At first glance, the FCC's May 19 public hearing on E911 and voice-over-IP appeared to deal a black eye to the country's nascent VoIP industry. VoIP subscribers from Florida, Texas and Connecticut stepped forward to testify, in heart-wrenching detail, about how VoIP had failed them during police and medical emergencies during the past several months. All had chosen VoIP as their primary residential phone service, but none were able to reach an emergency operator when they called 911. FCC Chairman Kevin Martin decried the situation as “simply unacceptable;” he and the other commissioners then ordered all VoIP providers to deliver E911 service to their customers within 120 days.

But what looked like a public relations debacle for VoIP providers actually is an important opportunity. Technologically, VoIP has reached a critical stage — the point at which it can deliver public network-grade quality in addition to new features and dramatic cost savings. But widespread demand for VoIP as a primary service will only occur when consumers trust that it can replicate the emergency-calling capabilities of the traditional telephone. The FCC's ruling will eliminate VoIP offerings that don't offer 911 at all or that rely on 10-digit routing and other shortcuts in place of true E911 functionality. Those services threaten to undermine the public's confidence in VoIP over the long term. For that reason, the FCC's order is not only sound social policy, it's also positive for the industry.

The good news is VoIP networks, when properly designed, can provide E911 via “direct trunking,” a solution that allows 911 calls to be automatically routed to public-safety answering points, or PSAPs, in any market where the service is offered. The call is presented to the PSAP with the subscriber's callback number and address.

Direct trunking takes time, money and effort to implement. It requires switching infrastructure, a significant investment in circuits, a facilities-based network, interconnection agreements with ILECs and agreements with individual PSAPs. My company, Level 3, has deployed an E911 infrastructure across most of the U.S. The process has taken close to two years and will ultimately cost tens of millions of dollars. Today, however, it enables us to deliver full E911 service to cable companies, ISPs and other wholesale customers selling VoIP to end users. (In the future, it's worth noting, VoIP promises to do far more than simply match the E911 functionality of the public network. The ability of IP to converge voice and data — and deliver them together over the same network connection — means that VoIP will surpass the legacy phone network as a critical tool for first responders, transmitting medical records, real-time video images and other vital information to emergency personnel along with a caller's voice signal).

Recognizing that providing E911 via VoIP is feasible, most VoIP service providers applauded the FCC's May 19 announcement. That said, there are some legitimate concerns about the potential breadth of the commission's detailed order and its impact on the industry.

One issue, for example, will be the commission's directives regarding VoIP subscribers who temporarily move their VoIP phones away from their primary address. Such “nomadic” functionality — one of a range of new services not possible with traditional telephones — presents technical and operational challenges that may not be overcome within the FCC's 120-day timeline.

Today's landline E911 system is designed to support phones that stay in one place; therefore, emergency calls are consistently routed to a single PSAP. Requiring VoIP providers and database managers to enable frequent manipulation of location data and routing might corrupt data integrity and appropriate 911 routing. It would be unfortunate, to say the least, if efforts to accommodate nomadic users actually reduced the reliability of E911 coverage overall.

Requiring VoIP providers to secure 100%, nationwide E911 coverage also seems unrealistic, especially since fixed wireline and wireless services took decades to get even close to that level. Level 3 has made a significant investment of time and capital to achieve E911 coverage for 66% of all U.S. households, so it does not seem reasonable to require VoIP providers to achieve total coverage within four months in order to support nomadic users who temporarily move their VoIP devices to remote locations.

Despite those issues, however, the core objective of the FCC's order is laudable, necessary and achievable — and it underscores the maturation of VoIP and its growing acceptance as a mainstream service. VoIP remains one of the most important and promising technologies in the industry today. The commission's order will help ensure that it lives up to its full promise and potential.

James Crowe is CEO for Level 3 Communications, a wholesale telecom service provider based in Broomfield, Colo.