White Paper. Is VoIP Without E9-1-1 Worth the Risk? Challenges, Approaches, and Recommendations for VoIP Service Providers



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TeleCommunication Systems, Inc. www.telecomsys.com Is VoIP Without E9-1-1 Worth the Risk? Challenges, Approaches, and Recommendations for VoIP Service Providers

Notices 2004 TeleCommunication Systems, Incorporated. All rights reserved. No part of this, including text, diagrams, or icons, may be reproduced or transmitted in any form, by any means (electronic, photocopying, recording, or otherwise) without the prior written permission of TeleCommunication Systems, Incorporated. Note to U.S. Government Users Documentation related to restricted right - use, duplication, or disclosure by the Government is subject to restrictions set forth in subparagraphs (a) through (d) of the Commercial Computer - Restricted Rights clause at FAR 52.227-19 when applicable, or in subparagraph (c)(1)(ii) of the Rights in Technical Data and Computer Software clause at DFARS 252.227-7013, and in similar clauses in the NASA FAR Supplement. Information in this document is subject to change without notice. TeleCommunication Systems, Incorporated may have patents or pending patent applications, trademarks, copyrights, or other intellectual property rights covering subject matter in this document. The furnishing of this document does not give you license to these patents, trademarks, copyrights, or other intellectual property. Please send licensing inquiries to: TeleCommunication Systems, Incorporated, 275 West Street, Annapolis, Maryland, 21401. LIMIT OF LIABILITY/DISCLAIMER OF WARRANTY: THIS PAPER IS LICENSED AND/OR PROVIDED AS IS WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, REGARDING THE CONTENTS OF THIS PAPER, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES FOR THE PAPER S QUALITY, PERFORMANCE, MERCHANTABILITY, OR FITNESS FOR ANY PARTICULAR PURPOSE. IN NO EVENT SHALL TELECOMMUNICATION SYSTEMS, INC., OR ITS DEALERS OR DISTRIBUTORS BE LIABLE TO THE PURCHASER, OR ANY THIRD PARTY ASSOCIATED WITH THE PURCHASER, FOR LOST PROFITS, OR ANY OTHER CONSEQUENTIAL, INCEDENTIAL, OR PUNITIVE DAMAGES, EVEN IF ADVISED IN ADVANCE OF THE POSSIBILITY OF SUCH DAMAGES. Trademark Attributions Enabling Convergent Technologies is a registered trademark of TeleCommunication Systems, Incorporated. All rights reserved. All other trademarks, logos and service marks are property of their respective owners. i i

Table of Contents INTRODUCTION...1 THE BUSINESS CHALLENGE: MEETING CONSUMER EXPECTATIONS...1 THE CURRENT 9-1-1 LANDSCAPE...1 TECHNICAL CHALLENGES...3 CURRENT APPROACHES AND LIMITATIONS...4 NEW INDUSTRY STANDARDS...5 RECOMMENDED APPROACH...8 IMPLEMENTATION CONSIDERATIONS...8 TCS VOIP E9-1-1 SERVICE...9 ii ii

Is VoIP Without E9-1-1 Worth the Risk? Introduction When your subscribers dial 9-1-1, they expect a public safety responder to answer and dispatch help in a matter of seconds. However, when it comes to 9-1-1, Voice over Internet Protocol (VoIP) services do not always deliver. This paper details the importance of Enhanced 9-1-1 (E9-1-1) to VoIP s future success and the challenges VoIP Service Providers (VSPs) face in providing E9-1-1 services. It also reviews the various approaches VSPs are taking to address E9-1-1 and provides recommendations to VSPs for achieving successful, future-proof E9-1-1 implementations. The Business Challenge: Meeting Consumer Expectations VoIP involves the transmission of voice data packets using Internet Protocol (IP). VoIP presents an attractive business model to service providers because it enables them to offer voice services at a fraction of the price of traditional wireline services and at the same time offer premium services at higher margins (e.g., video conferencing, multimedia messaging and unlimited call bridging). While many consumers are attracted by VoIP's inexpensive voice service, others appreciate VoIP for the additional flexibility and mobility it offers. For instance, a residential VoIP subscriber living in North Dakota might use a Florida phone number so his family in Florida can call him without incurring long distance charges. A businesswoman might subscribe to VoIP so she can take advantage of premium services while on the road. But there is one major drawback to today s VoIP services. In the absence of reliable 9-1-1 services, consumers may refuse to rely on VoIP as their primary phone service, and others may not adopt it at all. If VSPs fail to deliver comprehensive E9-1-1 services, the FCC may step in and mandate it. VSPs who want to avoid these business and regulatory risks must overcome a number of technical challenges set forth below. These challenges are best understood in the context of the wireline and cellular E9-1-1 solutions in use today. The Current 9-1-1 Landscape In order for emergency services to be dispatched to a 9-1-1 caller, the caller must be located, the call must be routed to the nearest of over 6,500 Public Safety Answering Points (PSAPs), and the caller s location must be automatically delivered to that PSAP. With traditional landline phone 1 1

service, the phone company can easily determine the location of the caller, since it installed the physical phone line and set up the service at a specific address. This location information is stored in an Automatic Location Identifier (ALI) database. Information stored in the ALI database is used to provision selective routers, which route 9-1-1 calls to PSAPs, along with the caller s phone number and address. This process is depicted in the call flow below. Wireline E9-1-1 Call Flow When cellular phones were introduced, their mobility caused some new challenges for locating the caller, routing the call to the closest PSAP, and automatically delivering the caller's location and callback number to the PSAP. Cellular carriers solved the location problem by using technology that identifies the location of the closest cell tower ( Phase I ) and by deploying technology like GPS into their networks so they can identify a caller s latitude and longitude ( Phase II ). Cellular companies contracted with service bureaus to convert this location data into a format compatible with emergency services systems so that it could be automatically routed to the closest PSAP along with the call. However, because selective routers were designed to work with landline phones, they don t automatically recognize cell phone numbers; consequently, selective routers were not able to route cellular 9-1-1 calls. To solve this problem, cellular carriers created selective router-recognizable 10-digit numbers that could be temporarily associated with a cell phone number. Service bureaus then provisioned these numbers into the ALI databases and selective routers, so that cellular 9-1-1 calls could be routed to the correct PSAP. This approach has become the preferred solution for 2

supporting E9-1-1 functionality in cellular networks and is depicted in the diagram below. Wireless E9-1-1 Call Flow Technical Challenges Because VoIP services use IP networks rather than landline or cellular networks, VoIP E9-1-1 requires a different solution. VSPs must resolve a new set of challenges for determining the location of the caller, routing the call to the closest PSAP and automatically delivering the caller s location and call back number to the PSAP. The challenge of locating VoIP 9-1-1 is a consequence of VoIP's flexibility. Depending on their level of mobility, VoIP subscribers can be classified as static, nomadic or mobile. Static subscribers use VoIP as a landline supplement or replacement, typically using residential cable or DSL. Their VoIP phone is deployed in a fixed location and uses the standard North American Numbering Plan. LECs can support static VoIP subscribers with local telephone numbers in the same way they support their wireline subscribers: by provisioning each VoIP number into the ALI database so the selective routers can recognize and correctly route the 9-1-1 calls. But in most cases, this wireline model only supports static subscribers with local phone numbers. Because of the frequent use of non-local phone numbers, VSPs face challenges similar to those once faced by cellular carriers in terms of routing calls and location data through selective routers that don t recognize numbers from outside their area. 3

Nomadic subscribers view VoIP as a highly portable telephony configuration that allows them to establish a telecommunication connection wherever they can obtain Internet access. Nomadic users take their VoIP service with them while on the go, connecting at the airport, in their hotels, and at any available hot spot. Mobile subscribers not only take their VoIP phone with them wherever they go, but they remain continuously connected. Much like cellular technologies allow today, mobile VoIP subscribers will eventually be able to roam from their home-based telephony connection throughout a continuously interconnected Wireless Fidelity (WiFi) network. As coverage of WiFi hot spots and other wireless methods for WiFi access become ubiquitous, the number of mobile VoIP subscribers is expected to increase. Because of the mobility of nomadic and mobile VoIP subscribers, VoIP 9-1-1 solutions are dependent upon all subscribers to accurately identify their location when they register for VoIP services, as well as every time they log in. However, since it often takes 24-48 hours for subscriber location data to be updated in the ALI database, new solutions are required for rapidly updating location data. Current Approaches and Limitations VSPs are addressing the 9-1-1 issue with three main approaches. The first is to simply not offer 9-1-1 services. VSPs who adopt this approach feel no obligation to offer 9-1-1 services to their customers because VoIP is not a telecommunications service and is therefore unregulated. This approach may resolve the VSP's problem in the short term, but in the long term it is detrimental to the entire VSP industry. Without E9-1-1 services, the public is unlikely to adopt VoIP as a replacement to traditional wireline services; to protect those who do, the FCC would likely mandate VoIP E9-1-1. The second approach uses routing tables to map a caller s IP phone to the appropriate PSAP serving his or her area. When the caller dials 9-1-1, the VSP uses these routing tables to convert the call to a 10-digit number that rings a designated 24x7 administrative line at the PSAP. Calls to administrative lines do not receive the level of attention that regularly-routed emergency calls receive, and unfortunately they sometimes go unanswered. For this reason, and since this approach does not include automatic delivery of address information to the PSAP, the National Emergency Number Association (NENA) has deemed "10-digit routing" to be a minimally sufficient short-term solution. A third approach requires the establishment of dedicated circuits or redundant DS-0 trunk groups over diverse T1s to the selective routers. "Direct trunking" is a non-standard approach that is unlikely to win the widespread support of PSAPs because it requires major changes to the 4

current system: installation of a facilities-based network, deployment of specialized switches, significant investment in circuits, and interconnection agreements with the ILECs. Additionally, direct trunking is ineffective for subscribers with non-local phone numbers. New Industry Standards In an effort to help VSPs deploy viable E9-1-1 solutions, NENA has worked with the telecommunications and public safety communities to develop recommended call flows. In each of the recommendations currently being deployed, the burden is on subscribers to keep their location information upto-date. In the I1 stage of deployment, the VoIP 9-1-1 call is delivered to a 24x7 administrative line without the caller s location; the caller s phone number is only provided when caller ID is available on the receiving PSAP phone. This approach is detailed in the diagram below. VoIP E9-1-1 I1 Call Flow 5

In the I2 stage of deployment, the VoIP 9-1-1 call is delivered to the correct PSAP via a selective router infrastructure solution. In this call flow, the caller's location and callback number are automatically delivered to the PSAP without any required hardware or software upgrades to the existing PSAP E9-1-1 infrastructure. The I2 approach is detailed in the diagram below. VoIP E9-1-1 I2 Call Flow 6

The following table summarizes the location, routing, and delivery mechanisms employed by landline, cellular, and VoIP E9-1-1 services: Enhanced 9-1-1 Summary Landline Cellular Phase I Cellular Phase II VoIP I1 VoIP I2 Location Routing Delivery Provisioned in ALI Routing based on exact database; takes 24-48 location of landline phone; hours to be activated; call is routed through the based on where the phone selective router; the PSAP is installed, so it is highly is associated with the accurate; does not allow caller's location prior to for mobility the call Based on cell tower location; is not the caller's precise location; margin for error can range from a few city blocks to several miles Precise location based on GPS or network-based calculation; accuracy is 300 meters or less; location derived in 20 seconds or less Provided by VoIP subscriber prior to the 9-1- 1 call; subscriber must update location each time they move in order to be accurate Allows for calculation of exact location of the caller; current solutions rely on location provided by VoIP subscriber prior to the 9-1-1 call Routing based on cell site location; call is routed through the selective router; PSAP is identified as part of the call flow; accuracy is dependent upon the placement of the cell tower Routing based on precise location; call is routed through the selective router; PSAP is identified as part of the call flow; defaults to cell site if precise location is not determined quickly enough Routing is based on subscriber-provided location; PSAP is identified as part of the call flow; call is routed to a 10-digit administrative line Routing is currently based on subscriber-provided location; call is routed through the selective router; PSAP is identified as part of the call flow Call back number, voice channel and subscriber's location are delivered to the PSAP across established emergency services trunks Call back number, voice channel and closest cell tower location information are delivered to the PSAP across established emergency services trunks Call back number, voice channel and caller's precise location information are delivered to the PSAP across established emergency services trunks Voice channel is delivered to the PSAP via a 10-digit admin line; no location is delivered; call back number is visible if the phone is equipped with caller ID Call back number, voice channel and caller's precise location information are delivered to the PSAP across established emergency services trunks 7

Recommended Approach There is no doubt that accurate and reliable 9-1-1 services will be an integral component of VoIP s future success. As such, VSPs must quickly respond to the challenges of locating 9-1-1 callers, routing the calls to the nearest PSAP and automatically delivering caller location and call back number to the PSAPs. The best approach for resolving these challenges is for VSPs to deploy comprehensive I2 solutions. The major benefits of the I2 approach are rapid validation of caller location, simplified PSAP integration and accurate location, routing and delivery for all types of VoIP subscribers. Rapid address validation represents an obvious advantage to VoIP subscribers: while database solutions can require 24-48 hours to validate address updates, network technology-based solutions can provide address validation within an hour. Additionally, PSAPs prefer I2 solutions because they cannot afford to make further upgrades to emergency communication systems. (Recently PSAPs were required to make costly technology upgrades to support cellular E9-1-1 services. Most have just fulfilled these requirements, and they are unlikely to make substantial new upgrades voluntarily in the near future.) By selecting a solution that is familiar to the PSAP, VSPs can avoid having 9-1- 1 calls misrouted to PSAP administrative lines. The end result is the ability to deliver fast, reliable, and accurate E9-1-1 services for all VoIP subscribers, whether static, nomadic, or mobile. Moving to an I2 solution opens the door to additional benefits: in the near future there may be IP services that automatically send additional useful information to the PSAPs. Medical history, emergency contacts and other relevant data could be instantly transmitted across the IP network and delivered to emergency responders. Implementation Considerations In order to deploy an I2 solution, a VSP will need to implement a method for gathering and validating subscriber addresses as close to real-time as possible, establish connectivity from their call server or their SIP Server to a VoIP Positioning Center, and obtain access to nationwide selective routers. Potential implementation partners should provide VSPs with real-time address validation and geocoding, as well as selective router access; these capabilities ensure VoIP E9-1-1 calls are routed directly to PSAP dispatchers (vs. PSAP administrative lines). By selecting an implementation partner who is an active participant in the development of E9-1-1 standards, VSPs can also enjoy the benefits of future-proof solutions that conform to industry (and possibly regulatory) standards. And since VSPs need PSAPs to be willing partners in the implementation process, potential implementation partners should 8

demonstrate that they have earned the respect and trust of the PSAPs community. Finally, VSPs should select a provider with proven experience in implementing end-to-end solutions that support mobile subscribers. TCS VoIP E9-1-1 Service TCS offers VSPs the only comprehensive, future-proof E9-1-1 service that is I2-compliant and meets the needs of both subscribers and PSAPs. TCS VoIP E9-1-1 Service offers rapid address validation, simplified PSAP integration, and accurate location, routing and delivery for static, nomadic, and mobile VoIP subscribers. Why TCS? TCS developed and deployed the world s first cellular location platform in 1996 and has since become a proven leader in the E9-1-1 industry as well as a trusted partner to both cellular carriers and the emergency services community. TCS has E9-1-1 service contracts with more than 30 service providers that support over 50 million subscribers nationwide. Continuing leadership in the development of E9-1-1 standards enables TCS to offer future-proof VoIP E9-1-1 solutions in the same distributed, multi-threaded and auto-aware environment as its proven cellular E9-1-1 services. For more information on TCS VoIP E9-1-1 Service, please call 206-792- 2000 or visit our website at www.telecomsys.com. 9