The ability to access emergency services by dialing 911 is a vital component of public safety and emergency preparedness. Recent reports of consumers inability to access life-saving emergency services while using Voice over Internet Protocol (VoIP) services have highlighted a critical public safety gap. The Federal Communications Commission (FCC) has taken steps to close this gap by imposing Enhanced 911 (E911) obligations on providers of interconnected VoIP services, i.e., VoIP services that use the Public Switched Telephone Network (PSTN), including wireless networks, to originate and terminate calls. E911 systems automatically provide to emergency service personnel a 911 callers call back number and, in most cases, location information.

What Is Interconnected VoIP Service?

Interconnected VoIP service allows you to make and receive calls to and from traditional phone numbers, usually using an Internet connection, possibly a high-speed (broadband) Internet connection, such as Digital Subscriber Line (DSL), cable modem, or wireless broadband. It can be used in place of traditional phone service. Typically, interconnected VoIP technology works by either placing an adapter between a traditional phone and Internet connection, or by using a special VoIP phone that connects directly to your computer or Internet connection. While you may choose to use interconnected VoIP service from a single location, like a residence, some interconnected VoIP services can be used wherever you travel, as long as a broadband Internet connection is available. Companies offering interconnected VoIP service call it by a number of different brand names.

The Public Safety Challenges of VoIP Services

Traditional phone services have generally associated a particular phone number with a fixed address. Portable interconnected VoIP services enable consumers to take their home or business phone service almost anywhere. Because certain interconnected VoIP services can be used from virtually any Internet connection, the location of the caller cannot automatically be determined.

This portability raises a number of challenges for the emergency services community. The FCC has recently taken action to make sure that emergency calls from these VoIP services will get through to the appropriate public safety authorities, but there are certain things that consumers need to know.

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.

Because 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. The FCC and VoIP service providers are striving to eliminate these differences, but some of them are:

7         VoIP 911 call may not connect to PSAP;

7         VoIP 911 service may ring to the administrative line of the public safety answering point (PSAP), which may not be staffed after hours, or by trained 911 operators;

7         VoIP 911 service correctly connected to the PSAP, but did not automatically transmit the users phone number and/or location information;

7         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;

7         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:

7         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.

7         Before an interconnected VoIP provider can activate a new customers 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.

7         Interconnected VoIP providers must transmit all 911 calls, as well as a callback number and the callers registered physical location, to the appropriate emergency services call center or local emergency authority.

7         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.

7         Interconnected VoIP providers must obtain affirmative acknowledgement from all existing customers that they are aware of and understand the limitations of their 911 service.

7         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.

Tips for VoIP Subscribers

If you have or are thinking of subscribing to an interconnected VoIP service, you should:

7         Provide your accurate physical address to your interconnected VoIP service provider to ensure that emergency services can quickly be dispatched to your location.

7         Be familiar with your VoIP service providers procedures for updating your address, and promptly update address information in the event of a change.

7         Have a clear understanding of any limitations of your 911 service.

7         Inform children, babysitters, and visitors about your VoIP service and its 911 limitations, if any.

7         If your power is out or your Internet connection is down, be aware that your VoIP service may not work. Consider installing a backup power supply, maintaining a traditional phone line, or having a wireless phone as a backup.

7         If you have questions about whether the phone service you are receiving is an interconnected VoIP service, contact your service provider for further information.

For Further Information

For more information about interconnected VoIP and 911 or about VoIP in general, see http://www.fcc.gov/cgb/consumerfacts/voip.html or www.fcc.gov/cgb/voip911order.pdf. You can also contact the FCCs Consumer Center at 1-888-CALL-FCC (1-888-225-5322)voice, or 1-888-TELL-FCC (1-888-835-5322) TTY.