Coping With E911 Deadline: A Stunning Task, But Doable


The five-alarm notice from the FCC on July 26 that cable operators must collect E911 acknowledgements from all voice-over-Internet protocol customers by August 29, or shut them off the next day, had settled into a heightened business-as-usual mentality by last week.

Reason: A triangulation of approaches will very likely work in tandem to get the Federal Communications Commission what it wants.

Here’s the short version of the situation: The FCC, which views the promotion of public safety as its primary role, doesn’t want any more citizens to die because the technology they used to dial 911 didn’t deliver.

What rattled the cable providers of VoIP about the new FCC deadline is this: From the birth of cable-delivered VoIP, all operators chose to color within the lines of traditional, facilities-based telephone providers. (“Facilities-based” means they own the network that serves you, just like the phone company, and the power company — and follow the same rules.) That means cable VoIP providers routinely included E911 connectivity in the construction of the service.

Other VoIP providers — Vonage Holdings Corp. always seems to get singled out, but there are others — have a trickier time of doing 911, because their service is useful to the nomadic. Pick a phone number (perhaps with a different area code than the one that covers your house), plug the box into the DSL or cable modem at your house, talk. Go to Atlanta on a trip, take the box, plug it into a broadband link, talk. Pay $25 a month, either way.

But if you’re in Atlanta, and you dial 911, how are they to know you’re not at home?

Before we go much further, a quick primer on the difference between 911 and E911. When Customer Jane dials 911, her call goes to what’s called a “PSAP,” or a “Public Safety Access Point.” There, the operator knows Jane’s phone number, and can ask her where she is.

When Customer Jane dials 911 from a phone attached to a system that’s outfitted for the “E” in E911 — “Enhanced” — her address pops up on the PSAP operator’s screen. They can send help even if Jane can’t speak.

But instances remain in which a person receiving VoIP service from a cable provider might run into 911 trouble — like when the power goes out. It’s true that most, if not all, E-MTA (embedded multimedia terminal adaptor) gear comes with a battery slot — but so do lots of other things in your house that you don’t always think about.

To follow the FCC’s logic, when you’re in a calamity serious enough to warrant a 911 call, you’re probably not thinking about where the batteries are.

Thus, the FCC wants every VoIP customer to know what’s what about E911. They want people to know repeatedly, like with a sticker in plain view. And they want 100% certainty that everybody knows by Aug. 29.

Those who don’t know are to get their VoIP service shut off. On Aug. 30.

That last part is what got people excited. Time Warner Cable is approaching 700,000 VoIP customers. Cablevision Systems is hooking them up like crazy. Cox is turning them up, as is Comcast, and Charter.

All in, a million or more people need to acknowledge the message they get from their cable VoIP provider — within the next 21 days of what’s already a heavy vacation month. Yeesh.

The FCC’s specific request is for “affirmative acknowledgement” of all VoIP customers. It’s a boldly vague term. It gave room for minds to cool, and consider the options.

Turns out there are at least three, maybe more, ways to go after the “affirmative acknowledgement.” That’s why people involved in the VoIP notification craziness last week were anxious, but confident, that they’ll get to 100% before the end-of-the-month deadline.

The first option is a direct mail piece, with a tear-off bingo card to mail back. Direct marketing aficionados says that even if a “sign here” card is so compelling, people trip over themselves in their haste to find a pen, the best one can hope for is a 20% response. Four percent is terrific. Two percent is normal.

The second option stems from the simple fact that almost all cable VoIP customers are also broadband Internet customers. That opens the door for an e-mail campaign, with a “click here” link to the acknowledgement. Or, a splash screen that “pushes” broadband customers to the acknowledgement page.

Third is the use of an in-house or outsourced IVR (interactive voice response) function. Maybe you pick up the phone, and there’s a message to dial this number. Or maybe you pick up the phone and are literally diverted to an operator, who explains the situation, and collects your acknowledgement.

Even with three handy tools, getting to 100% in customer acknowledgements is still a tall task, rammed on top of all the other tall tasks systems staffers are working on.

But on the scale of grimaces, this one is more like a sharp kick in the shin than, say, having to cut off of the @Home Network in a week, or having to switch billing systems. It’s a huge bruise, but you can still walk.

The bad news is, you have to do it. The FCC is forming a task force for enforcement.

The good news is that everyone working on it seems more stunned by the craziness of the ask than by the hardship of the task.

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