The FCC shouldn’t allow relay providers to forward 911 calls to other providers, Sorenson and other Internet relay providers said in reply comments. Earlier this month, in initial comments on a rulemaking about the FCC 10-digit numbering plan for Internet relay, the National Emergency Number Association said the FCC should require relay providers to forward 911 calls to other providers if they don’t answer in a set period. A forwarding requirement would “absolve” understaffed providers “of any responsibility for complying with the rules, and could result in a ‘round robin’ where 911 calls are shuttled multiple times to different providers before being processed,” Sorenson said. Forwarding “goes beyond functional equivalency” required by the Americans with Disabilities Act, GoAmerica said. AT&T opposed a forwarding obligation, too, but for technical reasons. To implement the process, providers “would need to develop a system to exchange information in real-time that will assess the CA [communications assistant] availability of each provider,” the carrier said. “While such a system may be technically feasible, it would be difficult to develop, test, and implement the system” by Dec. 31, the date by which providers must implement the 10-digit numbering system, it said. Meanwhile, AT&T opposed adoption of slamming rules for Internet relay. The rules, endorsed only in initial comments, would protect relay users from unauthorized default provider changes. The FCC didn’t adopt slamming rules on voice carriers until it developed a “substantial record of complaints from consumers,” AT&T said. The FCC hasn’t done the same for Internet relay, it said. “Extending all of the slamming rules to Internet-based TRS providers would be a solution without a problem to resolve.”

No relay provider should read the FCC order on a 10- digit numbering plan for Internet-based telecom relay services (CD Aug 18 p8) as empowering to complicate consumers’ efforts to access alternative providers by dialing around, TRS provider CSDVRS said. In a petition for clarification, CSDVRS said it fears that relay providers might get the wrong idea from “the FCC’s new emphasis on having a default provider” handling nearly all inbound and outbound calls for registered users. The FCC should clarify that no default provider is allowed to “create barriers that would impede or discourage a user” from dialing around, including “pop-up screens or warning messages, or degradation of the TRS call, video quality or video interpreter capabilities,” it said. The default provider rule is “flawed because of two fundamental differences” between relay services and regular switched-based or VoIP voice calls, CSDVRS said. The required speed of answer for relay services is “not at all functionally equivalent to the dial tone enjoyed by voice telephone users,” and “there is no fiduciary relationship” between a relay user and default provider, it said. The differences “raise questions about having to rely on the default provider for all incoming and outgoing calls, and make all the more critical the need for clear FCC guidance requiring all providers to facilitate calls to competing providers.”

Deaf interest groups, telecom relay providers and others argued details on an FCC plan to give 10-digit phone numbers to deaf people using Internet-based TRS services. They filed comments Friday on a rulemaking (CD June 26 p2) on the 10-digit numbering plan. The FCC sought comment on 911 and other issues, as well as how it might apply customer proprietary network information (CPNI), slamming and other customer privacy rules to relay providers. Relay providers have until Dec. 31 to implement a 10-digit plan.

Sorenson will ask a federal court to stay part of an FCC order on marketing rules for telecom relay service providers unless the FCC does so by July 24, Sorenson said Monday. Sorenson disputes rules adopted last November that ban TRS providers from contacting customers to “attempt to influence … [consumer] use of relay service” or encourage participation in lobbying (CD July 3 p6). Last month, Sorenson sought review in the 10th U.S. Circuit Court of Appeals in Denver. A late May FCC order intended to clarify limits only “made things worse -- not better -- exacerbating the conflict” with the Constitution, Communications Act and Administrative Procedure Act, Sorenson said.

Rules to protect deaf consumers from unwanted marketing and lobbying have created a double standard for how the FCC regulates telecom relay service providers and dial-tone carriers, said relay providers and others. But advocates for deaf people said marketing is one issue for which the FCC should treat TRS providers differently. “If we get abused, the fundamental principles of relay service will not meet its full potential,” said Claude Stout, executive director of Telecommunications for the Deaf and Hard of Hearing (TDI). If TRS users believe their call is being monitored or their data will be used for other purposes, they will be “less confident” to use relay service, he said. “We need to make sure that doesn’t happen.”

The FCC adopted the National Exchange Carrier Association’s annual report on the telecommunications relay services fund, it said late Tuesday. NECA projected an $805.5 million TRS fund for the July 2008-June 2009 rate year (CD May 5 p8).

An FCC order on a 10-digit numbering plan for IP relay services most closely resembles a system pitched by AT&T and GoAmerica, but also incorporates elements of other proposals, the FCC said. The order, released late Tuesday, recommends a single database of phone numbers and IP addresses, maintained by a neutral party. Access would be limited to IP relay providers, the FCC said. But the FCC didn’t throw out proposals by NeuStar and CSDVRS. “We find that no single Industry Proposal represents the best implementation of a centralized numbering directory mechanism, but instead find that a combination of different elements” is appropriate, the FCC said.

Internet-based speech-to-speech services should qualify for Telecom Relay Service fund subsidies, the FCC tentatively concluded late Wednesday in a notice of proposed rulemaking adopted. Speech-to-speech, a TRS service, is used by people with speech disabilities. The FCC asked if IP STS should be compensated at the same rate as non-IP STS services, and for comment on how to improve provision of STS. This includes whether to extend to 20 minutes from 15 the minimum a relay operator must stay on a call before switching to another operator. The notice also seeks comment on ways to improve outreach associated with STS, the FCC said.

The FCC adopted a 10-digit numbering plan for Internet- based relay services for the deaf, the commission said late Wednesday. The press release gave no technical specifics, but the original draft order most closely resembled a proposal by AT&T and GoAmerica (CD June 9 p7). Once it is implemented, telecom relay service users will be able to use 10-digit phone numbers to call and be called by hearing and TRS users, the FCC said. Relay users will be able to buy service from any IP Relay company, and port numbers from one provider to another, it said. The order requires providers to obtain and maintain information on their users’ physical locations, and to automatically route emergency calls to use the information to route them the appropriate emergency service authorities. The FCC previously imposed that obligation on interconnected VoIP carriers, it said. IP Relay providers have until Dec. 31 to comply with the order, the FCC said. As expected, the FCC attached a notice of proposed rulemaking seeking comment on the potential application of slamming, CPNI and other related rules to IP relay.

FCC commissioners are unlikely to oppose a proposed order circulated on a 10-digit numbering plan for IP-based telecom relay services, said an industry source close to the proceeding. “The commission has a strong interest in making sure that the new 10-digit plan gets rolled out promptly,” the source said. It doesn’t seem that the commissioners will vote before the June 12 meeting at which the order is set for consideration, the person said. But an FCC source said an early vote is “certainly possible,” not only on the 10-digit plan but also on the other two wireline items set for the meeting. They include a proposed order to extend indefinitely FCC enforcement of the federal do-not-call list and a notice of proposed rulemaking about providing TRS speech-to-speech services. Of three 10-digit plan proposals, a pitch by AT&T and GoAmerica (CD June 2 p10) most closely resembles the draft. GoAmerica and the sources of the other two proposals, NeuStar and CSDVRS, are doing “heavy lobbying” -- but the commissioners and their staff “have been intentionally vague and not going into specifics” in meetings with industry, said another industry official close to the proceeding. That’s not unusual, the source said. “They need to be careful not to do anything that could derail their internal process.”