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FCC Offers VoIP Providers Extra Time on E911
[July 26, 2005]

FCC Offers VoIP Providers Extra Time on E911

By TED GLANZER
TMCnet Communications and Broadband Columnist

Interconnected voice over Internet Protocol (VoIP) service providers still scrambling to meet the subscriber notification provisions of the Federal Communications Commission's rules governing enhanced 911 (E911) capabilities by July 29 can breathe a little easier today.

Indeed, the Commission's Enforcement Bureau announced in a public notice Tuesday that it will grant interconnected VoIP service providers with 30-day extensions so that they may obtain acknowledgements from 100 percent of their subscribers that they have read and understood an advisory concerning the limitations of their E911 service.

There is one catch for those who want the extension. According to the notice, a service provider must file by Aug. 10 a "Subscriber Notification and Acknowledgement Status and Compliance Report" that sets for the progress and projected success of the provider's compliance efforts.


For example, the report must include a description of the steps the provider has taken to advise all of its subscribers of the circumstances under which E911 may not be available or limited compared to traditional E911 service. The description should include dates and methods that the provider used to contact the subscriber.

The July 29 notification provisions are part of the Commission's June 3 "VoIP E911 Order," which requires VoIP service providers to provide E911 capabilities to all of their subscribers no later than Nov. 28 (or 120 days after the order's July 29 effective date).

The order, which was issued by the FCC in response to several incidents in which interconnected VoIP users were not able to reach emergency operators, requires providers to perform the following by July 29:

Advise all new and existing subscribers of the circumstances under which E911 service may not be available or may be limited by comparison to traditional E911 service;

Obtain and keep a record of affirmative acknowledgement by every subscriber of having received and understood the advisory; and

Begin maintaining records of affirmative acknowledgements from subscribers indicating that they have received and understood the letter describing E911 limitations.

The Enforcement Bureau said in its notice that the "brief extension" will give interconnected VoIP providers additional time to obtain subscriber acknowledgements by Aug. 29.

A provider that fails to obtain an acknowledgement is required to disconnect that subscriber's service. It's a harsh, not to mention costly, result.

"[W]e expect that if an interconnected VoIP provider has not received subscriber acknowledgements from 100 [percent] of its existing subscribers by August 29, 2005, then the interconnected VoIP provider will disconnect, no later than August 30, 2005, all subscribers from whom it has not received such acknowledgements," the notice provides.

Attorney Ross Buntrock told TMCnet last month that meeting the order's deadlines is no small undertaking for VoIP providers, particularly those with large subscriber lists.

Indeed, according to Buntrock, while they have just been given months, it would normally take a year for VoIP providers to fully comply with the June 3 order.

-----

Ted Glanzer is assistant editor for TMCnet. For more articles by Ted Glanzer, please visit:

http://www.tmcnet.com/tmcnet/columnists/columnist.aspx?id=100033&nm=Ted%20Gl
anzer

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