VoIP Threatens Communications Access
Editor: Several months ago we ran a couple of articles about Voice
over IP (VoIP), which is the practice of using computer networks to
transmit telephone conversations. On the face of it, it's a great idea,
because it promises less expensive and more reliable phone service. But
as we mentioned in our previous discussions, there are a couple of dark
sides to this proposal. The following article points out that a pending
Senate bill classifies VoIP as an information service rather than a
telecommunications service. This seemingly innocuous distinction means
that many of the current telecommunications rulings (e.g. hearing aid
compatibility, requirements to support relay services, etc.) would NOT
apply to VoIP.
Note that the information below was originally distributed by the
Voice Over Internet Consumer Equity (VOICE) coalition as a call to
contact the appropriate senators and urge them NOT to approve the bill
as written. The consideration date has passed, so it's too late to do
that. But I've chosen to publish this article anyway, because it's
important that everyone associated with hearing loss understand and be
able to discuss this issue. VoIP is the wave of the future; it WILL BE
our telecommunications backbone. We need to get it right the first time.
That's SO MUCH easier than trying to fix it after the fact.
~~~~
APT has confirmed that the VoIP Regulatory Freedom Act of 2004,
introduced by Senator John Sununu, is set for markup by the Senate
Commerce Committee on July 20th. If passed as is, this bill would deal a
serious blow to consumer protection and accessibility in the IP-enabled
era.
[snip]
At the bottom of this email is the text of the letter that APT sent
to the Committee today for your reference.
What does the Sununu bill say?
The bill categorizes VOIP as an "information" service,
severely restricting any type of regulation from being imposed. If it is
passed, the following consumer protections would be at risk:
1. Universal Service. VoIP providers would not be required to
contribute directly to the universal service fund. This fund provides
access to telephone service to residents in rural high-cost areas and
low income consumers, and it is the funding mechanism for the E-rate.
2. Public Safety, Reliability, and Security. The provision of 911 and
enhanced 911 services, reliability and security would not be required.
They are all voluntary provisions.
3. Accessibility. Standards of accessibility by customers with
disabilities would be voluntary for providers of VoIP services, leaving
it to the industry to develop their own guidelines. Important provisions
such as Telecommunications Relay Services would be optional.
To read the whole bill, go to http://thomas.loc.gov/cgi-bin/query/C?c108:./temp/~c108KS5dyo.
Thank you for your support.
Debbie Goldman President
========================================
July 16, 2004
Dear Senator:
In advance of the Senate Commerce Committee markup of the proposed
VoIP Regulatory Freedom Act of 2004 (S. 2281), the Alliance for Public
Technology (APT) and the undersigned members of the Voice Over Internet
Consumer Equity (VOICE) Coalition would like to express their concerns.
We believe that this particular bill overlooks the most critical aspect
of the ongoing debate over VoIP: the consumer.
The VOICE Coalition agrees that emerging technologies such as VoIP
offer exciting new possibilities and can dramatically alter the way in
which Americans communicate with one another. But the full potential of
these technologies will only be realized if we adopt public policies to
ensure that providers fulfill the social obligations that have been the
hallmark of the traditional public switched telephone network. These
obligations include:
* Universal Service. VoIP is functionally equivalent to traditional
telephone service and is reliant on the public switched network that has
been the backbone of this country's communications system. As such, VoIP
providers should be required to contribute directly to the universal
service fund to ensure access to telephone service to rural, high-cost
and low-income consumers, and schools and libraries.
* Accessibility. Consumers with disabilities expect, and Section 255
of the Telecommunications Act of 1996 mandates, that all
telecommunications services be accessible and usable. VoIP providers
should be required to meet the same standards as traditional voice
telephony providers, and to contribute to important provisions such as
Telecommunications Relay Service (TRS).
* Public Safety, Reliability and Security. The provision of 911 and
enhanced 911 services, as well as basic consumer protections, should be
required of all communications providers, regardless of the technology.
The VoIP Regulatory Freedom Act of 2004 would require none of these
important public interest provisions. The Act would also, by way of
implementing two different regulatory scenarios for essentially the same
telecommunications service, create an environment that is inhospitable
to investment in and maintenance of the public switched network upon
which all telephone service relies.
The role of government in this case ultimately should be to create a
regulatory framework that promotes the growth of VoIP while protecting
the interests of all consumers. We respectfully submit that the bill
currently before the Committee falls well short of this goal. We urge
you to seriously consider the ramifications of your decision, and to
refrain from passing any legislation that does not specifically require
the public interest obligations outlined by the VOICE Coalition.
[snip]
Sincerely,
The Alliance for Public Technology
Alliance for Technology Access
American Association of Law Libraries
American Association of People with Disabilities
American Federation of Teachers
Communications Workers of America
Community Action Partnership
Department of Professional Employees, AFL-CIO
Independent Living Network
MAAC Project
National Association of the Deaf
National Consumers League
National Council of La Raza
Telecommunications for the Deaf, Inc.
Telecommunications Research and Action Center