Why Skype Can’t Offer Skype-In To Canadians
30. Apr, 2009 
4 Comments
Many Canadians are asking why they can’t get a Skype-In number in Canada. Well, it has to do with this CRTC decision.
Some snippets:
The Commission requires VoIP service providers providing either nomadic VoIP service or foreign exchange VoIP service to implement, within 90 days of the date of this decision, an interim solution which provides a level of service comparable to Basic 9-1-1 service…
Users of nomadic VoIP service can make calls from any location where users can get access to Internet service. Foreign exchange VoIP service allows users in one exchange to receive telephone calls dialled as local calls in another exchange that they have selected (e.g. a customer located in Ottawa with a Halifax local telephone number)…
Basic 9-1-1 service connects the caller to a central call centre which then connects the call to the correct emergency response centre, at which point the caller must identify his or her location in order for an emergency response service to be dispatched.
So this states that Skype, as a provider of nomadic VOIP must at least be able to take a 911 call, know where the person is calling from sufficiently accurately that they can direct the call to the proper 911 call center.
Now, what’s interesting is the bit about a “foreign exchange VOIP provider” which allows someone in city A to have a local number in city B. Due to the wonders of the internet, it is currently possible for Canadians to have this type of service through Skype – just get a US number. For all intents and purposes, Skype IS operating in Canada this way. Canadians can get a Skype-In number, be in Canada, make calls from Canada to Canada, and attempt and fail to call 911 in Canada. It seems odd that the CRTC still will not allow Skype to offer Skype-In, a service which doesn’t allow anyone to call 911, merely to have a phone number, but there are no prohibitions on Skype-Out as it is viewed as an internet service and is beyond the CRTC’s purview. Yet Skype-Out is the part of Skype that makes the calls…
Skype of course has their opinion:
For those who don’t want to read the entire thing, Skype basically says that any company marketing a service to be a full phone replacement and meets certain conditions of such a service should be obliged to offer 911/e911 services as the CRTC wants. However, they would like the option to not be held up to that standard so long as they don’t market themselves as a full phone service replacement meeting those standards.
LAW OFFICES
GOLDBERG, GODLES, WIENER & WRIGHT
1229 NINETEENTH STREET, N.W. WASHINGTON, D.C. 20036
HENRY GOLDBERG
JOSEPH A. GODLES
JONATHAN L. WIENER
BRITA D. STRANDBERG
LAURA A. STEFANI
HENRIETTA WRIGHT
THOMAS G. GHERARDI, P.C.
COUNSEL
(202) 429-4900
TELECOPIER: (202) 429-4912
general@g2w2.com
May 10, 2004
Electronic Submission
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554
Re: WC Docket 04-36 Ex Parte
Dear Ms. Dortch:
On May 9, 2005, Skype Communications, S.A. (“Skype”), represented by
Director of Operations Michael Jackson, undersigned counsel, and Brita
D. Strandberg of this firm, met with Chairman Martin’s Chief of Staff
Daniel Gonzalez and Michelle Carey, Legal Advisor to Chairman Martin,
and separately with Commissioner Copps and Jessica Rosenworcel, Legal
Advisor to Commissioner Copps, to discuss the application of 911/e911
requirements to IP-enabled services.
Specifically, Skype explained its position that those providing IP-
based replacements for fixed-line wireline telephone service should
provide equivalent access to 911/e911 emergency response services
as available to consumers using the telephone services for which
they are seeking a replacement. In this way, consumers, who expect
to have access to emergency response when they replace their fixed-
line telephone service, will not be exposed to potentially dangerous
situations if their reasonable expectations are not met.
Skype emphasized that the Commission should define IP-based
replacements for fixed-line wireline telephone service as services
that:
Assign users NANPA/E.164 phone numbers;
Offer as a package real-time, two-way service that is able to receive
voice communications from the PSTN and terminate voice
communications on the PSTN;
Provide, or enable use of, traditional CPE or CPE that, like
traditional CPE, is always on and has dial tone.
Use of this definition will ensure that consumers buying phone service
that is marketed as, and intended to be used as, a replacement for
fixed-line wireline telephone service will be able to reach emergency
services.
Naturally, Skype itself will abide by this proposal and will offer
access to emergency response whenever it offers services meeting
these criteria. Indeed, Skype is planning to integrate its IP
offerings with its own WiFi handsets and will support the provision
of reliable user location information to emergency services when
consumers buy those handsets.
In the interim, Skype is concerned that overbroad application of
911/e911 requirements will impede rather than facilitate the provision
of emergency services. Skype does not have access to reliable real-
time location information for its users – Skype may determine a user’s
IP address, but IP addresses (in addition to being vulnerable to
spoofing) offer only the most general sense of a user’s location. Of
course, Skype could request location information from users, but any
self-reported information is likely to be unreliable. Skype users
typically use Skype from laptops or from several computers, logging
into their Skype accounts from home, work, hotel rooms, airports,
Internet cafes, and anywhere else they have access to a computer
and a broadband connection. Consequently, any user-reported
location information, even if initially correct, will accurately
describe a user’s location only some of the time, and could be
off by entire continents.
Because it does not have and cannot obtain reliable location
information from its users, Skype currently is unable to deliver
emergency calls to the proper PSAP. It is likewise unable to transmit
location and callback information. A Skype call to emergency services
would run a serious risk of being routed to the wrong PSAP and would
contain unreliable information once connected. Adding capability for
such calls to Skype would reduce user security by creating a false
impression that Skype can and should be used to reach emergency
services and would burden PSAPs with improperly routed calls and
unreliable information. Skype has addressed this limitation by warning
users that Skype should not be used as a telephone replacement service
and cannot be used for emergency dialing
For the reasons discussed above, Skype urges the Commission to limit
the immediate application of 911 and e911 requirements to IP-based
replacements for fixed-line wireline telephone service as defined
herein.
Respectfully submitted,
Henry Goldberg
Attorney for Skype Communications, S.A.
cc: Commissioner Copps
Michelle Carey
Daniel Gonzalez
Jessica Rosenworcel
