******************************************************** 
                      NOTICE
********************************************************

This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.

*****************************************************************



                                                                    DA 11-304

                                                             February 4, 2011

                                             Enforcement Advisory No. 2011-05

   ENFORCEMENT BUREAU REMINDS INTERNET-BASED TELECOMMUNICATIONS RELAY SERVICE
                  PROVIDERS OF EMERGENCY CALLING REQUIREMENTS

   In 2008, the Federal Communications Commission issued rules governing 911
   emergency call handling requirements for providers of certain
   Internet-based forms of Telecommunications Relay Services (TRS). The
   purpose of these requirements is to ensure that individuals with hearing
   or speech disabilities who use Internet-based TRS receive 911 service that
   is comparable to that received by traditional telephone network TRS users.
   Because of the public safety risks that would result from an
   Internet-based TRS provider's failure to complete a 911 call properly,
   including passing location-identifying information to the applicable
   emergency services organization, the Enforcement Bureau issues this
   Enforcement Advisory to remind such providers, especially IP Relay and VRS
   providers of these requirements. In particular, we emphasize that the 911
   emergency call handling requirements apply regardless of the equipment or
   software used by consumers seeking emergency assistance via Internet-based
   TRS.

   The 911 emergency call handling rules for IP Relay and VRS providers
   include, among other things, the following requirements:

     * IP Relay and VRS providers must transmit all 911 calls -- as well as
       automatic number identification (ANI, generally the caller's 10-digit
       number), the caller's registered location, the name of the
       Internet-based TRS provider, and the communications assistant's (CA's)
       identification number for each call -- to the public safety answering
       point (PSAP), or other appropriate local emergency authority that
       serves the caller's registered location;

     * IP Relay and VRS providers must answer incoming emergency calls before
       any non-emergency call, i.e., prioritize the emergency calls and move
       them to the top of the queue;

     * IP Relay and VRS providers must route all 911 calls through the use of
       ANI, and, if necessary, pseudo-ANI, via the dedicated wireline E911
       network to the PSAP, or appropriate local emergency authority that
       serves the caller's registered location;

     * If the Internet-based TRS is capable of being used from more than one
       location, the IP Relay and VRS provider must offer the consumer one or
       more methods of updating his or her registered location at will and in
       a timely manner. At least one of those methods must allow the user to
       update his or her registered location from the equipment he or she
       uses to access the Internet-based TRS;

     * In the event that one or both legs of the emergency call (i.e., either
       between the TRS user and the CA or between the CA and the PSAP/other
       emergency authority) is disconnected, the IP Relay or VRS provider
       must immediately re-establish contact with the TRS user and/or the
       appropriate PSAP or other emergency authority.

   Internet-based TRS providers must comply with the emergency calling
   requirements regardless of the equipment or software used by consumers
   utilizing Internet-based TRS. This means that whether a consumer is
   placing a 911 emergency call via Internet-based TRS using customized
   equipment and software provided by an Internet-based TRS provider,
   off-the-shelf hardware and software that might be purchased or acquired
   from a source other than an Internet-based TRS provider, or some
   combination thereof, Internet-based TRS providers must fully comply with
   the Commission's emergency calling requirements. Noncompliant
   Internet-based TRS will be ineligible for compensation from the interstate
   TRS Fund. We note that violation of the Commission's rules and orders may
   also subject an Internet-based TRS provider to severe penalties, including
   substantial monetary forfeitures.

   For additional information regarding compliance and enforcement of the
   emergency calling requirements for Internet-based TRS providers please
   contact Janet Sievert of the Enforcement Bureau at 202-418-1362 or at
   janet.sievert@fcc.gov. To request general information on emergency calling
   requirements for Internet-based TRS providers, please contact Diane Mason
   of the Consumer & Governmental Affairs Bureau's Disability Rights Office
   at 202-418-7126 or at diane.mason@fcc.gov. Media inquiries should be
   directed to David Fiske at 202-418-0513 or david.fiske@fcc.gov.

   To request materials in accessible formats for people with disabilities
   (Braille, large print, electronic files, audio format), send an email to
   fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at
   202-418-0530 (voice), 202-418-0432 (TTY). You may also contact the
   Enforcement Bureau on its TTY line at 202-418-1148 for further information
   about this Enforcement Advisory, or the FCC on its TTY line at
   1-888-Tell-FCC (1-888-835-5322) for further information about the
   emergency calling requirements for Internet-based TRS providers.

                                         Issued by: Chief, Enforcement Bureau

                                     -FCC-

   Telecommunications Relay Services and Speech-to-Speech Services for
   Individuals with Hearing and Speech Disabilities, E911 Requirements for
   IP-Enabled Service Providers, Report and Order and Further Notice of
   Proposed Rulemaking, , 23 FCC Rcd 11591 (2008); Telecommunications Relay
   Services and Speech-to-Speech Services for Individuals with Hearing and
   Speech Disabilities, E911 Requirements for IP-Enabled Service Providers,
   Report and Order and Further Notice of Proposed Rulemaking, 23 FCC Rcd
   5255 (2008). TRS permits persons with hearing or speech disabilities to
   access the telephone system to call other telephone users. For example, a
   TRS user contacts a relay provider through a device (e.g., a text
   telephone or videophone), and is connected to a communications assistant
   (CA) who, in turn, places a telephone call to the person the TRS user
   wishes to call. The CA then communicates to the called party what the
   relay user has communicated to the CA, and relays back to the TRS user
   what the called party says. With Internet-based TRS, calls between the
   relay provider and the person with a hearing or speech disability are made
   via the Internet. The two most commonly used forms of TRS are Internet
   Protocol Relay (IP Relay) and Video Relay Service (VRS).

   This Enforcement Advisory highlights key emergency calling requirements.
   See section 64.605 of the Commission's rules, 47 C.F.R. S: 64.605, for a
   comprehensive list of all emergency calling requirements applicable to
   Internet-based TRS providers. Certain of the requirements only apply to IP
   Relay (text-to-voice) and VRS providers.

   "All 911 calls" is defined as "any communications initiated by [a] VRS or
   IP Relay user dialing 911." See 47 C.F.R. S: 64.605(b)(2)(ii).

   Internet-based TRS providers must obtain from their users the physical
   location at which the service will first be used when the user registers
   for a 10-digit number, and must provide an easy way for users to update
   their information if it changes. 47 C.F.R. S: 64.605(a)(4).

   See 47 U.S.C. S: 503.

                                  Page 3 of 3

   PUBLIC NOTICE

                                   Page 1of 3

   PUBLIC NOTICE

                            FCC ENFORCEMENT ADVISORY

   Federal Communications Commission

   445 12th St., S.W.

   Washington, D.C. 20554

                                        News Media Information 202 / 418-0500

                                                 Internet: http://www.fcc.gov

                                                          TTY: 1-888-835-5322

                                        News Media Information 202 / 418-0500

                                                 Internet: http://www.fcc.gov

                                                          TTY: 1-888-835-5322

   Federal Communications Commission

   445 12th St., S.W.

   Washington, D.C. 20554