MONTEREY COUNTY
Emergency Communications Department
9-1-1 FIRE, POLICE, MEDICAL
240 Church Street, Room 6N, Salinas, CA 93901
Phone: (831) 755-5110 FAX: (831) 755-5101
January 27, 2004
Senator Debra Bowen, Chair
Energy, Utilities and Communications Committee
State Capitol Room 4040
Sacramento, CA 95814
Senator Joseph Dunn, Member
Energy, Utilities and Communications Committee
State Capitol Room 2080
Sacramento, CA 95814
Dear Senators,
It has just come to my attention that the Energy, Utilities and Communications Committee will hold an Informational Hearing this afternoon on the Subject: Voice Over Internet Protocol – Is It Where Telephone Service Is Headed?
I don’t have the answer to the question asked, but as a 9-1-1 professional I do have a concern about the proliferation of this service without a requirement – or even a plan – to provide E911 service to the millions of people who now have this service. I ask that, in your discussions and deliberations on this issue you keep in mind the safety of the residents of and visitors to California and take steps to ensure that we do not repeat the mistakes of the last ‘big thing’ in telephony – wireless.
If history can teach us anything, we need only look back about fifteen years to the dawn of the cellular/PCS revolution to see what happened to 9-1-1 when wireless became the must-have technology. In 1994, the FCC tried to get a handle on the problem with their ruling on Docket 94-102, which required wireless carriers to provide, first the "Phase I" call-back number and cell site location, then true ANI/ALI on all wireless 9-1-1 calls. It has been ten years since that ruling, yet the vast majority of our population, in California and nationwide, do not have even the most basic Phase I service. The effort to correct this, the cost, and the lives lost because 9-1-1 was not addressed "up front" as wireless telephone service rolled out is incalculable. Please help ensure that a repetition of this mistake is not permitted with this new technology.
California is generally way ahead of the nation in 9-1-1 service, systems, equipment and infrastructure, with a proactive and adequately funded statewide program. Even so, the ‘wireless catch-up’ has cost us far more than it would have if 9-1-1 information delivery had been required when the service was new. The fact is that the nature of the new voice over internet technology will make it much simpler than wireless was to require this information; it’s already delivering both voice and data together.
There are other considerations too that your Committee should investigate in the context of your question. California Public Utilities Commission Director of Telecommunications Division, Jack Leutza, gave a presentation on VOIP at the November 13, 2003 Commission Meeting (a copy of which is on the PUC website under Items of Interest). In his presentation, Mr. Leutza makes the point that IP Telephony does not do the following:
- Provide E911 service
- Pay access charges
- Contribute to any of the special funds (such as Universal Lifeline Fund, Deaf & Disabled Telecommunications Fund, California Teleconnect Fund for schools, etc.)
- Provide access to traffic for law enforcement
- Obtain telephone numbers under the North American Numbering Plan
These are all issues that should be – must be – addressed before VOIP technology is permitted to become ubiquitous in California. For many of the people we serve, their lives truly depend on it.
I believe I can safely say that I speak for all Public Safety Answering Points and 9-1-1 professionals in raising this concern and imploring that you do not permit any technology or any device from any source to "call 9-1-1" without ANI/ALI information. I am not an expert, or even terribly well-informed on this issue, but would be happy to answer any questions I can. My direct line is 831-796-3580 and my e-mail address is dieboldl@co.monterey.ca.us.
Sincerely,
Lynn Diebold
Director
