1. VoIP and Enhanced 911 Services - Can you find me now?
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911 System Concerns Related to VoIP
Verizon uses the wildly successful phrase ‘Can you hear me now?’ to imply that
telecommunications reliability and communication quality can be measured with end-to-end
connectivity tests performed by people traveling throughout the United States. Providers of
Voice over Internet Protocol (VoIP) services testing end-to-end connectivity, reliability and
quality of emergency 911 services could summarize today’s most significant challenges with the
phrase ‘Can you find me now?’
Looking beyond the regulatory confusion surrounding VoIP, there are significant public
safety concerns regarding the emergency 911 services provided to VoIP subscribers, including
whether all VoIP vendors must offer such services, how infrastructure and service provider
relationships can be improved, and whether caller ‘location’ information is available and reliable.
This article overviews emergency 911 system concerns, emergency 911 legislation in process,
and challenges and recommendations affecting VoIP subscriber access to emergency 911
Overview - VoIP Regulation
“Since its creation in 1995, Voice over Internet Protocol has benefited from the confusion
of regulatory classifications and developed as a relatively unregulated technology.”1 VoIP is an
Internet application allowing real time voice communications2 that “offer[s] a service that is
almost indistinguishable, from the consumers’ point of view, from the service offered by
interstate telecommunications service providers.”3 As a substitute for ‘plain old telephone
service’ (POTS) or for cellular telephone service, VoIP provides economic benefits to
Ryan K. Mullady, Regulatory Disparity: The Constitutional Implications of Communications Regulations that
Prevent Competitive Neutrality, 7 PGH. J. TECH. L. & POL'Y 7, para. 9 (2007).
John B. Morris, Jr., 2004 Privacy in Review Special Topic: VoIP: Privacy Year in Review: Privacy and VoIP
Technology, 1 ISJLP 509, 510 (2005).
Assessment and Collection of Regulatory Fees for Fiscal Year 2007, 72 FR 45908, 45912 (2007).
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2. VoIP and Enhanced 911 Services - Can you find me now?
subscribers and providers, but “security issues must be addressed or [the] economic benefits
could be lost in the wake of a malicious attack.”4
Congress has indicated that the Internet should be regulation free, but at the same time,
has directed that national public policy goals, such as emergency 911 services, should “continue
to apply as communications networks evolve.”5 “The FCC has declared VoIP to be within its
jurisdiction as an interstate service, thus preempting state regulation.” 6 Though not regulated as
fully as other telecommunication services, VoIP services are not “beyond the reach of
regulations designed to promote public safety and consumer protection,”7 and “the explosive
growth of the VoIP industry in recent years has resulted in recent [Federal Communication]
Commission actions addressing the service.”8 One such national public policy goal, regulated to
promote public safety, is emergency 911 services,9 because “[o]ne problem with allowing VoIP
to operate free of any regulation is that consumers are increasingly turning to VoIP as a lower-
cost alternative for traditional telephony without the knowledge that VoIP does not necessarily
provide reliable 911 service.”10
Emergency 911 Services – Basic and Enhanced
The National Emergency Number Association estimated that 911 services were available
to 99 percent of the United States.11 Emergency 911 services have existed for over forty years,12
Emily Frye & Gregory Staita, Hold the (Internet) Phone! The Implications of Voice-over-Internet Protocol (VoIP)
Telephony for National Security & Critical Infrastructure Protection, 1 ISJLP 571, 572 (2005).
In the Matter of IP-Enabled Services, 19 FCC Rcd. 4863, 4893 (2004).
Melissa Winberg, Calling All Angles: Perspectives on Regulating Internet Telephony, 10 VAND. J. ENT. & TECH. L.
241, 258 (Fall 2007). “The FCC maintains it has authority to regulate VoIP service providers with respect to E911
under the Communications Act of 1934 as amended by the 1996 Telecom Act by virtue of its Title I powers.” Linda
A. Rushnak, Is Voice Over Internet Protocol (VoIP) Subject to Regulation Under the Telecommunications Act of
1996?, 17 ALB. L.J. SCI. & TECH. 213, 225 (2007).
In the Matter of IP-Enabled Services, supra note 5, at 4867.
Assessment and Collection of Regulatory Fees for Fiscal Year 2007, supra note 3, at 45912
Rushnak, supra note 6 at 219.
Andrea W.M. Louie, Imposing Geographical "Locateability" for Voice Over Internet Protocol, 51 N.Y.L. SCH. L.
REV. 654, 674 (2006-2007).
In the Matters of IP-Enabled Services; E911 Requirements for IP-Enabled Service Providers, 20 FCC Rcd.
10245, 10248 (2005) (hereinafter E911 Requirements).
In the Matter of IP-Enabled Services, supra note 5, at 4897.
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and although customers may not understand the underlying technology, VoIP subscribers might
assume that emergency 911 services work the same as for traditional telephones,13and when
dialing 9-1-1 expect the call to be answered by an emergency operator, 14 and that emergency
responders can be dispatched to the caller’s location.15 VoIP technology provides callers with
several benefits, but because VoIP “services can be used from virtually any Internet connection,
the location of the caller cannot be automatically determined,”16 which introduces the challenge
of appropriately dispatching emergency responders.
Emergency 911 services include basic 911 and enhanced 911 (E911) services. 17 The FCC
assumed authority “to determine whether the public interest required that a provider of a
particular service should be required to provide 911/E911 to its customers, and if so, to what
extent and in what time frame such covered service should be subject to the Commission’s
911/E911 requirements.”18 Providers are required to make emergency 911 services available
• The entity offers real-time, two-way switched voice service, interconnected
with the public switched network, either on a stand-alone basis or packaged
with other telecommunications services
• Customers using the service or device have a reasonable expectation of access
to 911 and enhanced 911 services
• The service competes with traditional [commercial mobile radio service] or
wireline local exchange service, and
• It is technically and operationally feasible for the service or device to support
Louie, supra note 10, at 677.
A 9-1-1 call is typically answered by either a primary or a secondary Public Safety Answering Point. “A primary
PSAP is defined as a PSAP to which 911 calls are routed directly from the 911 Control Office, such as, a selective
router or 911 tandem. A secondary PSAP is defined as a PSAP to which 911 calls are transferred from a primary
PSAP.” PSAP Registry, http://www.fcc.gov/pshs/services/911-services/enhanced911/psapregistry.html (last visited
Mar 10, 2008).
Closing Remarks of Commissioner Deborah Taylor Tate, Accenture Global Convergence Forum 2006, Beijing,
China, 2006 FCC LEXIS 2920, *11 (2006).
FCC Consumer Advisory, VoIP and 911 Service, http://www.fcc.gov/cgb/consumerfacts/voip911.html (last visited
Mar 10, 2008).
In the Matter of IP-Enabled Services, supra note 5, at 4898. A VoIP subscriber’s 9-1-1 call could be processed by
either basic 911 services or enhanced 911 services, or neither of the services. Access to 9-1-1 Emergency Services,
http://www.911voip.org/voip.htm, (last visited Mar. 14, 2008).
In the Matter of IP-Enabled Services, supra note 5, at 4899.
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Basic 911 service routes calls to a Public Safety Answering Point (PSAP),20 but does not
define the type of information that must accompany the call.21 Enhanced 911 (E911) seeks to
improve upon basic 911 services by providing additional information. 22 The FCC divided the
E911 program for wireless services into two phases. In Phase I, providers forward the caller’s
telephone number, and the location of the cell site or base station transmitting the call, to
PSAPs.23 In Phase II, Providers forward the caller’s latitude and longitude to PSAPs, within
specified reliability and accuracy standards.24
As of 2005, some VoIP providers did not offer emergency 911 services, or may have
required subscribers to provide location information prior to first use of emergency 911
services.25 “Upon learning that some VoIP subscribers were having difficulties accessing
emergency services, the FCC acted quickly and decisively to remedy the situation.” 26 In May
2005, the FCC released In the Matters of IP-Enabled Services; E911 Requirements for IP-
Enabled Service Providers,27which required interconnected28 VoIP providers to support E911
Id. at 4900.
E911 Requirements, supra note 11, at 10248. “Public Safety Answering Point (PSAP) – A 911 answering station
designated to receive 911 calls from a specific geographic area.” FCC, OET BULLETIN No. 71, Guidelines for
Testing and Verifying the Accuracy of Wireless E911 Location Systems, pg. 9, Apr. 12, 2000 (hereinafter OET).
In the Matter of IP-Enabled Services, supra note 5, at 4898.
Enhanced 911 - Wireless Services, http://www.fcc.gov/pshs/services/911-services/enhanced911/Welcome.html
(last visited Mar 10, 2008). In 1980, AT&T introduced the first E911 system for traditional telephone systems,
which automatically provided the caller’s telephone number and location. Louie, supra note 10, at 660.
Enhanced 911 - Wireless Services, supra note 22.
Id. “Phase II accuracy. (1) By September 11, 2012, licensees subject to this section shall comply with the
following standards for Phase II location accuracy and reliability, to be tested and measured at the PSAP service
area geographic level: (i) For network-based technologies: 100 meters for 67 percent of calls, 300 meters for 95
percent of calls; (ii) For handset-based technologies: 50 meters for 67 percent of calls, 150 meters for 95 percent of
calls.” 47 CFR 20.18(h) (2008).
Clinton Howard Brannon, Reach Out and Tax Someone: What Does the Future Hold for the Taxation and
Regulation of Voice Over Internet Protocol Telephone Services? 57 ALA. L. REV. 173, 198 (2005).
E911 Requirements, supra note 11, at 10245.
“‘[I]nterconnected’ refers to the ability of the user generally to receive calls from and terminate calls to the public
switched telephone network (PSTN), including commercial mobile radio service (CMRS) networks.” Id. at 10246
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services29 by selecting from three methods:
• Interconnecting to the E911 network indirectly through a third party
• Interconnecting directly to the E911 network, or
• Employing any other method that allows them to provide E911 service30
In 2006, Vonage, a VoIP provider, reported that about 70% of Vonage subscribers had
E911 access, and as of March 2008, over 98% of Vonage subscribers have E911 services.31
E911 services are a complicated cross section of regulations.32 While PSAPs are State
regulated, the FCC regulates VoIP services.33 VoIP providers are challenged in connecting E911
calls to the appropriate PSAP,34 because: “(1) callers may not be able to connect to 9-1-1
dispatch centers; and (2) there is no guarantee that callers’ location information is correct when
sent to a 9-1-1 dispatch center from a VoIP system.”35
In some locations, the way a VoIP provider transfers subscriber calls from the Internet to
the Public Switched Telephone Network (PSTN) may cause a 911 call to be connected to a fire
or police department instead of a PSAP.36 To connect directly to a PSAP, the VoIP provider must
interconnect with a Local Exchange Carrier (LEC), but “[s]ome LECs have refused to cooperate
with VoIP services in providing 9-1-1 access.”37 To address connectivity concerns, some VoIP
providers display a disclaimer regarding emergency 911 services limitations, or may recommend
Id. at 10246. The FCC’s sense of urgency is highlighted in a footnote that stated the VoIP E911 order was released
in advance of other IP-Enabled service issues, because the Commission sought to address public safety concerns.
“For example, [the Commission was] aware of a recent incident in Texas in which it was reported that a 911 call
was not completed when an interconnected VoIP user dialed 911 to seek emergency assistance during a home
invasion burglary.” Id. at 10246 n.2.
Brannon, supra note 25, at 200.
Brian Solomon, VoIP Customers Soon to Have 911 Service, http://www.tmcnet.com/enews/e-newsletters/Internet-
Telephony/20080310/22454-voip-customers-soon-have-911-service.htm (last visited Mar. 12, 2008).
Brannon, supra note 25, 192.
Frye & Staita, supra note 4, at 572.
Id. at 578.
Jerry Ellig & Alastair Walling, Regulatory Status of VoIP in the Post-Brand X World, 23 SANTA CLARA COMPUTER
& HIGH TECH. L.J. 89, 131 (2006).
Frye & Staita, supra note 4, at 578.
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maintaining traditional telephone services at the caller’s physical location.38
The challenge of ensuring end-to-end connectivity for emergency 911 services has fueled
a number of FCC requests for information, including an Information Collection Regarding
Redundancy, Resiliency and Reliability of 911 and E911 Networks and/or Systems.39 This request
seeks public input on a proposed rule requiring all emergency 911 service or infrastructure
providers to provide state-by-state reports through a restricted web-based database.40 The data
provided would identify physical and logical redundancies within the emergency 911 services
infrastructure.41 VoIP providers would be required to provide identification information,
information about interconnection to other providers, physical and logical redundancy statistics,
reasons why redundancies might not be available, and plans to improve redundancy.42 All
providers would supply plans for disaster recovery, service re-routing, service restoration, as
well as plans for migrating to the next generation of emergency 911 architecture.43
Although 911 services require a VoIP provider have a “method for determining a user’s
location without assistance from the user,”44 a first step is to require VoIP providers to retain, for
each customer, a default location, which is “the physical location at which the service will first
be utilized.”45 If the caller is not at the default location, the caller may have to provide the city,
county and state where help is needed.46 Unlike basic 911 services, a VoIP subscriber’s
Notice of Public Information Collection(s) Being Reviewed by the Federal Communications Commission,
Comments Requested, 73 FR 10769 (Feb. 28, 2008).
Id. at 10770-10773.
Id. Redundancy lowers the risk that a single failure will disable an entire system. Physical redundancy is the
availability of an alternate physical route between the caller and person called, which enables bypass of a failed
hardware device. Logical redundancy is the availability of an alternate logical route between the caller and person
called, which enables bypass of failed circuitry, even though the same hardware is used.
Id. at 10772-10773.
Id. at 10773.
Brannon, supra note 25, at 200.
Id. at 199-200. “VoIP providers have initially managed this by simply having subscribers register where they
would be making their calls from. Registration can be changed easily and updated within hours of moving.” Ellig &
Walling, supra note 36, at 131.
911VoIP. org, Frequently Asked Questions, http://www.911voip.org/faqs.htm, (last visited Mar. 14, 2008).
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telephone number may not be automatically available to the emergency operator, which may
prevent a callback if the subscriber is disconnected.47
In addition, the FCC has imposed the requirement that VoIP providers must
automatically provide emergency 911 services to all subscribers, and not allow subscribers to opt
out of emergency 911 services.48
“Consumer Reports estimates that accurate location information is not delivered at the
PSAP level in nearly half of the country.”49 When public safety is at stake, the FCC “has
consistently set aggressive benchmarks for” providers, and although the FCC is “not mandating
any specific location technology or approach” to providing location information, 50 three methods
stand out. One method of providing the real time location of 911 callers is ‘handset-based
location technology’, which uses special location-determining hardware and software in a
portable or mobile phone.51 A second method is ‘network-based location technology’, which
employs hardware and software in the wireless network and another fixed infrastructure.52 A
third method is to include a wireless chip within the device used to make the call, then determine
the device’s location relative to known existing wireless access points.53
An example of ‘network-based location technology’ for determining real time location is
“cellular tower triangulation, where location is measured based on the signal strength to multiple
cellular towers.”54 Triangulation technology may improve existing emergency service offerings,
and become a competitive advantage over traditional telephone services, giving VoIP providers
The Public Safety Challenges of VoIP Services, http://www.fcc.gov/pshs/services/911-
services/voip/challenges.html (last visited Mar 10, 2008).
Wireless E911 Location Accuracy Requirements, 73 FR 8617, 8618 (Feb. 14, 2008).
Id. at 8618-19.
OET, supra note 20, at pg. 9.
Kevin Werbach, Sensors and Sensibilities, 28 CARDOZO L. REV. 2321, 2333 (Apr. 2007).
Morris, Jr., supra note 2, at 515. Location can be determined using a global positioning system within a computer
or mobile telephone. “In some parts of the world wireless services providers are already ‘pushing’ advertisements to
phones based on the location of the phone (and thus the location of the user).” Id.
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an incentive to invest in emergency service capabilities.55
Arguably, Congress has yet to expressly delegate to the FCC the right to regulate the
Internet, though the FCC has taken authority to impose regulations such as E911. Such FCC
regulations have created controversy regarding “which economic and social benefits should be
preferred or can be attained.”56 In February 2008, to address the concern regarding FCC authority
in this area, the U.S. Senate passed the IP-Enabled Voice Communications and Public Safety Act
of 2007,57 which would amend the Wireless Communications and Public Safety Act of 1999.58
VoIP and Emergency 911 Services – Congressional Bills
In 2006, a young mother in Deltona, Florida “watched her baby die as she tried in vain to
reach emergency 911. She had a telephone that she did not realize, because it was voice over the
Internet, there was no provision for emergency 911 services.” 59 After that tragedy, in which a
911 emergency response team never received the call, the IP-Enabled Voice Communications
and Public Safety Act of 2007 was introduced.60
Since the introduction of this bill, which is very similar to House bill 911 Modernization
and Public Safety Act of 2007, the FCC has taken regulatory actions to ensure VoIP subscribers
have emergency 911 services, but those regulations have gaps.61 This bill closes those regulatory
gaps by granting the FCC jurisdiction to require VoIP suppliers provide E911 service, by
resolving potential emergency 911 services liability concerns, and by requiring “the national
E-911 Implementation Coordination Office to work with industry to oversee the next generation
Frye & Staita, supra note 4, at 579.
Susan P. Crawford, The Internet and the Project of Communications Law, 55 UCLA L. REV. 359, 380-81 (Dec.
S. 428, 110th Cong. § 2 (2008).
47 U.S.C. 615 et seq.
154 Cong Rec S1205, 1208 (daily ed. Feb. 28, 2008) (statement of Sen. Nelson of Florida).
Id. The 911 Modernization and Public Safety Act of 2007, H.R. 3403, 110th Cong. § 1 (2007), was passed by the
House of Representatives on November 13, 2007.
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of emergency 911 network.”62
The Senate version of this legislation, the IP-Enabled Voice Communications and Public
Safety Act of 2007, specifies:
It shall be the duty of every IP-enabled voice service provider engaged in
interstate or foreign communication to provide 9-1-1 service, including enhanced
9-1-1 service, to its subscribers in accordance with the orders of the [Federal
Communications] Commission in effect on the date of enactment of [this Act], as
such orders may be modified by the Commission from time to time.63
The Act commits the FCC to “issue regulations granting IP-enabled voice service
providers of access to 9-1-1 components that are necessary to provide 9-1-1 service, on the same
rates, terms, and conditions that are provided to [wireless] service providers.”64 This provision
ensures that other vendors, such as Local Exchange Carriers, may not refuse to cooperate in
providing 9-1-1 access to VoIP providers. The Act allows the FCC to delegate enforcement of
these regulations to State commissions or agencies.65
The Act does not permit the FCC “to issue regulations that require or impose a specific
technology or technological standard” regarding E911 services, and, defines terms such as ‘IP-
enabled 9-1-1 service’.66
The Act amends Section 201 of the Wireless Communications and Public Safety Act of
1999 to include reference to VoIP providers and alternate emergency communication services.67
These references protect VoIP providers and alternate emergency communication service
providers from civil liability due to the provision or use of emergency 911 services.
154 Cong Rec S1205, supra note 59, at 1208.
S. 428, supra note 57.
Id. “The term 'IP-enabled 9-1-1 service' means any 9-1-1 service provided by an IP-enabled voice service
provider, including enhanced IP-enabled 9-1-1 service.” Id.
Id. An ‘alternative emergency communications service’ “means the provision of emergency information to a
public safety answering point via wire or radio communications, and may include 9-1-1 and enhanced 9-1-1
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The Act states that nothing may prevent a VoIP provider from collecting State imposed
fees in support of emergency 911 services, as long as the fee does not exceed the comparable fee
collected by telecommunications service providers68. To ensure transparency, the FCC must
report, by State, findings regarding the collection and distribution of State imposed 911 service
The Act amends the National Telecommunications and Information Administration
Organization Act,70 requiring creation of a “national plan for migrating to a national IP-enabled
emergency network capable of receiving and responding to all citizen activated emergency
communications and improving information sharing among all emergency response entities.”71
This ‘next generation’ plan shall:
(A) Outline the potential benefits of such a migration;
(B) Identify barriers that must be overcome and funding mechanisms to address
(C) Provide specific mechanisms for ensuring the IP-enabled emergency network
is available in every community and is coordinated on a local, regional, and
(D) Identify location technology for nomadic devices and for office buildings and
(E) Include a proposed timetable, an outline of costs and potential savings;
(F) Provide specific legislative language, if necessary, for achieving the plan;
(G) Provide recommendations on any legislative changes, including updating
definitions, to facilitate a national IP-enabled emergency network;
(H) Assess, collect, and analyze the experiences of the PSAPs and related public
safety authorities who are conducting trial deployments of IP-enabled emergency
networks as of the date of enactment of the IP-Enabled Voice Communications
and Public Safety Act of 2007;
(I) Document solutions that a national IP-enabled emergency network will
provide for 9-1-1 access to those with disabilities and needed steps to implement
such solutions, including a recommended timeline for such implementation; and
(J) Analyze technologies and efforts to provide automatic location capabilities and
provide recommendations on needed regulatory or legislative changes necessary
to implement automatic location solutions for 9-1-1 purposes.72
S. 428, supra note 57.
47 U.S.C. 942.
S. 428, supra note 57.
Id. Provisions (C) and (D) are not included in the House bill Modernization and Public Safety Act of 2007.
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To assist VoIP providers in achieving compliance, the Act allows the FCC to compile
and make available to the public, contact information related to 911 service providers.73
With an eye on future technologies, the Act allows the FCC to “require any provider of a
voice service that is a substitute for telephone exchange service . . . to provide 9-1-1 service,
including enhanced 9-1-1 service, to its subscribers.”74
The Senate and House bills have some significant differences. The Senate version tasks
the FCC with developing various best practices and procedures.75 The House version includes
updates to Section 22 of the Communications Act of 193476 that authorize VoIP suppliers to
provide customer information for emergency 911 services purposes, and preventing those with
access to emergency 911 services databases from using that information for competitive
Though the Senate’s IP-Enabled Voice Communications and Public Safety Act of 2007
must be resolved with the House’s 911 Modernization and Public Safety Act of 2007, then signed
into law, Congress’ efforts to date have made significant progress towards improving E911
services available to VoIP subscribers. Regardless, several critics offer additional
recommendations to improve emergency 911 services.78
Emergency 911 Services – Challenges Ahead
Looking to the future, the National Emergency Number Association offers six
S. 428, supra note 57.
47 U.S.C. 222.
H.R. 3403, supra note 61.
See generally, Dale N. Hatfield, A Report on Technical and Operational Issues Impacting The Provision of
Wireless Enhanced 911 Services, Prepared for the Federal Communications Commission, available at
www.locatemodelcities.org/library/HatfieldReport.pdf (last visited Mar. 14, 2008). Mr. Hatfield’s extensive study
and list of recommendations includes establishing a National 911 Program Office, increasing FCC oversight of the
rollout of E911 services, and developing industry-wide procedures for testing and certification of E911 services. Id.
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recommendations for improving emergency 911 services for VoIP subscribers:
(1) Establishing a national E9-1-1 VoIP policy;
(2) Encouraging vendor and technology neutral solutions and innovation;
(3) Retaining consumer service quality expectations;
(4) Support[ing a] dynamic, flexible, open architecture system design process for
(5) Developing policies for 9-1-1 compatible with the commercial environment
for IP communications; and
(6) Promoting a fully funded 9-1-1 system.79
Regarding concern about regulations that impose a specific technology or technological
standard, “the FCC should allow for innovation on the part of VoIP providers in coming up with
a unique solution that takes into account the significant technological differences between VoIP
and traditional telephony.”80 “With E911 compliance, for example, the FCC should not expect
VoIP providers to come up with the same solution as a traditional telephone company.
Emergency assistance to VoIP users could be different from traditional 911 services so long as it
is effective and reliable.”81
‘Can you find me now?’ could be the battle cry of VoIP subscribers who have endured
waiting for the arrival of emergency responders. As state and federal entities develop laws and
regulations that seek to improve end-to-end connectivity and reliability of emergency 911
services, numerous challenges are forcing regulators, providers, and customers to balance
economic objectives against public safety concerns. Legislation under consideration is expected
to resolve VoIP regulatory confusion, to identify vendor requirements, and to improve the
reliability of caller ‘location’ information provided to emergency responders.
Brannon, supra note 25, at 193.
Winberg, supra note 6, at 265, quoting Susan P. Crawford, The Ambulance, the Squad Car, & the Internet, 21
BERKELEY TECH. L.J. 873, 891 (2006).
Winberg, supra note 6, at 265.
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Although the challenges facing emergency 911 service providers will eventually be
resolved, the financial capital, and duration of time, required to improve the emergency 911
system are not the only factors to be considered. Carrying great emotional, ethical and moral
weight are the number of human tragedies that might be prevented by a reliable, resilient and
robust emergency 911 system.
UNIVERSITY OF DETROIT MERCY SCHOOL OF LAW
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