Second Internet-based TRS Order

Citation: Federal Commns. Comm'n, Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, WC Docket No. 05-196, Second Report and Order and Order on Reconsideration, 24 FCC Rcd 791 (Dec. 19, 2008) ("Second Internet-based TRS Order").

Overview
In the Second Internet-based TRS Order, released on December 19, 2008, the Commission addressed issues included in the First Internet-based TRS Order’s Further Notice of Proposed Rulemaking. Among other things, the Commission provided existing users a three-month “registration period,” during which iTRS users could select a default provider, provide their Registered Location, and obtain their new ten-digit NANP telephone numbers, followed by a three-month “permissive calling period,” which ended on November 12, 2009.

During these registration and permissive calling periods, existing iTRS users were able to place and receive calls via the method used prior to implementation of the Commission’s numbering plan.22 At the conclusion of the permissive calling period, however, providers were required to register any unregistered user before completing a non-emergency VRS or IP Relay call.23

The Commission also found that, to further the goals of the numbering system, “Internet-based TRS users should transition away from the exclusive use of toll-free numbers” and required all iTRS users to obtain “ten-digit geographically appropriate numbers, in accordance with the FCC's numbering system.” The Commission reasoned that local numbers, and not toll-free numbers, should be used when contacting Public Safety Answering Points (PSAPs). Accordingly, the Commission stated that a user’s toll-free number must be mapped to the user’s local, geographically appropriate number. Moreover, the Commission found that, just as voice telephone users are responsible for the costs of obtaining and using toll-free numbers, the TRS fund should not compensate providers for the use of toll-free numbers by iTRS users.