Direct Access to 911

Related Proceedings and Rules of the FCC

Gregory Hlibok, FCC, Consumer & Governmental Affairs

Using TTYs to dial 911

Because Title II of ADA requires PSAPs be directly accessible by TTYs, using TTYs connected to wireline and analog wireless telephone system to dial 911 was technically a trouble-free task.  However, with the arrival of digital wireless phone service, TTYs users had trouble using digital wireless phone service to dial 911.  As a result, in the Fourth E911 Report and Order released in 2000, the Commission required digital wireless service providers to make technological changes in their wireless service system in order to enable TTY users with TTY-compatible handsets to place a 911 call over their networks.  However, using a TTY with a compatible digital wireless phone to dial 911 continue to present technical challenges in certain locations TTY users may not be able to complete 911 calls successfully to PSAPs.  The Commission therefore continues to encourage public safety organizations, vendors of TTY equipment for 911 call centers, TTY vendors, and wireless service providers to work together both to better identify the extent of these difficulties and to develop solutions.  In the meantime, TTY users should consider alternatives to placing an emergency 911 call as landline phone service, analog wireless service, or TRS.

Using TRS to dial 911

Handling of emergency calls.

In the TRS proceedings, the Commission had frequently reminded consumers that using TTY to call 911 directly is the best means of getting an immediate service.  However, in modifying the TRS emergency call handling rule in the 2000 Improved TRS Order, the Commission noted that some persons continue to make emergency calls via TRS and therefore the Commission concluded that providers have an “obligation to make relay calls to 911 functionally equivalent to a direct call to 911.”  The Commission subsequently clarified the rule in the 2004 Improved TRS Order that providers must use a system for incoming emergency calls that, at a minimum, automatically and immediately transfers the caller to the appropriate PSAP.  An appropriate PSAP is either a PSAP that the caller would have reached if he had dialed 911 directly, or a PSAP that is capable of enabling the dispatch of emergency services to the caller in an expeditious manner.

The Commission sought comments on the feasibility of TRS centers routing wireless emergency calls to an appropriate PSAP in its 2003 Improved TRS Order’s FNPRM.  However, because E911 was not yet available in many wireless phones and many parts of this country, in the 2004 Improved TRS Order the Commission deferred consideration of how TRS facilities should route wireless TRS calls pending further implementation of the E911 requirements.

Using TTYs to dial 911 through VoIP service

VoIP E911 Order.

On June 3, 2005, the Commission released the VoIP 911 Order, requiring providers of interconnected VoIP service to provide E911 capabilities to their customers based on a premise that consumers have a reasonable expectation to be able to call 911. Specifically, the Commission requires interconnected VoIP providers, by November 28, 2005, to transmit all 911 calls, as well as a call back number and the caller’s “Registered Location” for each call, to the PSAP, designated statewide default answering point, or appropriate local emergency authority that serves the caller’s Registered Location.  Recognizing that it currently is not always technologically feasible for providers for interconnected VoIP services to automatically determine the location of their end users without end users’ active cooperation,  the Commission stated that interconnected VoIP providers must obtain from each customer, prior to the initiation of service, the physical location at which the service will first be utilized.  The Commission also required providers of interconnected VoIP services that can be utilized from more than one physical location to provide their end users with a method of updating information regarding the user’s physical location.

In light of the requirement in Title II of the ADA that PSAPs be directly accessible by TTYs, the VoIP 911 Order’s NPRM, the Commission sought comment on whether persons with disabilities can use interconnected VoIP service and other VoIP services to directly call a PSAP via a TTY. The Commission further sought comment on whether, if so, what steps the Commission needs to ensure that people with disabilities who desire to use interconnected VoIP service obtain access to E911 services.

The Commission also noted the 1999 Section 255 Report and Order’s Notice of Inquiry, where the Commission sought comment on the extent to which Internet telephony was impairing access to communications services among people with disabilities, the efforts that manufacturers where taking to render new technologies accessible, and the degree to which these technologies should be subjected to the same disability access requirements as traditional telephony facilities.  The Commission was asking the commenters to refresh the record in that proceeding.

Using Emerging Services and Devices to dial 911

In the E911 FNPRM released on December 20, 2002, the Commission, in anticipation of a large mitigation to telecommunications services that rely on packet switched networks rather than PSTN, sought comment on the potential for the emerging services and devices to act as a means of providing access to emergency services for individuals with speech and hearing disabilities This proceeding remains an open docket, No. 94-102.

Using VRS and IP Relay to dial 911

Because the VRS and IP Relay calls are placed on the Internet, which has no geographical correlations, the providers have no way of identifying the originating location of the caller or receiving an Automatic Number Information (ANI) needed to route an emergency TRS call to an appropriate PSAP in compliance with the TRS emergency call handling rule.  In recognizing this limitation, the Commission waived the emergency call handling rule for VRS and IP Relay.  In the March 2003 IP Relay Order on Reconsideration, the Commission extended the waiver to January 1, 2008 for IP Relay and in the June 2004 Improved TRS Order, the Commission also extended the waiver for VRS to this coming January 1, 2006.

There are several possible ways Ip Relay and VRS provider could handle emergency calls.  For example, requiring consumers to register would enable the providers of IP Relay and VRS services to receive its consumers’ location information.  In theory, with access to the consumers’ location information, providers should be able to relay an emergency call to an appropriate PSAP.  The CA will need to continue relaying the message after making a second leg of call to the PSAP because the PSAP is not equipped to receive a direct IP or video call.  Thus, in this instance, the CA remains a player in relaying an emergency VRS or IP Relay call. 

Possible policy approach

The Commission understands that because many VRS and IP Relay consumers do not have a TTY or access to a PSTN telephone line, they may have to rely on VRS or IP Relay when placing an emergency call.  Providers have discussed several possible solution to this.  Among them are:

1)  Requiring VRS and IP Relay providers to obtain from each of their customer the physical location at which the service will be utilized by means of registration.  In another word, the VRS or IP Relay consumer has to pre-register with the provider before using its service.  This would enable the VRS and IP Relay providers, in most case, accurately identify their customers’ location information for the purpose of facilitating emergency calls.

2)  If mandatory registration is the preferred course, we need to consider whether there should be a shared database of the consumers’ identifying location information or that each provider maintains its database.  There are logistics we need to consider in the implementation of a shared database such as who would be the administrator to maintain and update the database and how the providers would be able to access the database.  If there should be a separate database maintained by each provider, it will mean that the consumers would need to register with each provider.

3)  Select one IP Relay and one VRS provider through a competitive bidding process to provide an emergency access service on a nationwide basis.

4)  Allow the VRS and IP Relay providers to “prioritize” the incoming calls by identifying emergency calls so that such calls can promptly be directed to a CA without waiting in a queue. 

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