Understanding the Importance of 911 Services
The ability to access emergency services by dialing 911 is a fundamental aspect of public safety and emergency preparedness. It is crucial for consumers using telephone services, regardless of the technology employed, to be able to reach emergency services efficiently. To ensure that consumers opting for Voice over Internet Protocol (VoIP) services can still access emergency services without hindrance, the Federal Communications Commission (FCC) has implemented requirements for providers of "interconnected" VoIP services. These services use the Public Switched Telephone Network (PSTN), including wireless networks, to originate and terminate calls, ensuring they meet Enhanced 911 (E911) obligations. E911 systems play a vital role by automatically providing the 911 caller's callback number and, in most cases, their location information to emergency service personnel.
How Traditional and VoIP 911 Services Differ
The Functionality of Traditional 911 Calls
When you make a 911 call from a traditional telephone, the call is typically routed to a Public Safety Answering Point (PSAP). This PSAP is responsible for assisting individuals within a specific geographic area or community. PSAP personnel can usually automatically determine your location and direct the nearest emergency responders accordingly. Additionally, they can often identify your telephone number, allowing them to call you back if the call gets disconnected.
The Unique Aspects of VoIP 911 Service
VoIP services operate differently from traditional phone services, which means consumers using VoIP should be aware that their 911 service may function differently. In response to FCC actions, VoIP service providers are working towards bridging these differences. However, some potential differences include:
1. **Connection Issues**: VoIP 911 calls might not connect directly to the PSAP or could mistakenly ring to an administrative line of the PSAP, which may not be staffed after hours or by trained 911 operators.
2. **Transmission of Information**: VoIP 911 calls may connect to the PSAP but fail to automatically transmit the user's phone number and/or location information.
3. **Updating Information**: VoIP customers may need to provide their location or other details to their service providers and update this information if they change locations to ensure proper functioning of their VoIP 911 service.
4. **Service Interruptions**: VoIP services might not function during power outages or if the Internet connection fails or becomes overloaded.
FCC Regulations for Interconnected VoIP Providers
To address these differences and mitigate any potential risks to public safety, the FCC has imposed several requirements on interconnected VoIP providers:
Mandatory 911 Service Provision
- **Automatic 911 Service**: All interconnected VoIP providers must automatically offer 911 services as a standard, mandatory feature to all their customers. Customers cannot opt out of this essential service.
- **Location Information**: Before activating a new customer's service, providers must obtain the physical location where the service will initially be used. This information is crucial for emergency services personnel to locate any customer dialing 911.
Ensuring Accessibility and Awareness
- **Transmission Requirements**: Interconnected VoIP providers must ensure that all 911 calls, along with a callback number and the caller's registered physical location, are transmitted to the appropriate emergency services call center or local emergency authority.
- **Customer Awareness**: Providers are required to take necessary steps to ensure that customers clearly understand any limitations of their 911 service. They must explicitly inform new and existing customers, using plain language, of the scenarios where 911 service may not be available or may have limitations compared to traditional 911 services.
Customer Notification and Acknowledgment
- **Distribution of Warning Labels**: Providers must distribute labels to all customers, warning them if their 911 service might be limited or unavailable. These labels should be placed on or near the equipment used with the interconnected VoIP service.
- **Acknowledgment of Limitations**: Providers must obtain affirmative acknowledgment from all existing customers, confirming their awareness and understanding of any 911 service limitations.
Handling Areas with Limited Capability
In some regions, emergency service providers might not be equipped to receive or process the location information or callback number automatically transmitted with 911 calls. In such areas, interconnected VoIP providers must ensure that a 911 call is routed correctly to the appropriate PSAP.
By understanding these FCC requirements, consumers and providers can work together to ensure that VoIP services meet safety standards and provide reliable access to emergency services.
