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Re: More on Vonage service disruptions...

  • From: Thor Lancelot Simon
  • Date: Thu Mar 03 17:03:46 2005

On Wed, Mar 02, 2005 at 09:46:05AM -0600, Church, Chuck wrote:
> Another thing for an ISP considering blocking VoIP is the fact that
> you're cutting off people's access to 911.  That alone has got to have
> some tough legal ramifications.  I can tell you that if my ISP started
> blocking my Vonage, my next cell phone call would be my attorney... 

Why?  Do you have a binding legal agreement with your ISP that requires
them to pass all traffic?  Do you really think you can make a
persuasive case that you have an implicit agreement to that effect?

(Note that I am not expressing an opinion about whether you _should_
 or _might like to_ have such an agreement, just my skepticism that
 you actually _do_ have such an agreement, and can enforce it)

The 911 issue is a tremendous red herring.  In fact, it's more of a
red halibut, or perhaps a red whale.  Vonage fought tooth-and-nail
to *not* be considered a local exchange carrier precisely *so that*
they could avoid the quality of service requirements associated with
911 service.  One of their major arguments in that dispute was that
they provided a service accessible by dialing 911 that was "like"
real 911 service but that was "not actually 911 service".

As I and others noted at the time, that very much violates the
principle of least surprise, and is quite possibly more dangerous
than not providing any 911 service at all: in New York City, for
example, the number to which Vonage sends 911 calls is not equipped
to dispatch emergency services and often advises callers to "hang
up and dial 911": this _decreases_ public safety by causing people
to waste time instead of dealing with emergencies in some constructive

But Vonage persisted nonethess in insisting that they should not be
held to real 911 service standards, and they prevailed, basically by
convincing a compliant federal regulatory body with little or no
understanding of the underlying technical and human-factors issues
to force the state regulators to see it Vonage's way.  To turn around
now and use 911 reliability (of their service that is "like 911 but
not 911" and thus should not _have_ any reliability standards enforced
upon it) as a reason why other carriers should be enjoined from
filtering Vonage's packets is not just wrong, it's absurd.

Of course, like much of Vonage's other rhetoric, it will probably
be effective.  Ultimately, Vonage will succeed in the marketplace
and, in the process of controlling its own costs, manage to wipe
away almost all of the traditional regime of regulation of service
quality, telco accountability, etc. even in realms like contact to
emergency service in which the public good is generally considered
to in fact be well served by those regulations.

We will have cheaper voice telephone service when all is said and
done but will we, eventually, be forced to turn around, after
Vonage uses cheaper costs from differential regulation to wipe out
all the old wireline carriers, to painfully reinstate a large part
of the old regulatory regime to ensure that telecom services that
we believe essential to the public good are not (or do not remain)
wiped out as well?


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