The ability to access emergency services by dialing 911 is a vital component of public safety and emergency preparedness. It is imperative that consumers of telephone service be able to reach emergency services regardless of the technology used to place a 911 call. To ensure that a consumer’s choice of Voice over Internet Protocol (VoIP) for telephone service does not adversely affect that consumer’s ability to access emergency services, the Federal Communications Commission (FCC) has taken steps to require that providers of “interconnected” VoIP services (VoIP services that use the Public Switched Telephone Network (PSTN), including wireless networks, to originate and terminate calls) meet Enhanced 911 (E911) obligations. E911 systems automatically provide to emergency service personnel a 911 caller’s call back number and, in most cases, location information.
When you call 911 from a traditional telephone, the call in most cases is sent to a Public Safety Answering Point (PSAP) that is responsible for helping people in a particular geographic area or community. PSAP personnel often can automatically identify your location and direct the closest emergency personnel to that location. They also often can automatically identify your telephone number so that they can call you back if you are disconnected. Since VoIP service works differently from traditional phone service, consumers who use it should be aware that VoIP 911 service may also work differently from traditional 911 service. VoIP service providers, in response to FCC action, are making progress in eliminating these differences, but some of the possible differences include:
1. VoIP 911 calls may not connect to the PSAP, or may improperly ring to the administrative line of the PSAP, which may not be staffed after hours, or by trained 911 operators;
2. VoIP 911 calls may correctly connect to the PSAP, but not automatically transmit the user’s phone number and/or location information;
3. VoIP customers may need to provide location or other information to their VoIP providers, and update this information if they change locations, for their VoIP 911 service to function properly;
4. VoIP service may not work during a power outage, or when the Internet connection fails or becomes overloaded.
To reduce these differences and any possible risks to public safety posed by interconnected VoIP 911 service, the FCC has imposed the following requirements:
* All interconnected VoIP providers must automatically provide 911 service to all their customers as a standard, mandatory feature without customers having to specifically request this service. VoIP providers may not allow their customers to “opt-out” of 911 service.
* Before an interconnected VoIP provider can activate a new customer’s service, the provider must obtain from the customer the physical location at which the service will first be used, so that emergency services personnel will be able to locate any customer dialing 911. Interconnected VoIP providers must also provide one or more easy ways for their customers to update the physical location they have registered with the provider, if it changes.
* Interconnected VoIP providers must transmit all 911 calls, as well as a callback number and the caller’s registered physical location, to the appropriate emergency services call center or local emergency authority.
* Interconnected VoIP providers must take appropriate action to ensure that their customers have a clear understanding of the limitations, if any, of their 911 service. All providers must specifically advise new and existing customers, prominently and in plain language, of the circumstances under which 911 service may not be available through the interconnected VoIP service or may in some way be limited in comparison to traditional 911 service. They must distribute labels to all customers warning them if 911 service may be limited or not available and instructing them to place the labels on and/or near the equipment used in conjunction with the interconnected VoIP service.
* Interconnected VoIP providers must obtain affirmative acknowledgement from all existing customers that they are aware of and understand the limitations of their 911 service.
* In some areas, emergency service providers are not capable of receiving or processing the location information or call back number that is automatically transmitted with 911 calls. In those areas, interconnected VoIP providers must ensure that a 911 call is routed to the appropriate PSAP.