in addressing critical public safety issues. These decisions together will pave the way for future investment and innovation in the ICT industry, while remaining mindful of important social obligations. In response to the Commission s questions posed in this NPRM, TIA respectfully urges the Commission to refrain from requiring VoIP providers to automatically provide location information by June 2006, and to refrain from imposing E911 or CMRS 911/E911 obligations on wireless broadband connections such as Wi-Fi or WiMax. In many instances, it is feasible for industry to comply with Title II of the American Disabilities Act (ADA) requirements that PSAPs be directly accessible to text telephones (TTYs). I. A JUNE 2006 DEADLINE FOR PROVIDING LOCATION INFORMATION IS PREMATURE AND BURDENSOME TIA urges the Commission to refrain from requiring all terminal adapters or other equipment used in the provision of interconnected voice over Internet-protocol (VoIP) service sold as of June 1, 2006 to be capable of providing location information automatically. An unrealistic timetable will only impede development of innovative, sustainable, and efficient solutions. 2

3 Industry is already actively developing standards that will aid in providing automatic location information. For example, TIA engineering subcommittee TR 41.4 is currently developing SP (to become TIA-1057), Link Level Discovery Protocol (LLDP) Media Endpoint Discovery (MED), which is an extension of the IEEE 802.1ab LLDP protocol that will allow, among other things, VoIP terminals to discover and report their location for E911 purposes. This standard, nearly ready for publication, applies to any VoIP device connected through an Ethernet interface, and provides a method of conveying location information between the VoIP endpoint and the access equipment immediately upstream from the VoIP endpoint. Importantly, only the broadband access provider actually has the ability to determine the location of the VoIP endpoint and in a true Internet VoIP environment, there may not be a relationship between the broadband access provider and the provider of the VoIP services. Thus, the location data must be transported via signaling from the VoIP endpoint to the VoIP Call Control application. Clearly, the access network has a critical role to play in providing location information to VoIP endpoints which cannot autonomously determine their location. Thus, TIA-1057 it is not an end-to-end solution since it requires technical standards support from other organizations including a National Emergency Number Association (NENA) interface that standardizes the delivery of information to public safety answering points (PSAPs). In addition, a TIA telecommunications systems bulletin, TSB-146, explores several potential solutions for supporting E911 within the enterprise. 3

4 While representing significant industry progress, development of these standards alone should not be used as justification for a June 2006 deadline. Serious technical limitations will remain in the ability of a VoIP system to automatically convey location information to the appropriate PSAP. Until adequate methods are available to accomplish this conveyance, the ability of VoIP systems to comply with this proposed requirement is severely jeopardized. TIA also notes that with current E911 implementation efforts continuing to prove time consuming and technically complex, TIA believes new Commission initiatives here would be premature and would divert scarce resources from the ongoing efforts of not only industry but the overburdened PSAPs as well. Moreover, decisions regarding how best to cooperate with public safety and emergency services are more appropriately dealt with by the companies and engineers who manufacture and develop the products and services themselves. The industry is accustomed to developing its own technologies while complying with numerous socially driven goals, and will continue to do so with respect to E911. II. WIRELESS INTERCONNECTED VOICE SERVICES SHOULD NOT BE SUBJECT TO E911 OR CMRS 911/E911 REQUIREMENTS TIA also urges the Commission to refrain from imposing E911 or CMRS 911/E911 obligations on wireless broadband connections such as Wi-Fi or WiMax at this time. Due to the mobility limitation of Wi-Fi technology the end user is not able to venture far from the router location information already would be available from the wireline connection. In addition, WiMax technology is not yet mature enough to most effectively evaluate the best methods for providing E911 or CMRS 911/E911 4

5 compliance. As such, providers of wireless interconnected voice services should not be subject to these regulations. III. IN MANY INSTANCES, IT IS FEASIBLE FOR INDUSTRY TO COMPLY WITH TITLE II OF THE AMERICAN DISABILITIES ACT (ADA) REQUIREMENTS THAT PSAPS BE DIRECTLY ACCESSIBLE TO TTYS Finally, it is feasible for VoIP providers to comply with Title II of the American Disabilities Act (ADA) requirements that PSAPs be directly accessible to TTYs, in many instances. Responding to industry studies which showed that TTY devices used by the deaf and hard of hearing did not operate reliably through VoIP networks, TIA engineering subcommittee TR-30.1 developed TIA-1001, Transport of TIA-825-A Signals over IP Networks, standard. The standard was approved in October TIA-825-A, A Frequency Shift Keyed Modem For Use On The Public Switched Telephone Network, is the TIA standard for the modem found in Baudot TTY devices. TIA-1001 was originally conceived as a standard to be used in gateways between the PSTN and IP networks; however, recent investigations by TR-30.1 have shown that it also applies to IP telephones and IP Terminal Adapters. If support for TIA-1001 were to be included in IP phones and/or terminal adapters and at the gateway associated with the PSAP, reliable TTY communications with the PSAPs can be assured. IV. CONCLUSION The ongoing standards activities highlighted above should serve as evidence of industry s longstanding commitment to the development of solutions that ensure access 5

6 to advanced 911 solutions for products and services where consumers reasonably assume such functionality. An unrealistically aggressive compliance mandate from the FCC will likely impede and disrupt these successful efforts. For the foregoing reasons, TIA respectfully urges the Commission to refrain from requiring VoIP providers to provide location information by June 2006, and to refrain from imposing E911 or CMRS 911/E911 obligations on wireless broadband connections such as Wi-Fi or WiMax. Additionally, in many instances, it is feasible for industry to comply with Title II of the American Disabilities Act (ADA) requirements that PSAPs be directly accessible to TTYs. Respectfully submitted, Grant Seiffert Vice President, External Affairs & Global Policy Derek Khlopin Director, Law & Public Policy Danielle Jafari Manager, Regulatory & Government Affairs August 15, 2005 Bill Belt Director, Technical Regulatory Affairs 6

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