Federal Comms. Comm'n, First Internet-based TRS Order, 23 FCC Rcd 11591 (June 24, 2008).
On June 24, 2008, the Federal Communications Commission issued the First Internet-based TRS Order, in which it adopted a uniform numbering system for iTRS. The Commission established the numbering system to advance functional equivalency by ensuring that deaf and hard-of-hearing iTRS users can be reached by hearing telephone users in the same way that hearing telephone users are reached.
The numbering system was designed to ensure that emergency calls placed by iTRS users would be directly and automatically routed to the appropriate emergency services authorities. The system also provides the benefits of local number portability, to allow deaf and hard-of-hearing iTRS users to port their telephone numbers from one iTRS provider to another. The Commission’s numbering plan included the creation of a central database mechanism that maps the NANP telephone numbers assigned to iTRS users’ devices to an appropriate IP address known as a Uniform Resource Identifier (URI).
In the First Internet-based TRS Order’s Further Notice of Proposed Rulemaking, the Commission sought comment on issues involved in using toll-free numbers for iTRS, including any impact that such numbers may have on the provision of 911 service and whether iTRS users should be subject to a fee for use of a personal toll-free number, as hearing users are.
Prior to the Commission’s numbering plan, there was no uniform numbering system for iTRS. Rather, iTRS users were reached at a dynamic IP address, a proxy or alias number, or a toll-free number. In the case of toll-free numbers, an iTRS user would provide the number to any hearing user. When a hearing user dialed the iTRS user’s toll-free number, the voice call was routed by the PSTN to the provider that had subscribed to the number and assigned it to a user. That toll-free number was not linked to a user-specific local number but the provider would be able to translate the toll-free number dialed by the hearing user to the iTRS user’s IP address in the provider’s database.
However, prior to December 31, 2008, iTRS providers did not share databases, and therefore, the iTRS user and people calling that user were forced to use the service of the iTRS provider that gave the user the toll-free number. This arrangement was in tension with the Commission’s interoperability requirements, which prohibit a VRS provider that seeks compensation from the Interstate TRS Fund from restricting the use of its equipment or service so that a VRS user cannot place or receive a call through a competing VRS provider.
- ↑ Id. at 11592–93, ¶1.
- ↑ Id.
- ↑ Id. at 11607, ¶35.
- ↑ Id. at 11610–12, ¶¶46-49. The iTRS Directory is administered by NeuStar. See Commission Awards Contract to NeuStar Inc. to Build and Operate Centralized Database for Internet Based Telecommunications Relay Service Numbering System, Public Notice, 23 FCC Rcd 13385 (WCB 2008).
- ↑ First Internet-based TRS Order, 23 FCC Rcd at 11630, ¶111. The Commission acknowledged that certain Internet-based TRS providers were offering and issuing numbers that were used to provide toll-free services using non-geographic area codes such as 800, 888, 877 and 866. See id. at 11602, ¶22 n.72.
- ↑ 23 FCC Rcd at 11594, ¶4.
- ↑ Id. at 11594, ¶¶4–5.
- ↑ Id.
- ↑ Id.