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You are right, this solution is not 911 compliant. Neither is service from Nufone, Teliax, Voipjet, Stanaphone or hundreds of other VOIP carriers out there. The question of the degree of 911 compliance is very much up in the air right now because the FCC's requirement is basically unenforceable. Skype is not compliant, and yet there are millions of people on their service. As far as I'm concerned, all of the hoopla around 911 compliance is BS that is out there to scare people out of the voip business and tie up the resources of the people who are in it. The model I put together never touches the PSTN, it is purely data - no different than Skype or MSN messenger with voice enabled or Xbox live with players talking to each other. The distinction of what consitutes "911 capable phone service over IP" has not been made yet and will not be made for some time.

You can argue the FCC's 911 requirement all your want, but nevertheless it is there and they can fine you. If you believe the risk is justifiable based on your revenue projections then by all means go ahead with it.

The requirement is there but has yet to be proven by law, or enforced. I intend to keep my voip ventures separate from my regular ISP business. If the 911 requirement for voip is proven by law, then I can either work to make it compliant according to the established legal history, sell the customers to another voip provider or shut it down.

FWIW, there is a requirement for cell companies for several years to provide location information to e911 centers. Guess what, a majority of the cellular carriers can't or don't provide that location information. They have gotten exemptions over and over. That didn't stop them from selling service and building out markets. This is the same sort of situation. The public wants VOIP, and they are going to get it. The 911 details will get worked out over time and a few court cases.

Tying up valuable financial resources into an early stage market like this and expecting to make a large committment without guaranteed revenue possibilities is insanity. Committments also reduce flexibility, and that is a key to the success of the small ISP/WISP operator. If someone comes out with .5 cents a minute or lower termination for low volumes, I will be able to switch my outbound service to that provider with a couple of configuration changes. You are going to be stuck with your committment, and if they can't deliver the same thing you will be out of luck. It's like signing a four year contract for Internet backbone at todays rates. The people who did that in 2003 are now paying twice as much for bandwidth as people who didn't sign long term contracts and maintained their flexibility.

You don't need to sign a four year or large minute commitment to get $0.005 per minute termination. Our wholesale customers average $0.002 to $0.009 per minute depending on call patterns and markets served with no commitment.


I chose a poor way to express my point. Here is a better way. A year ago I spoke with another prospective voip solutions provider (similar to CommPartners) and it was going to require a $3000/month committment in services sold to start doing my own voip service. I am glad that I did not pursue that avenue, as it would have been money wasted. That is the kind of committment/lack of flexibility that I do not want to get into. I apologize if it seems that I am being contradictory, I just think that it makes sense to have some good healthy debate about things. We all see things from a different perspective, and I do appreciate what you have brought to the discussion.

Business wise, if you can do $0.005 per minute termination in the lower 48 with minimal committments and can terminate IAX, then I am interested in more about what you have to offer. The difference between 1.5 cents and .5 cents a minute is pretty huge for the margins, and makes the breakeven projections work a lot better.
Matt Larsen
WISPA Wireless List:



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