FCC Issues Consumer Advisory - Emergency Calling & Ten-Digit Numbering

While I'm sure that everyone will have an abudance of training in the individual VRS offices about this topic, it's also important to hear it straight from the horses mouth (so to speak). Below is the text of the consumer advisory.

I'm curious - what questions have you been asked by consumers about these two topics? What have you told them? What have they told you?

*I'm not talking about the company elevator speech or confidential internal information - I'm thinking more from what signs did you use, what signs did they use?? Which language use seemed to get the point across in a clear way??


Overview
Beginning on December 31, 2008, persons with hearing and/or speech disabilities who
use Video Relay Service (VRS) or Internet Protocol Relay (IP Relay) – two forms of
Internet-based Telecommunications Relay Service (TRS) – will be able to obtain tendigit
telephone numbers from their VRS or IP Relay provider. These are the ten-digit
telephone numbers used by voice telephone users. New Federal Communications
Commission (FCC) rules require that VRS and IP Relay users be able to make and
receive calls using their new ten-digit numbers, and be able to make 911 calls and have
those calls – AND the caller’s ten-digit number and location information – routed to the
appropriate public safety answering point, the same enhanced 911 (E911) call center
used by voice telephone users.

This advisory contains important information for VRS and IP Relay users on how to
obtain a ten-digit number, what the new FCC rules require providers to do, and how the
new 911 call handling requirements will result in more functionally-equivalent 911 access
for VRS and IP Relay users.

Ten-Digit Geographic Numbers
Ten-digit geographic telephone numbering has been the standard used for voice
telephone service in North America for decades. Ten-digit numbers consist of a three-digit area code that corresponds to the consumer’s geographic address, followed by a
three-digit number associated with the consumer’s local telephone exchange, then a
four-digit number unique to the end user. With a ten-digit geographic number, VRS and
IP Relay users can be reached through a single number that will automatically connect
to the user’s primary (“default”) VRS or IP Relay provider (see “Registering with a
Default Provider” below) and allow the provider to determine the user’s IP address for
purposes of delivering incoming calls made to that number. In other words, voice
telephone users calling a VRS or IP Relay user through a relay provider will no longer
have to dial the telephone number of a provider and then give the provider the current IP address of the VRS or IP Relay user so that the communications assistant (CA) can
connect the call. Instead, they will simply dial the VRS or IP Relay user’s assigned tendigit geographic telephone number.

How to Obtain a Ten-Digit Geographic Number
Beginning December 31, 2008, VRS and IP Relay users may obtain a ten-digit
geographic number by contacting and registering with the VRS or IP Relay provider of
their choice. This provider becomes the consumer’s “default” provider (see “Registering
with a Default Provider” below), although a consumer can still use other providers to
make and receive calls using the telephone number for that provider. (See “Placing or
Receiving Calls Through An Alternate Provider” below.) Although consumers must
choose one default provider, they are free to switch default providers, just as voice
telephone users can switch telephone providers. (See “Changing Default Providers”
below.)
Who May Obtain a Ten-Digit Geographic Number
Any individual with a hearing and/or speech disability who wishes to use VRS or IP
Relay may obtain a ten-digit geographic number. During the registration process, users
will be asked to certify that they have a medically-recognized hearing or speech disability that necessitates their use of VRS or IP Relay.

Registering with a Default Provider
Once a VRS or IP Relay user selects and registers with a provider, this provider
becomes the user’s “default provider.” When a user registers, the provider must obtain
the user’s physical address, or “Registered Location,” at which the VRS or IP Relay
service will first be used. Providers also must give users an easy way to update their
location information if it changes, without cost or additional equipment. Registration
enables VRS and IP Relay providers to match their users’ telephone numbers with the
users’ IP addresses to properly route and complete calls, and obtain their users’ physical
locations in order to provide E911 service. Thus registration, including the updating of
users’ Registered Location information, is critical to ensuring that providers can route all
calls properly, especially emergency calls to appropriate emergency services personnel.
(See “Emergency 911 Calls Using VRS or IP Relay” below.)

Users may register with any VRS or IP Relay provider they choose, regardless of any
prior relationship they may have had with another VRS or IP Relay provider. The default
provider will route and deliver all of the user’s incoming and outgoing calls, unless the
user chooses to place a call with, or receives a call from, an alternate provider. (See
“Placing or Receiving Calls Through An Alternate Provider” below.) Consumers may
change their default providers at any time. (See “Changing Default Providers” below.)

Registration Schedule and Transitioning to Ten-Digit Geographic Numbers
Beginning December 31, 2008, any eligible new VRS or IP Relay users (those using
VRS or IP Relay for the first time), and any eligible newly-provisioned VRS or IP Relay
users, including users to whom a VRS or IP Relay provider delivers a new device or
application software download, must register with a provider and obtain a ten-digit
geographic number.

For existing users (for example, users who have been issued proxy numbers, or who
have been issued devices that connect with a provider’s service), the FCC has
established two time periods for the transition to the use of the new ten-digit numbers: a three-month Registration Period, and a six-month Permissive Dialing Period.
Three-Month Registration Period. Because it may not be possible for all current VRS
and IP Relay users to register with a default provider by December 31, 2008, the FCC
has established a Registration Period to allow existing VRS and IP Relay users to
register with a default provider. Existing users may register with the provider of their
choice during the three-month period beginning December 31, 2008, and ending March
31, 2009.

Six-Month Permissive Dialing Period. Between December 31, 2008, and June 30, 2009,
VRS or IP Relay users who have received ten-digit geographic numbers may still receive
calls to their former “proxy” or “alias” numbers. Default providers will provide messages
notifying callers of their users’ new ten-digit geographic numbers and advising callers
that, after June 30, 2009, users may only be reached by dialing the new number.
(Please note that, after June 30, 2009, any toll-free number used to route VRS or IP
Relay calls must be directed to the appropriate ten-digit geographic number. (See
“Individual Toll-Free Numbers” below.)

After June 30, 2009, all eligible VRS and IP Relay users must be registered with a
default provider in order to place a non-emergency call through any VRS or IP Relay
provider.

Placing or Receiving Calls Through an Alternate Provider (“Dial-Around” Calls)
VRS and IP Relay users are not limited to placing or receiving calls through their default
provider. They have the right to place or receive calls through any authorized VRS or IP
Relay provider, as they have done in the past, without any penalty or retaliation from
their default provider. Users can place a call through an alternate provider by clicking on the URL Internet address of the provider, or by dialing the toll-free number of the
provider they wish to handle their call. Default providers may not configure their end
user equipment to make reaching an alternate provider more difficult after ten-digit
numbering than before ten-digit numbering. Similarly, VRS and IP Relay users may
receive calls from voice telephone users dialing a provider’s toll-free number and asking
to be connected to the VRS or IP Relay user’s ten-digit geographic number.
Changing Default Providers (Functionality of End User Equipment After the Switch)
VRS or IP Relay users may select and register with a new default provider at any time
and may also have their ten-digit geographic numbers transferred (“ported”) to that
provider. The procedures for porting a VRS or IP Relay telephone number and a voice
telephone number are the same. For more information on local number portability, see
the FCC’s consumer fact sheet at www.fcc.gov/cgb/consumerfacts/numbport.html.

VRS or IP Relay users switching to a new default provider and porting their numbers are
entitled to keep equipment supplied by another VRS or IP Relay provider. The new
default provider must work with the users’ equipment to ensure that users can make and receive VRS and IP Relay calls, as well as point-to-point (non-relay) calls. Users should not assume that enhanced features of the equipment, such as missed call lists or speed dial lists, will still be available after switching default providers. Because providers offer these features on a competitive basis, users should ask, prior to selecting or changing default providers, whether and how a prospective default provider can provide enhanced services on the user’s equipment.

Limits on the Assignment of Ten-Digit Geographic Numbers
Users may obtain separate ten-digit geographic numbers for different services (for
example, one number for VRS and a second number for IP Relay). The FCC’s rules do
not prohibit a provider from offering a feature that automatically forwards incoming calls
to one service (VRS, for example) to the user at another service (IP Relay, for example), if both numbers are obtained from the same provider and if this arrangement does not result in additional costs to the Interstate TRS Fund.

For the same service, a user also may obtain separate ten-digit geographic numbers for
devices placed at different locations (for example, one VRS device at home and another
at the office). As noted above, the FCC’s rules do not prohibit a provider that has issued more than one ten-digit geographic number for the same service (but different devices) from offering a feature that automatically forwards an incoming call to an Internet address associated with one telephone number to the user at an Internet address associated with another telephone number, if forwarding does not result in additional costs to the Interstate TRS Fund.

Individual Toll-Free Numbers
Some VRS and IP Relay providers have already issued their users individual, toll-free
numbers that permit calls to users from anywhere within the United States without
incurring long distance charges (the call is free of charge to the calling party). VRS or IP Relay users may retain current toll-free numbers or obtain new toll-free numbers if: (1) they have also been assigned ten-digit geographic numbers by June 30, 2009, (the last day of the permissive dialing period); (2) the toll-free numbers are directed to users’ ten-digit geographic numbers by that date; and (3) such arrangements do not result in additional costs to the Interstate TRS Fund. (See “Numbering Costs” below.)

Numbering Costs
Consistent with the Communication Act’s functional equivalency mandate, costs typically paid by voice telephone users are not compensable from the Interstate TRS Fund.

These costs include: (1) the costs of obtaining a ten-digit geographic number; (2) the costs of obtaining and using an individual toll-free telephone number; and (3) E911 charges that may be imposed under a state or local E911 funding mechanism. To protect consumers, the FCC requires any VRS or IP Relay provider wishing to pass on to users any noncompensable, numbering-related costs to first obtain approval from the FCC.

Emergency 911 Calls Using VRS or IP Relay
Under the FCC’s new emergency call handling rules, VRS and IP Relay users will be
able to make an emergency call through their default provider and have the call, along
with the ten-digit number and Registered Location of the caller, automatically route to an appropriate public safety answering point (E911 call center). In addition, all 911
emergency calls made through VRS or IP Relay must receive priority attention so that
they will be answered by the first available CA ahead of all other non-emergency calls.
Users are strongly encouraged to provide accurate and up-to-date Registered Location
information to their default provider, both when registering with their default provider and ANY time they change the location from which they are using the service. Without
accurate and up-to-date location information, providers will be unable to send accurate
location information or route 911 calls to appropriate emergency personnel. Remember,
in an emergency, seconds count – please keep your Registered Location information
updated at all times.

Emergency Calling Tips for VRS and IP Relay Users
Make sure you are familiar with your provider’s procedures for updating your Registered
Location, and promptly update the information any time it changes, even if the change is temporary.

Know any limitations of your service; for example, have a plan for making emergency
calls in the event of a power or Internet outage. Inform children, babysitters, and visitors about using your VRS or IP Relay service; the limitations, if any, on placing emergency calls; and all information needed in the event of an emergency. Keep instructions for using the service, as well as your address and other information, written down and near your VRS or IP Relay equipment.

Filing a Complaint with the FCC
If you have a problem completing a 911 call, the important thing is to first reach
help. Either dial-around to another provider to tell them about the emergency
(including your location), or utilize your back-up plan for emergency calling. As
soon as practicable after the emergency, notify your provider of any problem completing a 911 call through that provider. If your provider cannot or does not properly address any problem, you can file a complaint with the FCC. There is no charge for filing a complaint. You can file your complaint using an on-line complaint form found on the FCC Web site at esupport.fcc.gov/complaints.htm. You can also file your complaint with the FCC’s Consumer Center by emailing fccinfo@fcc.gov; calling 1-888-CALL-FCC (1-888-225-5322) voice or 1-888-TELL-FCC (1-888-835-5322) TTY; faxing 1-866-418-0232; or writing to:

Federal Communications Commission
Consumer & Governmental Affairs Bureau
Consumer Inquiries and Complaints Division
445 12th St., SW
Washington, DC 20554

What to Include in Your Complaint
The best way to provide all the information the FCC needs to process your complaint is
to complete fully the on-line complaint form. When you open the on-line complaint form,
you will be asked a series of questions that will take you to the particular section of the
form you need to complete. If you do not use the on-line complaint form, your complaint, at a minimum, should indicate:
• your name, address, email address, and phone number where you can be reached;
• whether you are filing a complaint on behalf of another party, and if so, the party’s
name, address, email address, day time phone number, and your relationship to the
party;
• preferred format or method of response (letter, fax, voice phone call, email, TRS,
TTY, ASCII text, audio recording, or Braille);
• that your complaint is about TRS;
• the name, address, and telephone number (if known) of the company or companies
involved with your complaint; and
• a brief description of your complaint and the resolution you are seeking, and a full
description of any equipment or service you are complaining about, including date of
purchase, use, or attempt to use.

For More Information
For more information about TRS, VRS, or IP Relay, or to learn more about FCC
programs to promote access to telecommunications services for people with disabilities,
visit the FCC’s Disability Rights Office Web site at www.fcc.gov/cgb/dro. For
information about other telecommunications issues, visit the FCC’s Consumer &
Governmental Affairs Bureau Web site at www.fcc.gov/cgb, or contact the FCC’s
Consumer Center using the information provided for filing a complaint.