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Compliance Deadlines Set for FCC’s VoIP E911 OrderBy TED GLANZER TMCnet Communications and Broadband Columnist Note to interconnected Voice-over-Internet-Protocol providers: Mark July 29 and Nov. 28 down on your calendars; they’re big days. Indeed, VoIP providers that are similar to traditional telephone providers must, by those dates, be in compliance with the requirements set forth in the Federal Communication Commission’s June 3 enhanced 911 order, according to a release issued by the law firm of Womble Carlyle Sandridge & Rice. The FCC issued the order, which requires VoIP providers to supply E911 services to all of their customers, in response to incidents in which interconnected VoIP users were not able to reach emergency operators. The order was published in the Federal Register today, thereby triggering the effective dates of the VoIP E911 rules, the statement said. July 29 Notice and Record Requirements According to the statement, VoIP providers must, by July 29, accomplish the following: • Provide all customers with a letter describing the circumstances under which E911 service may not be available; • Provide subscribers with warning stickers or labels noting that E911 service may have limitations; • Begin maintaining records of affirmative acknowledgements from subscribers indicating that they have received and understood the letter describing E911 limitations. Nov. 28 Zero Hour According to the statement, VoIP providers must be in full compliance with the E911 order by Nov. 28. To do so, VoIP providers must submit a letter to the FCC by Nov. 28 that describes their compliance with most of the requirements contained in the order, which include the following: • The ability to transmit all 911 calls, a call back number, and the consumer’s “Registered Location” to the public service answering point via the “Wireline E911 Network;” • Provide interconnection indirectly with a 911 provider, directly with the Wireline E911 Network, or through any other means; • Implement a database of the “Registered Location” for every customer of the carrier –no opt-out allowed – that may be modified by consumers by multiple means, including used of the telephone. Meeting the deadlines is no small undertaking for VoIP providers, particularly those with large subscriber lists, Womble Carlyle partner Ross Buntrock, told TMCnet today. Indeed, under a best-case scenario, it would take VoIP providers about a year to comply with the requirements contained in the FCC’s order, Buntrock said. “I know [VoIP providers are] working double time [to meet the deadlines],” Buntrock said. “Most of the big dogs, such as Vonage and Sun Rocket, are in pretty good shape,” Buntrock said that he had heard rumors that some providers may request extensions, but “they would not be well-received” now, considering the amount of time left to comply. “The FCC would tell the [providers] to make their best efforts to comply,” Buntrock said, adding that a few companies would probably seek extensions as deadlines loom larger. Financial Beast of Burden? While the FCC’s order was necessary, applauded and long overdue, there are certain financial realities facing VoIP providers that must comply with the E911 rules. Indeed, VoIP providers are taking two hits to their proverbial wallets as a result of the E911 order. First, VoIP providers must obtain the rights to offer E911 services. In so doing they have a particularly unenviable bargaining position considering that (1) they have to negotiate primarily with competitors or a few independent companies to obtain the actual E911 services; and (2) they must make available E911 by a date certain that everyone knows about. Tough to find bargains when having to deal with those circumstances The second significant financial hit that VoIP providers have to absorb are the costs associated with showing compliance to the FCC in a short period of time. ----- 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 |