Internet Relay Providers Resist NENA Proposal for 911 Call Forwarding
The FCC shouldn’t allow relay providers to forward 911 calls to other providers, Sorenson and other Internet relay providers said in reply comments. Earlier this month, in initial comments on a rulemaking about the FCC 10-digit numbering plan for Internet relay, the National Emergency Number Association said the FCC should require relay providers to forward 911 calls to other providers if they don’t answer in a set period (CD Aug 12 p6). In a reply, AT&T opposed imposing slamming and other new customer privacy rules on relay providers.
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A forwarding requirement would “absolve” understaffed providers “of any responsibility for complying with the rules, and could result in a ‘round robin’ where 911 calls are shuttled multiple times to different providers before being processed,” Sorenson said. “Each provider must be able to prioritize and handle all 911 calls that it receives.” Forwarding “goes beyond functional equivalency” required by the Americans with Disabilities Act, GoAmerica said. “There is no record to support the need for this added functionality.”
AT&T opposed a forwarding obligation, too, but for technical reasons. To implement the process, providers “would need to develop a system to exchange information in real-time that will assess the CA [communications assistant] availability of each provider,” the carrier said. “While such a system may be technically feasible, it would be difficult to develop, test, and implement the system” by Dec. 31, the date by which providers must implement the 10-digit numbering system, it said.
Requiring providers to forward 911 calls is better than forcing them to drop non-911 calls, said NeuStar, which serves as the North American Numbering Plan Administrator. But the company acknowledged the possibility that “a caller could face a circumstance where there was no available CA in any TRS provider.”
Meanwhile, AT&T opposed adoption of slamming rules for Internet relay. The rules, endorsed only in initial comments, would protect relay users from unauthorized default provider changes. The FCC didn’t adopt slamming rules on voice carriers until it developed a “substantial record of complaints from consumers,” AT&T said. The FCC hasn’t done the same for Internet relay, it said. “Extending all of the slamming rules to Internet-based TRS providers would be a solution without a problem to resolve.” Similarly, the FCC should “carefully consider” whether customer proprietary network information (CPNI) rules are “necessary in the TRS context,” AT&T said. Privacy and confidentiality requirements are in place, as are bars on unfair and deceptive marketing practices, it said. “Additional privacy requirements, like the existing CPNI rules, accordingly may add little privacy value.”
Groups lobbying on behalf of the deaf people for slamming and CPNI rules urged more privacy protections. Ten- digit numbers for relay automatically should be registered on the national Do-Not-Call list, said a filing by the National Association of the Deaf and five other advocates for the deaf and hearing impaired. “The TRS Fund need not pay for unwanted and unsolicited telemarketing calls to TRS users.”
Sorenson urged the FCC to act speedily in selecting a neutral third-party administrator to build the 10-digit plan’s underlying database of phone numbers and Internet addresses. “If that selection is not made soon, providers will remain in the dark on key technical specifications regarding the TRS Telephone Numbering Directory,” it said.