VoIP companies say the US Federal Communications Commission’s deadline came sooner than was widely expected and is unrealistic. Also, the FCC’s expectations on VoIP companies have been called confusing at best.

People in the industry are still trying to figure out a lot of the grey middle areas of the ruling, said Paul White, CFO of Deltathree, a New York IP company makes most of its money selling VoIP services to VoIP providers. We’re all still scrambling to figure this out.

E911 provides emergency services staff with a caller’s physical location and callback number, similar to the way landline and mobile calls are handled. Typically, this information for VoIP callers was not sent to 911 services and these calls also may not be routed to appropriate emergency personnel.

The FCC ruled on June 3 that the mandate applies to all interconnected VoIP providers, meaning those that allow users to send and receive calls from the PSTN. (PC-to-PC voice providers are not affected.)

But this week the ruling was formalized by being published in the US public record, the Federal Register. The move gives VoIP providers until November 28 to comply.

It is going to be very difficult and not likely fully possible within the allowable timeframe, said Myrle McNeal, senior VP of consumer voice services at Level 3, which provides wholesale E911 services.

VoIP providers also now have fewer than 30 days to inform customers how VoIP 911 services differ from traditional landline calls. They also must provide warning stickers for customers to affix on phone equipment that states the limitations of existing E911 services.

White said it was not clear just how those stickers and that information should read and what language the FCC requires for VoIP companies to comply.

They also must obtain and keep a record of affirmative acknowledgement by every subscriber, both new and existing, of having received and understood the advisory, read the Federal Register document. Again, this seems tricky to quantify.

Just how many VoIP companies will meet the new deadline is a messy problem.

Many VoIP providers that are not also cable companies, which is most of them, gain wholesale access to E911 services through IP networks, such as Level 3 Communications Inc.

However, Level 3, which coordinates various moving parts of E911 that are owned by other companies, currently has E911 coverage for just 66% of all US households.

The company has a goal to expand its coverage to 70% of US households by the end of the year — not necessarily by November 28

Level 3 has spent 20 months and much cash to get the E911 coverage it has. To get 100% coverage in the US is prohibitively expensive, said VP McNeal.

Clearly, VoIP providers won’t be able to offer E911 to customers everywhere and, come Nov. 28, may have to limit who they sell to.

There’s also the problem of nomadic E911 services for cell phones, which the FCC mandate also covers.

Will Level 3 nomadic service cover all the PSAPs? Their current service doesn’t cover all the PSAPs … so are VoIP providers just supposed to be left to cover it themselves? asks White. These are just some of the open questions we have.

Level 3 said it plans to roll out limited nomadic E911 in time to meet the FCC deadline. But whether that would be effective in enabling true E911 capability – to the extent the FCC is demanding – is unclear.

The Broomfield, Colorado company, one of the largest of its type in the country, connects VoIP companies with the various moving parts of E911, which include Public Service Answer Points, 911 database compilers and other companies.

While Level 3 plans to make those connections available to VoIP providers, exactly how a 911 database company would know the location of a VoIP cell phone user is not yet known. After all, Level 3’s network doesn’t know when a call is nomadic or not.

This is a fairly difficult requirement and we’re not sure how all this is going to get solved, said Level 3’s McNeal.

He also pointed out the FCC had demanded similar 911 services from cell phone providers about a decade ago, but did not strictly enforce it. Today, some US cell phones still do not have traditional 911 capabilities.

The posture of the FCC would indicate that they are not going to treat the VoIP providers the same way [as cell phone providers], McNeal said.

VoIP market leader Vonage Holdings Corp has not escaped the problems.

Unlike some other large US VoIP sellers, Vonage does not already have E911, except for its Rhode Island, New York market. The company plans to rollout E911 in New York City early next month, said Stephen Seitz, Vonage VP of 911 regulatory affairs.

Vonage’s goal is to enable all Vonage customers with E911 to meet the FCC’s deadline. There a lot of things that can happen on the way, Seitz said.

He said the company is working with the E911 community, with a number of E911 services vendors as well as cable companies who have access to E911 routing services.

This requires a tremendous amount of cooperation and collaboration among a number of different players, he said.

Seitz declined specific progress on Vonage’s E911 progress but said, We’re going to do everything in our power to meet the obligations.

Problem is, the power of any single VoIP provider to enable E911 to all customers is limited.