FCC Tackles Follow-Through on TRS 10-Digit Numbering Plan

The order builds on a June order outlining the 10-digit plan. “Ten-digit numbering will enable Internet-based TRS users to make and receive calls like anyone else, eradicating another barrier that stands in the way of functional equivalency,” FCC Chairman Kevin Martin said in a statement. “This equal access is vital to accessing jobs, education, public safety and simple communications with family, friends and neighbors.”

“Our work is not, however, complete,” Commissioner Robert McDowell said in a separate statement. “I strongly urge service providers to cooperate to implement standards- based solutions to resolve outstanding issues whenever possible, and trust that the user community will continue to provide us with valuable input as we move forward.”

“The Commission must be vigilant in addressing issues that may arise during the transition, including concerns that were raised regarding the portability of devices, promoting equipment competition, and consumer choices,” said Commissioner Michael Copps. And the FCC should “remain mindful” that deaf consumers get services at a “reasonable cost” to the Interstate TRS fund, he said.

Consumers must register for 10-digit numbers by July, the FCC said. After that, providers may not complete non- emergency calls by unregistered users, it said. The official registration period runs Dec. 31 through March, but an extra three-month “permissive calling period” will provide “a transition period in case, for some reason, some users need more time to register,” the FCC said. Proxy numbers currently used by TRS customers won’t work after June 30, and TRS providers must provide a message notifying callers of that, the FCC said. TRS users with toll-free numbers may keep them, if they register a 10-digit number and forward toll-free calls to the 10-digit number, the FCC said.

Only consumers with hearing and speech disabilities may get 10-digit numbers for use with relay services, the FCC said. TRS providers must verify accuracy of registration information, including the consumer’s name and mailing address, before issuing a ten-digit number, the commission said. Verification must include a self-certification mechanism “requiring consumers to verify that they have a medically recognized hearing or speech disability necessitating their use of TRS,” it said.

The FCC permitted TRS calling assistants (CAs) to relay background visual and auditory information to emergency workers. The information isn’t part of the conversation, so relaying it doesn’t violate TRS conversation protections, it said. CAs may also keep records of the information “for a reasonable time after an emergency call has terminated” in case emergency personnel call back, the FCC said. “Just as emergency personnel garner important information from the sounds they hear during an emergency call with a hearing user,” they may “get functionally equivalent information from the sights a CA sees during an emergency call with a VRS user,” the commission said.

The FCC decided not to change its call completion rules to permit calling assistants to end a non-emergency call to answer a 911 call. “As several providers note, allowing CAs to terminate a non-emergency call is inconsistent with the principle of functional equivalency and the role of the CA as a dial tone,” the commission said. “Moreover, the assumption that the CA would be terminating a call to answer a call that is more urgent may, in fact, not always be true.”

All Internet-based TRS users must be assigned geographically appropriate numbers, meaning within their local rate centers, the FCC clarified on its own motion. The FCC changed its mind about permitting providers to “temporarily employ suitable workarounds,” such as assigning a number “reasonably close to the user’s rate center or using remote call forwarding,” it said. It should be rare that wholesale carriers run out of geographically appropriate numbers, the FCC said. If it happens, TRS providers should tell the commission, which will work to resolve it, the FCC said.

Some costs won’t be repaid from the TRS fund, the FCC said. They include expenses typically “borne by consumers of voice communication services,” such as ten-digit number acquisition costs, toll-free number acquisition and usage costs, and any E-911 charges imposed on providers under a state or local E-911 funding mechanism, the FCC said. Internet-based TRS providers don’t have to contribute to shared local number porting costs, it said. Unlike interstate telecom carriers and interconnected VoIP providers, TRS providers don’t have end-user revenue because their costs are reimbursed by the TRS fund, the FCC noted. The FCC believes TRS users should bear portability costs the same as voice telephone users, but first must determine how to calculate providers’ share of LNP costs, it said.

The FCC also adopted general rules on slamming and consumer privacy. “The unauthorized change of an Internet- based TRS user’s default provider and the unauthorized disclosure of [a user’s] personal information are both prohibited,” the FCC said. The commission plans to adopt more specific rules “in a future order,” it said.

The FCC denied a petition by CSDVRS, GoAmerica and other relay providers to reconsider a rule requiring default providers to update an IP address database used for routing calls. The providers said it would be tough to comply with the rule because only the original, equipment-supplying provider has access to the device’s routing information. Sorenson opposed the petition, saying a new industry standard was in the works to address the problem (CD Sept 17 p11).

The commission granted most of a separate petition by CSDVRS about dial-around rules. CSDVRS had said the order could be read as empowering relay providers to complicate consumers’ efforts to access alternate providers by dialing around (CD Aug 27 p7). “Under the new numbering system, Internet-based TRS users must be able to dial around to competing providers just as they do today,” the FCC said.

Sorenson Communications is “pleased that the FCC is describing to VRS providers and consumers the services that must work with all devices,” a spokeswoman said. “Sorenson has been working hard to meet the FCC’s Dec. 31 deadline for E911 and local 10-digit numbers and this order will help us achieve that goal.” Other providers we contacted said they were still reviewing the order.