The FCC's latest action to mandate VoIP providers provide E911 is not surprising. The political obviousness of being "for" E911 is apparent even to VoIP providers, because they cannot afford too many headlines like this, notwithstanding they fully-disclose the service's E911 limitations.
Is the mandate an entry barrier that disadvantages "portable" VoIP services like Vonage and Lingo? Certainly.
More than that, the current E911 situation is a tale of unfortunate political economy, antiquated network architecture, balkanized systems and costly backwards compatibility. What's more, it is no one's fault; rather, it is the product of a series of unfortunate choices about how we regulate, architect and disburse funds for 911 service.
Dale Hatfield probably knows more than anyone about the nation's E911 system. So much, he wrote a report on it. I asked Dale what he thought of the current situation,
and he graciously offered these comments (which I reprint by permission):
[T]he situation is such a mess that it is hard to know where to start. I sould say right away though that I have not kept up with all of the recent developments and my report (which predicted many of the problems that are just being publicized - e.g., the averaging problem) is now several years old. Of the many problems, the antiquated 911 system operated by the ILECs is a major problem although, in their defense, they can't upgrade their network without impacting on the PSAPs who would have to upgrade as well - and they often lack the technical expertise and funding as noted in my report.
I recommended that the Commission set up an advisory group to work on solving the next generation problem - developing the architecture and some efforts have been made in that direction. But there are so many groups/jurisdictions (and associated jealousies) etc. involved it is a very tough to get momentum. With so many people involved and with a badly fragmented telecom industry brought about by competition (a good thing certainly) I don't have any great ideas on incentives beyond government grant programs. Because of the difficulty and time that it will take to develop and deploy an alternative in this fragmented environment, my guess is that backward capability will be necessary - otherwise the politicians will be in an untenable position as more people die because they can't reach help as expected.
I am sorry to be so pessimistic but having studied the situation in depth, I am pretty certain there are no fast and easy solutions.
In other words, there are enormous collective action problems to overcome before the nation has an up-to-date, technologically dynamic E-911 system. This mandate then becomes a short-term (yet potentially costly) fix, but cannot distract from the much more painstaking, difficult task of consituency management to actually bring the system forward from the 1970's architecture we now use.