VoiP

Since Americans were first able to dial "9-1-1" to reach emergency services in 1965, the public increasingly has come to depend on 911 in times of crisis. The communications industry, the states, and the Federal Communications Commission ("FCC") have worked hard to ensure that 911 is almost universally available on traditional wireline and wireless phones so that the public has access to emergency services. Telecommunications capabilities have advanced considerably since 1965. Most wireline 911 service has been enhanced ("E911") with the ability to provide caller identification and location information to the call answering center ("E911") and the FCC has established a program to require wireless telephone carriers to provide E911 capability. Not long ago, however, the states and the FCC began to recognize that consumers may not always understand that E911 and basic 911 services may work differently - or not at all - over Voice over Internet Protocol ("VoIP") services. Because in many cases, VoIP services operate much like traditional telephone service, including the capability to make calls to and receive calls from users on the traditional telephone network, some customers assume that these services also offer comparable access to 911 services.

In May 2005, the FCC adopted rules that respond to the threat that such misunderstandings pose to public safety. The FCC adopted rules requiring providers of interconnected VoIP services to supply 911 emergency calling capabilities to their customers as a mandatory feature of the service by November 28, 2005. "Interconnected" VoIP services are VoIP services that allow a user generally to receive calls from and make calls to the traditional telephone network. Under the FCC rules, interconnected VoIP providers must:

• Deliver all 911 calls to the local emergency call center;

• Deliver the customer’s call back number and location information where the emergency call center is capable of receiving it; and

• Inform their customers of the capabilities and limitations of their VoIP 911 service.