Federal Communications Commission FCC 08-151
1
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Telecommunications Relay Services and
Speech-to-Speech Services for
Individuals with Hearing and Speech Disabilities
E911 Requirements for IP-Enabled Service 
Providers
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CG Docket No. 03-123
WC Docket No. 05-196
REPORT AND ORDER AND FURTHER NOTICE OF PROPOSED RULEMAKING
Adopted:  June 11, 2008 Released: June 24, 2008
Comment Date:  [21 days after publication in the Federal Register]
Reply Comment Date: [36 days after publication in the Federal Register]
By the Commission:  Chairman Martin and Commissioners Copps, Adelstein and Tate issuing separate 
statements.
TABLE OF CONTENTS
Heading Paragraph #
I. INTRODUCTION.................................................................................................................................. 1
II. BACKGROUND.................................................................................................................................... 2
III. DISCUSSION....................................................................................................................................... 14
A. Jurisdiction..................................................................................................................................... 14
B. Adoption of a Uniform Ten-Digit Telephone Numbering System for Internet-based TRS........... 20
1. Number Acquisition and Assignment...................................................................................... 25
a. Assigning Telephone Numbers to End Users ................................................................... 26
b. Internet-based TRS Providers Acquisition of Numbering Resources ............................. 29
c. Local Number Portability.................................................................................................. 34
d. Geographically Appropriate Numbers .............................................................................. 41
e. Default Provider Registration........................................................................................ 42
2. Centralized Numbering Directory Mechanism........................................................................ 46
a. Information to be Provisioned to the Central Database .................................................... 50
b. Means for Provisioning the Central Database................................................................... 55
c. Authorized Access to the Central Database...................................................................... 64
d. Other Considerations ........................................................................................................ 68
3. Neutral Administrator.............................................................................................................. 73
C. Emergency Call Handling Requirements....................................................................................... 79
D. Consumer Outreach and Education................................................................................................ 87
E. IP Relay Fraud ............................................................................................................................... 92
F. Cost Recovery Issues ..................................................................................................................... 96
G. Timeline and Benchmarks ........................................................................................................... 102
IV. FURTHER NOTICE OF PROPOSED RULEMAKING................................................................... 105
1. 911 Issues .............................................................................................................................. 106
Federal Communications Commission FCC 08-151
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2. Registration Period ................................................................................................................ 109
3. Eligibility for Multiple Telephone Numbers......................................................................... 110
4. Use of Toll Free Numbers ..................................................................................................... 111
5. Signaling................................................................................................................................ 112
6. Assignment of a Single Telephone Number to Multiple Services......................................... 113
7. Multi-Line Telephone Systems ............................................................................................. 114
8. Eligibility to Obtain Internet-Based TRS Telephone Numbers............................................. 115
9. Regulatory Treatment of IP CTS........................................................................................... 116
10. Security.................................................................................................................................. 117
11. Verification of Registration................................................................................................... 118
12. Slamming Issues.................................................................................................................... 119
13. Consumer Privacy ................................................................................................................. 131
14. Cost Recovery Issues............................................................................................................. 147
V. PROCEDURAL MATTERS.............................................................................................................. 150
VI. ORDERING CLAUSES..................................................................................................................... 160
APPENDIX A: List of Commenters
APPENDIX B: Final Rule Changes
APPENDIX C: Final Regulatory Flexibility Certification
APPENDIX D: Initial Regulatory Flexibility Certification
I. INTRODUCTION
1. In this Report and Order (Order), we adopt a system for assigning users of Internet-based 
Telecommunications Relay Services (TRS),1 specifically Video Relay Service (VRS)2 and Internet 
Protocol (IP) Relay,3 ten-digit telephone numbers linked to the North American Numbering Plan 
(NANP).4 The numbering system adopted herein will further the functional equivalency mandate by 
ensuring that Internet-based TRS5 users can be reached by voice telephone users in the same way that 
  
1 TRS, created by Title IV of the Americans with Disabilities Act of 1990, enables a person with a hearing or speech 
disability to access the nations telephone system to communicate with voice telephone users through a relay 
provider and a Communications Assistant (CA).  See Pub. L. No. 101-336,  401, 104 Stat. 327, 33669 (1990); 47 
U.S.C.  225; 47 C.F.R.  64.601 et seq. (implementing regulations).
2 VRS is an Internet-based form of TRS that allows individuals with hearing or speech disabilities to communicate 
using sign language through video equipment.  The video link allows the CA to view and interpret the VRS users 
signed conversation, and relay the conversation back and forth between the VRS user and the called party.  See 47 
C.F.R.  64.601(17); Telecommunications Relay Services for Individuals with Hearing and Speech Disabilities, CC 
Docket No. 98-67, Report and Order and Further Notice of Proposed Rulemaking, 15 FCC Rcd 5140, 515254, 
paras. 2127 (Mar. 6, 2000) (2000 TRS Order).
3 IP Relay is an Internet-based form of TRS that permits individuals with hearing or speech disabilities to 
communicate in text using a computer (or other similar device) and the Internet, rather than with a teletypewriter 
(TTY) and the Public Switched Telephone Network (PSTN).  See Provision of Improved Telecommunications Relay 
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-
67, Declaratory Ruling and Second Further Notice of Proposed Rulemaking, 17 FCC Rcd 7779 (Apr. 22, 2002) (IP 
Relay Declaratory Ruling & Second FNPRM).
4 The NANP is the basic numbering scheme that permits interoperable telecommunications service within the 
United States, Canada, Bermuda, and most of the Caribbean.  See Administration of the North American Numbering 
Plan, CC Docket No. 92-237, Report and Order, 11 FCC Rcd 2588, 2590, para. 3 (July 13, 1995) (NANP Order).
5 We use the term Internet-based TRS herein to refer to both VRS and IP Relay, unless otherwise specified.  
Although presently there is a third Internet-based form of TRS  IP captioned telephone service (IP CTS)  we will 
(continued.)
Federal Communications Commission FCC 08-151
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voice telephone users are called.  The measures we adopt today also are intended to ensure that 
emergency calls placed by Internet-based TRS users will be routed directly and automatically to the 
appropriate emergency services authorities by Internet-based TRS providers.  Consistent with the Interim 
Emergency Call Handling Order,6 we require that the ten-digit numbering plan set forth herein be 
implemented no later than December 31, 2008. In the accompanying Further Notice of Proposed 
Rulemaking (Further Notice), we seek comment on additional issues relating to the assignment and 
administration of ten-digit telephone numbers for Internet-based TRS.
II. BACKGROUND
2. Telecommunications Relay Services.  Title IV of the Americans with Disabilities Act of 
1990 (ADA) requires the creation of a nationwide TRS program to allow persons with hearing and speech
disabilities access to the nations telephone network.7 Title IV requires that TRS be available to the 
extent possible and in the most efficient manner,8 and that relay services offer access to the telephone 
system that is functionally equivalent to voice telephone services, as reflected in the TRS mandatory 
minimum standards.9 The functional equivalency standard serves as the benchmark in determining the 
services and features TRS providers must offer to consumers.10 TRS is now available nationwide, 
twenty-four hours a day, seven days a week, so that persons with hearing and speech disabilities can 
access the telephone system to make calls to, and receive calls from, voice telephone users.  In some 
circumstances, TRS equipment also permits persons with hearing disabilities to communicate directly 
with each other (i.e., peer-to-peer or deaf-to-deaf calls).
3. When Congress enacted section 225, relay calls were placed using a text telephone device 
(TTY) connected to the Public Switched Telephone Network (PSTN).  Since then, the Commission has 
recognized new forms of TRS, including Internet-based forms of TRS such as VRS,11 IP Relay,12 and IP 
CTS.13
(Continued from previous page)    
address any issues relating to IP CTS, if appropriate, in a separate order because IP CTS raises distinct technical and 
regulatory issues.  See infra note 13.
6 See 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, Report and Order, 23 FCC Rcd 5255 (Mar. 19, 2008) (Interim Emergency Call Handling Order).
7 Pub. L. No. 101-336,  401, 104 Stat. 327, 33669 (1990); 47 U.S.C.  225.
8 47 U.S.C.  225(b)(1).
9 47 U.S.C.  225(a)(3); see also 47 C.F.R.  64.604.
10 See 47 C.F.R.  64.604.
11 See 2000 TRS Order, 15 FCC Rcd at 515254, paras. 2127.
12 See IP Relay Declaratory Ruling & Second FNPRM, 17 FCC Rcd at 778384, paras. 1014.
13 Captioned telephone service is a form of TRS generally used by someone who can speak and who has some 
residual hearing.  A special telephone displays the text of what the other party is saying, so that the user can 
simultaneously listen to what is said over the telephone (to the extent possible) and read captions of what the other 
person is saying.  See Telecommunications Relay Services, and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CC Docket No. 98-67, Declaratory Ruling, 18 FCC Rcd 16121 (Aug. 1, 2003) 
(CapTel Declaratory Ruling).  With IP CTS, the connection carrying the captions between the relay provider and the 
user is via the Internet, rather than the PSTN.  See Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities; Internet-based Captioned Telephone Service, CG 
Docket No. 03-123, Declaratory Ruling, 22 FCC Rcd 379, 388, para. 22 (Jan. 11, 2007) (IP CTS Declaratory 
Ruling).
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4. Uniform Numbering for Internet-Based TRS.  Currently, VRS users do not have a reliable 
or consistent means by which others can identify or reach them.  In contrast to the voice telephone 
network, Internet-based relay services are not linked to a uniform numbering scheme.  Instead of a ten-
digit telephone number, VRS users are typically assigned a dynamic IP address.14  As a consequence, it 
is more difficult to place a relay call to a VRS user, as compared to placing a call to a voice telephone 
user, because the calling party must ascertain the VRS users current IP address each time he or she
wishes to place a call to that individual.15
5. To simplify the process of contacting VRS users, some VRS providers have created their 
own database of proxy or alias numbers that link to the IP addresses of their customers, even if a 
particular customers IP address is dynamic.16 While these numbers often resemble telephone numbers, 
which makes it easier for Internet-based relay users to give their number to hearing persons who may 
wish to call them via VRS, these databases are maintained by the service provider and generally are not 
shared with other service providers.17 Therefore, a person desiring to call an Internet-based relay user via 
the users proxy number can only use the services of the VRS provider that generates the number,18 an 
outcome that is in tension with the Interoperability Declaratory Ruling and FNPRM.19
6. IP Relay users frequently are assigned other types of unique identifiers, such as an 
instant-message service and screen-name.20 Such unique identifiers also make it more difficult to place a 
relay call to an IP Relay user, as compared to placing a call to a voice telephone user, if for no other 
reason than they cannot be dialed over a telephone.21
7. Recognizing the need for a uniform numbering system for Internet-based TRS, the 
Commission previously sought comment in May 2006 on the feasibility of establishing a single global 
  
14 Because there are more Internet users than possible IP addresses, Internet service providers generally assign a 
temporary dynamic IP address to a computer.  Dynamic addressing generally assigns an available address to the 
computer each time a connection is established.  See Ray Horak, Communications Systems and Networks (3rd ed.) at 
489 (2002).  By contrast, a static IP address is a number assigned to a computer by an Internet service provider as 
a permanent Internet address.
15 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing Disabilities, 
CG Docket No. 03-123, Declaratory Ruling and Further Notice of Proposed Rulemaking, 21 FCC Rcd 5442, 5447, 
para. 12 (May 9, 2006) (Interoperability Declaratory Ruling and FNPRM); see also Telecommunications Relay 
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-
123, Notice of Proposed Rulemaking, 20 FCC Rcd 19476, 1948182, paras. 1314 (Nov. 30, 2005) (VRS/IP Relay 
911 NPRM).
16 Interoperability Declaratory Ruling and FNPRM, 21 FCC Rcd at 5459, para. 46.
17 Id.
18 Id. at 545960, para. 46.
19 In the Interoperability Declaratory Ruling and FNPRM, we ruled that a VRS provider that restricts the use of its 
equipment or service so that a VRS user cannot use such equipment or service to place or receive a call through a 
competing VRS provider is ineligible for compensation from the Interstate TRS Fund.  See id. at 5454, para. 29.  
Such a practice, we concluded, violates section 225(a)(3)s functional equivalency mandate and is inimical to the 
public interest.  Id. at 545456, paras. 3036.
20 See Sorenson Refresh Comments at 89 (noting that IP Relay addresses are often associated with a screen name, 
or some identifier other than an IP address).
21 When IP Relay is made available through a simple web interface, see, e.g., http://www.sprintip.com, users are 
even more difficult to reach given that the user may not need to provide any identifying information (such as a user 
login name) before initiating a call.
Federal Communications Commission FCC 08-151
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database of proxy numbers for VRS users that would be available to all service providers, so that a 
hearing person can call a VRS user through any VRS provider, and without first having to ascertain the 
VRS users current IP address.22 The Commission requested comment on technical and economic issues
relating to the establishment of a numbering scheme, including the need for standard protocols so that 
the database system can work with all VRS equipment and services.23 The Commission also sought 
comment on whether there are aspects of proxy numbers that are dependent on functionalities outside of 
a database, such as functionalities in the users equipment, as well as any other technical issues 
commenters may have deemed relevant to the Commissions inquiry.24
8. In addition to seeking comment on the use of proxy numbers, the Commission sought 
comment on assigning Internet-based TRS users uniform and static end-point numbers linked to the 
NANP so that the numbers will remain constant and thereby provide Internet-based TRS users a reliable 
and consistent means by which they may receive calls from non-TRS users.25 The Commission also 
sought comment on the maintenance and operation of such a database, and on the role of the Commission 
in creating and maintaining the database.26
9. In the March 19, 2008 Interim Emergency Call Handling Order, the Commission 
announced its intention to adopt a ten-digit numbering plan for Internet-based TRS in a future 
Commission order.27 That same day, and to ensure that the record reflects new technical, economic, and 
administrative developments related to the implementation of a ten-digit numbering system, the 
Commissions Consumer & Governmental Affairs Bureau (Bureau) issued the Numbering PN, inviting
interested parties to refresh the record on issues relating to the assignment and administration of ten-digit 
numbering for Internet-based TRS users.28  The Bureau also sought to refresh the record on other issues 
related to numbering, including number resource conservation,29 and the application of the Commissions
anti-slamming rules,30 CPNI rules,31 and local number portability (LNP) rules32 to Internet-based TRS 
  
22 Interoperability Declaratory Ruling and FNPRM, 21 FCC Rcd at 5460, para. 47.
23 Id.
24 Id.
25 Id. at 5460, para. 48.
26 Id at 5460, paras. 4950. Eight comments and five reply comments were filed with the Commission in response 
to the Interoperability Declaratory Ruling and FNPRM.  Commenters generally supported the establishment of a 
uniform numbering system linked to the NANP for Internet-based TRS users.  See, e.g., Comments of AT&T Inc., 
July 17, 2006 at 24; Comments of CSD, July 17, 2006, at 19; Comments of Hands On, July 17, 2006 at 115; 
Comments of Sorenson, July 17, 2006 at 27; Comments of Sprint Nextel Corporation, July 17, 2006 at 24; 
Comments of Verizon, July 17, 2006 at 15.
27 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5257, para. 1.
28 See id. at 5257, 5269, paras. 1, 24; see also Consumer & Governmental Affairs Bureau Seeks to Refresh Record 
on Assigning Internet Protocol (IP)-Based Telecommunications Relay Service (TRS) Users Ten-Digit Telephone 
Numbers Linked to North American Numbering Plan (NANP) and Related Issues, CG Docket No. 03-123, Public 
Notice, 23 FCC Rcd 4727 (Mar. 19, 2008) (Numbering PN) (seeking to refresh the record on numbering issues for 
Internet-based TRS users).
29 See, e.g., Interoperability Declaratory Ruling and FNPRM:  Comments of Communication Service for the Deaf, 
Inc. in CG Docket No. 03-123 at 68 (July 17, 2006) (addressing numbering-related slamming and LNP issues); see 
also Ex Parte of Hands On Video Relay Services, Inc. in CG Docket No. 03-123 at 2 (Nov. 7, 2007) (asserting that 
number conservation efforts should not hinder the deployment of a numbering system for Internet-based TRS).
30 See 47 U.S.C.  258(a); 47 C.F.R.  64.1120 (slamming restrictions).
Federal Communications Commission FCC 08-151
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providers.33
10. In the Interim Emergency Call Handling Order, the Commission also announced a plan 
to hold a Stakeholder Workshop addressing ten-digit numbering for Internet-based TRS at the conclusion 
of the comment cycle established by the Numbering PN.34 The Stakeholder Workshop, which was 
attended by consumers, providers, vendors, and other interested parties, included presentations and 
discussions of three principal proposals for implementing a ten-digit numbering system for Internet-based 
TRS, as filed in the record by NeuStar, Inc., CSDVRS LLC, and AT&T/GoAmerica, Inc.35 The 
Stakeholder Workshop, which was webcast and archived for later viewing,36 also included consumers
perspectives on each of the proposals, and a discussion of technical and operational issues posed by each 
proposal.37
11. Emergency Call Handling Requirements for Internet-Based TRS.  Under the 
Commissions emergency call handling requirements, a traditional, TTY-based TRS provider must use a 
system for incoming emergency calls that automatically and immediately transfers the caller to an 
appropriate Public Safety Answering Point.38  Through a series of orders between 2001 and 2008, the 
Commission examined the applicability of these requirements to Internet-based TRS and, in particular, 
assessed the technological challenges associated with determining the geographic location of Internet-
based TRS calls.39 The Commission recognized that because these services use the Internet, rather than a 
(Continued from previous page)    
31 See 47 U.S.C.  222; 47 C.F.R.  64.2001 et seq. (CPNI requirements).
32 See 47 U.S.C.  153(30) (defining number portability); 47 C.F.R.  52.20 et seq. (LNP requirements).
33 Numbering PN, 23 FCC Rcd at 472728.  Ten comments and twelve reply comments were filed by providers and 
other entities in response to the Numbering PN.  More than four hundred individual comments were also filed.  
Commenters overwhelmingly support Commission adoption of a system for assigning ten-digit telephone numbers 
to Internet-based TRS users.
34 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5257, 5269, paras. 1, 24; see also FCC to Hold 
Workshop on Solutions for Implementing Ten-Digit Telephone Numbering for Internet-Based Telecommunications 
Relay Services on April 29, 2008, News Release (April 4, 2008); FCC Releases Agenda for April 29, 2008, 
Stakeholder Workshop on Ten-Digit Numbering Solutions for Internet-Based Telecommunications Relay Services, 
News Release (April 23, 2008) (April 23, 2008, Stakeholder Workshop News Release).
35 See infra paras. 4772; see generally April 23, 2008, Stakeholder Workshop News Release.
36 See April 29, 2008 Workshop on Ten-Digit Numbering Plan for Internet-Based TRS, available at
http://www.fcc.gov/realaudio/mt042908.ram (Workshop Webcast).
37 See April 23, 2008, Stakeholder Workshop News Release (attaching workshop agenda); see also 
http://www.fcc.gov/cgb/dro/workshop_attendees.html (list of workshop participants).
38 See 47 C.F.R.  64.604(a)(4).  We note that, as amended by the Interim Emergency Call Handling Order, section 
64.604(a)(4) now applies exclusively to TTY-based TRS providers.  The emergency call handling requirements 
applicable to Internet-based TRS providers are now set forth in section 64.605 of the Commissions rules.  See 
Interim Emergency Call Handling Order, 23 FCC Rcd at 527576, Appendix B.
39 See generally Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing 
and Speech Disabilities, CC Docket No. 98-67, Order, 17 FCC Rcd 157 (Dec. 31, 2001) (2001 VRS Waiver Order) 
(waiving emergency call handling requirement for VRS for two years); Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-67, Order, 18 
FCC Rcd 26309 (Dec. 19, 2003) (extending VRS waiver through June 30, 2004); Telecommunications Relay 
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CC Docket Nos. 90-
571 & 98-67, CG Docket No. 03-123, Report and Order, Order on Reconsideration, and Further Notice of Proposed 
Rulemaking, 19 FCC Rcd 12475, 1252021, paras. 11112 (June 30, 2004) (2004 TRS Report & Order) (extending 
VRS waiver through December 31, 2005); Telecommunications Relay Services and Speech-to-Speech Services for 
(continued.)
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telephone and the PSTN, for the link of the call between the calling party and the relay provider, the relay 
provider does not receive the automatic number identification (ANI) of the calling party.40 As a result, 
providers experience difficulty identifying the callers location and determining the appropriate public 
safety answering point (PSAP) to call to respond to an emergency.41 Nonetheless, the Commission has 
consistently emphasized the importance of access to emergency services for relay users.42 The 
Commission therefore determined that a temporary waiver was needed to the extent that these 
technological challenges hindered providers ability to immediately and automatically place the 
outbound leg of an emergency call to an appropriate PSAP, as required by the Commissions emergency 
call handling rule.43
12. In the Interim Emergency Call Handling Order, the Commission terminated the 
temporary waivers of the emergency call handling rule, effective May 21, 2008, for VRS, IP Relay, and 
IP CTS in light of the present imperative to provide Internet-based TRS users a reliable means of 
accessing emergency services.44 The Commission required Internet-based TRS providers to accept and 
handle emergency calls and to access, either directly or via a third party, a commercially available 
database that will allow the provider to determine an appropriate PSAP, designated statewide default 
answering point, or appropriate local emergency authority that corresponds to the callers location, and to 
relay the call to that entity.45  The Commission also adopted several interim emergency call handling 
requirements for Internet-based relay services, finding that these measures are needed to facilitate access 
to emergency services for consumers of Internet-based relay services, pending the adoption of a longer 
term solution.46 In particular, the Commission required Internet-based TRS providers to:  (1) implement a 
(Continued from previous page)    
Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 21 FCC Rcd 14554 (Dec. 15, 
2006) (extending VRS waiver through December 31, 2007) (2006 VRS Waiver Order); IP Relay Declaratory Ruling 
& Second FNPRM, 17 FCC Rcd at 7789, para. 30 (waiving emergency call handling requirement for IP Relay for 
one year); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, CC Docket No. 98-67, Order on Reconsideration, 18 FCC Rcd. 4761, 4766, para. 12, and 4770
71, para. 28 (Mar. 14, 2003) (IP Relay Reconsideration Order) (extending IP Relay waiver through December 31, 
2007); 2007 IP CTS Declaratory Ruling, 22 FCC Rcd at 39192, para. 30 & n.100 (waiving emergency call 
handling requirement for IP CTS until 911 access for the Internet-based forms of TRS is resolved); see generally 
2004 TRS Report & Order, 19 FCC Rcd at 12594, Appendix E (chart summarizing VRS and IP Relay waivers);
Interim Emergency Call Handling Order, 23 FCC Rcd at 5255, para. 1 (terminating VRS, IP Relay, and IP CTS 
waivers, effective May 21, 2008, and adopting interim emergency call handling requirements for Internet-based TRS 
providers).
40 See, e.g., 2004 TRS Report & Order, 19 FCC Rcd at 12522, para. 117.
41 Id.; see also IP Relay Declaratory Ruling & Second FNPRM, 17 FCC Rcd at 7789, para. 30 (recognizing that, 
without ANI of the calling party, IP Relay provider petitioner could not provide PSAP with information regarding 
the calling partys location).
42 See, e.g., VRS/IP Relay 911 NPRM, 20 FCC Rcd at 19477, para. 1 (emphasizing the need for a solution providing 
direct, automatic access to emergency services via VRS and IP Relay); IP Relay Declaratory Ruling & Second 
FNPRM, 17 FCC Rcd at 7789, para. 30 (urging IP Relay providers to develop a method by which they can 
automatically provide critical emergency information to an appropriate PSAP).
43 See, e.g., 2001 VRS Waiver Order, 17 FCC Rcd at 162, para. 13 (granting temporary waiver of emergency call 
handling requirement for VRS providers).
44 See Interim Emergency Call Handling Order, 23 FCC Rcd at 526566, para. 16.
45 See id.; 47 C.F.R.  64.605 (setting forth additional operational standards applicable to Internet-based TRS).
46 See Interim Emergency Call Handling Order, 23 FCC Rcd at 526566, 527576, para. 16, Appendix B (adopting 
new section 64.605, setting forth emergency call handling requirements applicable to Internet-based TRS; prior 
section 64.605 redesignated as section 64.606).
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system that ensures that providers answer an incoming emergency call before other non-emergency calls; 
(2) request, at the beginning of every emergency call, the callers name and location information; 
(3) deliver to the PSAP, designated statewide default answering point, or appropriate local emergency 
authority, at the outset of the outbound leg of the call, at a minimum, the name of the relay user and 
location of the emergency, as well as the name of the relay provider, the CAs callback number, and the 
CAs identification number, thereby enabling the PSAP, designated statewide default answering point, or 
appropriate local emergency authority to re-establish contact with the CA in the event the call is 
disconnected; and (4) in the event one or both legs of the call are disconnected (i.e., either the call 
between the TRS user and the CA, or the outbound voice telephone call between the CA and the PSAP, 
designated statewide default answering point, or appropriate local emergency authority), immediately re-
establish contact with the TRS user and/or the appropriate PSAP, designated statewide default answering 
point, or appropriate local emergency authority and resume handling the call, when feasible.47
13. In the Interim Emergency Call Handling Order, the Commission also announced its 
intention to adopt in a forthcoming Commission order a Registered Location process, similar to that 
adopted by the Commission in the interconnected VoIP context.48 The Commission stated that a 
Registered Location procedure constitutes [a] critical component of an E911 solution for Internet-based 
TRS providers, so that a provider may promptly determine an appropriate PSAP, designated statewide 
default answering point, or appropriate local emergency authority to call to respond to an emergency.49
III. DISCUSSION
A. Jurisdiction
14. We conclude that we have the authority to adopt a system for assigning persons using 
Internet-based TRS ten-digit telephone numbers linked to the NANP pursuant to sections 225 and 251 of 
the Act.  As set forth below, section 225 requires that functionally equivalent TRS be available 
nationwide, and directs the Commission to adopt regulations to govern the provision and compensation of 
TRS.  Section 251 grants the Commission authority to oversee numbering administration in the United 
States.
15. Section 225.  The Commissions authority to adopt a system for the assignment and 
administration of ten-digit telephone numbers for Internet-based TRS derives from section 225 of the 
Act.50 That section instructs the Commission to adopt regulations implementing section 225, including 
regulations establish[ing] functional requirements, guidelines, and operations procedures for [TRS],51 as 
well as mandatory minimum standards governing the provision of TRS.52 Section 225 also requires 
TRS to offer service in a manner that is functionally equivalent to the ability of an individual who does 
  
47 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5268, para. 21.
48 See id. at 5268, para. 22 (citing IP-Enabled Services; E911 Requirements for IP-Enabled Service Providers, WC 
Docket Nos. 04-36, 05-196, First Report and Order and Notice of Proposed Rulemaking, 20 FCC Rcd 10245, 
10271, para. 46 (June 3, 2005) (VoIP 911 Order) (describing Registered Location requirement for interconnected 
voice over Internet Protocol (VoIP) providers)); see also 47 C.F.R.  9.3 (defining Registered Location as the 
most recent information obtained by an interconnected VoIP service provider that identifies the physical location of 
an end user).
49 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5268, para. 22.
50 47 U.S.C.  225.
51 47 U.S.C.  225(d)(1)(A).
52 47 U.S.C.  225(d)(1)(B).
Federal Communications Commission FCC 08-151
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not have a [hearing or speech disability] to communicate using voice communication services.53  
Throughout its orders, the Commission has relied upon the functional equivalency standard in 
determining the services and features TRS providers, including Internet-based TRS providers, must offer 
to consumers.54 Further, section 225 requires the Commission to ensure that TRS is available to the 
extent possible and in the most efficient manner to persons with hearing and speech disabilities.55  
16. The voice telephone system is predicated on the assignment of ten-digit numbers to 
consumers, and the ability of any telephone user to reach a consumer by dialing that persons particular 
number.  Further, because location and other identifying information is attached to each number, 
consumers can dial 911 and reach emergency services that can automatically determine the callers 
location to respond to the emergency.  The same holds true for consumers of the PSTN-based TRS.  
Voice telephone users can call these consumers via TRS if they know the consumers ten-digit telephone 
number, which they provide to the CA when making the relay call.  These TRS consumers can also 
contact emergency services by either dialing 911 directly or by calling a TRS provider; in either case, the 
callers location information will automatically be passed to the emergency personnel.  This is presently 
not the case, however, with respect to consumers using the Internet-based forms of TRS.  Voice telephone 
users can call an Internet-based TRS user only if the caller knows the TRS users current Internet address
(or a proxy therefor), and the Internet-based TRS user cannot call emergency services and have location 
information automatically transmitted.
17. We therefore find that the Commissions rulemaking authority provided in section 225(d) 
encompasses the authority to adopt a system for assigning Internet-based TRS users ten-digit telephone 
numbers linked to the NANP to ensure that such consumers have access to functionally equivalent relay 
service, including the ability to receive calls from voice telephone users and to make emergency calls that 
will automatically route to an appropriate PSAP.  We also find that the Commission has jurisdiction in 
this context under the authority granted by section 225(a) to ensure that TRS is available to the extent 
possible and in the most efficient manner to individuals with hearing or speech disabilities.
  
53 47 U.S.C.  225(a)(3), (c).
54 See, e.g., 2000 TRS Order, 15 FCC Rcd at 5152, para. 23 (recognition of VRS as a form of TRS will make relay 
services functionally equivalent to voice telephone service for persons whose first language is American Sign 
Language); see generally 2004 TRS Report & Order, 19 FCC Rcd at 1254748, para. 189 (the requirement of 
functional equivalency is met by offering service in compliance with the TRS mandatory minimum standards, and 
these standards will change as technology changes).
55 47 U.S.C.  225(b)(1).
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18. Section 251.  We also find that we have authority to establish a ten-digit numbering 
regime for Internet-based TRS and to extend the LNP requirements to Internet-based TRS providers and 
their numbering partners, based upon the authority that Congress granted this Commission under section 
251(e)(1).56  In section 251(e)(1) of the Act, Congress expressly assigned to the Commission exclusive 
jurisdiction over that portion of the NANP that pertains to the United States.57 The Commission therefore 
has authority to set policy with respect to all facets of numbering administration in the United States.58  
Our plenary authority over NANP numbering resources gives us authority to require Internet-based TRS 
providers to provide NANP telephone numbers to their users.59 We exercise our authority under the Act 
to ensure that Internet-based TRS users obtain and use NANP telephone numbers in accordance with the 
ten-digit numbering plan adopted herein.60  To the extent that an Internet-based TRS provider provides 
services that offer its customers NANP telephone numbers, both the Internet-based TRS provider and the 
telecommunications carrier that secures the numbering resource from the numbering administrator subject 
themselves to the Commissions plenary authority under section 251(e)(1) with respect to those numbers.
19. In addition, we have authority under section 251(b)(2) to impose LNP obligations on the 
local exchange carrier (LEC) numbering partners of Internet-based TRS providers.61 Section 251(b)(2) 
states that all LECs have a duty to provide, to the extent technically feasible, number portability in 
accordance with the requirements prescribed by the Commission.62 The Commission has long held that 
it has authority to require that number portability be implemented to the extent technically feasible and 
that our authority under section 251(b)(2) encompasses all forms of number portability.63  In addition, 
  
56 Cf. VoIP 911 Order, 20 FCC Rcd at 10265, para. 33 (relying on the Commissions plenary authority over U.S. 
NANP numbers, particularly Congresss direction to use that authority regarding 911, to impose 911 obligations on 
interconnected VoIP providers, given interconnected VoIP providers use of NANP numbers to provide service).  A 
numbering partner is a carrier that is eligible to receive numbers directly from the NANPA or the Pooling 
Administrator (PA) and makes such numbers available to its customers through commercial arrangements.  See infra
para. 31.
57 See 47 U.S.C.  251(e)(1) (providing that [t]he Commission shall have exclusive jurisdiction over those portions 
of the North American Numbering Plan that pertain to the United States).
58 Implementation of the Local Competition Provisions of the Telecommunications Act of 1996; Interconnection 
Between Local Exchange Carriers and Commercial Mobile Radio Service Providers; Area Code Relief Plan for 
Dallas and Houston, Ordered by the Public Utility Commission of Texas; Administration of the North American 
Numbering Plan; Proposed 708 Relief Plan and 630 Numbering Plan Area Code by Ameritech-Illinois, CC Docket 
Nos. 96-98, 95-185, 92-237, NSD File No. 96-8, IAD File No. 94-102, Second Report and Order and Memorandum
Opinion and Order, 11 FCC Rcd 19392, 19512, para. 271 (Aug. 8, 1996) (explaining that by retaining exclusive 
jurisdiction over numbering policy the Commission preserves its ability to act flexibly and expeditiously).
59 See 47 U.S.C.  251(e)(1).
60 Cf. Telephone Number Requirements for IP Enabled Services Providers; Local Number Portability Porting 
Interval and Validation Requirements; IP-Enabled Services; Telephone Number Portability; CTIA Petitions for 
Declaratory Ruling on Wireline-Wireless Porting Issues; Final Regulatory Flexibility Analysis; Number Resource 
Optimization, WC Docket Nos. 07-243, 07-244, 04-36; CC Docket Nos. 95-116, 99-200, Report and Order, 
Declaratory Ruling, Order on Remand, and Notice of Proposed Rulemaking, 22 FCC Rcd 19531, 19544 para. 23 
(Nov. 8, 2007) (exercising authority under the Act to ensure that end users maintain an interest in their NANP 
numbers through the porting process) (VoIP LNP Order).
61 See 47 U.S.C.  251(b)(2); cf. VoIP LNP Order, 22 FCC Rcd at 1954344, para. 23.
62 VoIP LNP Order, 22 FCC Rcd at 1954344, para. 23.
63 Telephone Number Portability, CC Docket No. 95-116, Fourth Memorandum Opinion and Order on 
Reconsideration, 14 FCC Rcd 16459, 1646667, para. 12 (July 16, 1999).
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we believe we have a separate additional source of authority under Title I of the Act to impose LNP 
obligations on Internet-based TRS providers.64
B. Adoption of a Uniform Ten-Digit Telephone Numbering System for Internet-based 
TRS
20. As stated above, in the Interim Emergency Call Handling Order, we committed to 
adopting a system for assigning users of Internet-based TRS ten-digit telephone numbers linked to the 
NANP by second quarter 2008, with implementation to be completed no later than December 31, 2008.65  
To that end, we issued the Numbering PN,66 and received numerous responses from industry, consumer 
groups, and concerned individuals.67
21. The record reflects a general consensus that Internet-based forms of TRS should have a 
uniform numbering system to facilitate interoperability between deaf and hearing users and to support 
comprehensive E911 service.68 There is further consensus that the numbering system should utilize 
numbers from the NANP.69 Use of NANP telephone numbers will allow Internet-based TRS users to 
reach and be reached by both hearing users of the PSTN and other Internet-based TRS users by doing 
something most Americans take for granted  dialing a ten-digit phone number.  Such a system also will 
help to ensure that persons using Internet-based TRS can promptly access functionally equivalent 911 
service.70
22. We find that utilization of NANP numbers will best achieve the goal of making Internet-
  
64 Cf. VoIP LNP Order, 22 FCC Rcd at 1954447, paras. 2427 (explaining that the Commission has ancillary 
authority over interconnected VoIP services, and that its assertion of subject matter jurisdiction is reasonably 
ancillary to the effective performance of the Commissions various responsibilities).  See generally National Cable 
& Telecomms. Assn v. Brand X Internet Services, 545 U.S. 967, 976 (2005) ([T]he Commission has jurisdiction to 
impose additional regulatory obligations under its Title I ancillary jurisdiction to regulate interstate and foreign 
communications, see  [47 U.S.C.] 151161.).
65 Interim Emergency Call Handling Order, 23 FCC Rcd at 5257, para. 1.
66 See Numbering PN, 23 FCC Rcd 4727.
67 A list of commenters is attached at Appendix A.  Numerous individuals also filed brief comments.  See supra note 
33.
68 See, e.g., AT&T Refresh Comments at 1; CSDVRS Refresh Comments at 2; TDI Coalition Refresh Comments at 
2; Nebraska PSC Refresh Comments at 23; Sorenson Refresh Comments at 2; Sprint Nextel Refresh Comments at 
1; AG Bell Refresh Reply Comments at 1; AAPD Refresh Reply Comments at 2; Sonny Refresh Reply Comments 
at 1.
69 See, e.g., CSDVRS Refresh Comments at 2 (CSD and CSDVRS enthusiastically support the establishment of a 
global, uniform ten-digit telephone numbering system for all Internet-based video and text relay users.); Sorenson 
Refresh Comments at 2 ([T]he Commission should adopt a uniform numbering system for Internet-based relay 
services that is integrated with the numbering system used for traditional voice services.); GoAmerica Refresh 
Comments at 6 ([T]he Commission should mandate that Internet based TRS providers implement a functionally 
equivalent numbering system for consumers based on NANP numbers . . . .); TDI Coalition Refresh Comments at 2 
(Establishing a numbering system linked to the NANP for IP-based relay services is a critical component in 
achieving functional equivalency for IP based TRS services . . . .).
70 See NENA Refresh Reply Comments at 1 (noting the critical need for telephone number availability for 9-1-1 
purposes for the deaf and hard of hearing community); Dash Refresh Comments at 2 (10-digit NANP numbering 
is a requirement if relay providers are going to successfully interconnect to the existing emergency network.); 
CSDVRS Refresh Comments at 5 (Personal ten-digit local telephone numbers will enable relay users to have 
integrated E9-1-1 support . . . .); TDI Coalition Refresh Comments at 3.
Federal Communications Commission FCC 08-151
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based TRS functionally equivalent to traditional circuit switched telephony, and will provide Internet-
based TRS users a reliable and consistent means by which they may receive calls from voice telephone 
users.  We therefore require, consistent with the procedures set forth below, Internet-based TRS providers 
to assign Internet-based TRS users NANP telephone numbers.71 We further require Internet-based TRS 
providers to stop issuing proxy or alias numbers no later than December 31, 2008.72
23. Full connectivity between Internet-based TRS and the PSTN cannot be achieved simply 
by assigning telephone numbers to Internet-based TRS users.  The networks upon which the Internet 
portion of Internet-based TRS operates require IP addresses rather than NANP telephone numbers for 
routing.  In order to allow calls to be appropriately routed and completed, a mechanism must be created 
for mapping the telephone numbers assigned to Internet-based TRS users to the IP addresses (or other 
appropriate endpoint identifiers) used by Internet-based TRS.
24. In light of the foregoing, the Commission must specify two major items in order to 
establish a uniform ten-digit numbering system for Internet-based forms of TRS: (1) a means for NANP 
numbers to be assigned to Internet-based TRS users and (2) a central numbering directory mechanism that 
maps each NANP telephone number assigned to an Internet-based TRS user to the appropriate Internet 
address.73
1. Number Acquisition and Assignment
25. We find that it is most expedient and consistent with our numbering policies for Internet-
based TRS users to obtain NANP telephone numbers directly from their Internet-based TRS providers.  
Internet-based TRS providers may obtain such numbers either: (1) directly from the NANPA or the PA if 
they are certificated as carriers and otherwise meet the criteria for obtaining numbers; or (2) through 
commercial arrangements with carriers (i.e., numbering partners).  These are precisely the methods of 
obtaining numbers that are available to providers of interconnected VoIP service and their customers.  
Finally, Internet-based TRS users and providers of Internet-based TRS will enjoy the full benefits of 
LNP.
a. Assigning Telephone Numbers to End Users
26. As an initial matter, we determine how Internet-based TRS users are to obtain, or be 
assigned, telephone numbers.  The record reflects that there are a variety of processes which could be 
employed, which fall generally into three categories:  (1) remote call forwarding, a process whereby 
Internet-based TRS users obtain service, including a NANP telephone number, from a LEC and forward 
  
71 To the extent that TRS consumers are concerned that they will receive unsolicited telemarketing calls, we note 
that TRS users may register their numbers with the National Do-Not-Call Registry.  See Rules and Regulations 
Implementing the Telephone Consumer Protection Act of 1991, CG Docket No. 02-278, Report and Order, 18 FCC 
Rcd 14014 (July 3, 2003) (2003 TCPA Order).  Consumers can add their telephone numbers to the Registry by 
registering online at www.donotcall.gov.
72 We acknowledge that certain carriers and Internet-based TRS providers offer, and have issued or assigned to 
Internet-based TRS providers, numbers that are used to provide toll-free services using non-geographic area codes 
such as 800, 888, 877 and 866 (toll free numbers).  See, e.g., http://www.csdvrs.com (last visited June 10, 2008). 
This Order does not preclude an Internet-based TRS user from choosing to keep a toll free number previously 
obtained from an Internet-based TRS provider in lieu of obtaining a geographically appropriate number.  We seek 
comment in the Further Notice regarding issues involved in the use of toll free numbers by Internet-based TRS 
users, including whether Internet-based TRS users should be subject to a fee for use of toll free numbers as are 
hearing users.  See infra Section IV.4.
73 Numbering for Internet-based Relay Services, Report of Alliance for Telecommunication Industry Solutions 
(ATIS), Washington, D.C., at 9, para. 3.3.1 (Dec. 19, 2007) (ATIS Report).
Federal Communications Commission FCC 08-151
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the number to the appropriate Internet-based TRS provider;74 (2) Internet-based TRS users obtain NANP 
telephone numbers directly from a neutral third-party administrator;75 or (3) Internet-based TRS users
obtain numbers from Internet-based TRS providers.76
27. There is little support for the general use of remote call forwarding in the record,77 and 
we find it unreasonable to require Internet-based TRS users to subscribe to local exchange service merely 
to obtain NANP telephone numbers that can be ported to or otherwise utilized by Internet-based TRS
providers,78 especially in light of the fact that subscribers to interconnected VoIP service can obtain 
numbers directly from their service providers.  The record does demonstrate some support for Internet-
based TRS users obtaining NANP telephone numbers from a neutral third party administrator.79 Such an 
approach has, however, several disadvantages.  First, requiring Internet-based TRS users to obtain 
numbers from a non-service provider is not functionally equivalent to the processes used by voice 
telephone users and subscribers to interconnected VoIP services.  In addition, granting a neutral third-
party administrator direct access to numbering resources would not be consistent with the Commissions 
rules,80 and although the neutral third party could obtain numbering resources from numbering partners, it 
would not be economically efficient to inject a middleman into a process that can be implemented directly 
by Internet-based TRS providers and numbering partners.81 Finally, utilization of a neutral third party for 
number distribution would add unnecessary cost and complexity to the implementation process.
28. We find that the best process for Internet-based TRS users to obtain telephone numbers is 
directly from their Internet-based TRS providers.  The record generally supports this approach.82 Such a 
  
74 ATIS Report at 13, para. 4.1.4.
75 ATIS Report at 13, para 4.1.5.
76 ATIS Report at 13, paras. 4.1.14.1.3, 4.1.6.
77 See Letter from Julie Miron, Executive Director, CAC, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-
123 at 6 (filed Apr. 28, 2008) (urging that Internet-based TRS users have primary responsibility for procuring 
numbers from their LEC).  NeuStar notes that remote call forwarding can be utilized in geographic areas where 
carriers are unwilling or unable to provide geographically appropriate numbering resources to interconnected VoIP 
providers and Internet-based TRS providers.  See NeuStar Refresh Comments, Attach. at 5.  As discussed in greater 
detail below, we agree that the use of remote call forwarding may be an appropriate temporary workaround in 
those limited cases where numbers are not available to Internet-based TRS providers through a numbering partner.  
See infra para. 41.
78 See AT&T Refresh Comments at 2 (Because VRS users only need to use NANP numbers for inbound service 
(calls from hearing individuals), there is no need for the VRS user to purchase a local exchange access line to their 
premise which is more expensive. . . .  The resulting cost for the VRS user is significantly less than the $20 or more 
per number when purchased individually in conjunction with an access line from the LEC.); GoAmerica Refresh 
Comments at 18 (criticizing proposal to require Internet-based TRS users to obtain numbers through LECs).
79 See CSDVRS Refresh Comments at 6 (A single neutral party, rather than VRS providers, should have primary 
responsibility for assigning and distributing ten-digit local numbers directly to relay users.); TDI Coalition Refresh 
Comments at 4 (supporting both third-party administrator and TRS provider options); AG Bell Refresh Reply 
Comments at 1; AAPD Refresh Reply Comments at 3; Sonny Refresh Reply Comments at 2.
80 See infra para. 30.
81 See infra para. 33.
82 See AT&T Refresh Comments at 23 (abandoning proposal that Internet-based TRS users obtain numbers from 
LECs in favor of proposal that users obtain NANP numbers directly from Internet-based TRS providers, who can 
obtain numbers the same way VoIP providers obtain numbers and can make the numbers available to users at a 
much cheaper price); Dash Refresh Comments at 6 (We would suggest that relay providers will likely obtain 
(continued.)
Federal Communications Commission FCC 08-151
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process is functionally equivalent to the process by which subscribers to interconnected VoIP, CMRS, 
and local exchange service obtain numbers.83 Indeed, even proponents of the neutral third-party process 
note that some consumers view their Internet-based TRS provider as if it were a telephone company and 
therefore expect that they should obtain numbering resources directly from the Internet-based TRS
provider.84
b. Internet-based TRS Providers Acquisition of Numbering Resources
29. In light of our decision to have Internet-based TRS users obtain numbers directly from 
Internet-based TRS providers, we must determine how Internet-based TRS providers are to obtain access 
to numbering resources.  The record reflects three methods:  (1) directly from the NANPA or the PA,85
(2) from a neutral third-party administrator established for the purpose,86 or (3) from numbering partners 
through commercial agreements.87
30. Only carriers, absent a Commission waiver,88 may obtain numbering resources directly 
from the NANPA or the PA.  Section 52.15(g)(2) of the Commissions rules limits access to the NANP 
numbering resources to those applicants that are (1) authorized to provide service in the area for which 
the numbering resources are being requested and (2) [are] or will be capable of providing service within 
sixty (60) days of the numbering resources activation date.89  Allowing only carriers to have direct 
access to NANP numbering resources helps to ensure that the numbers are used efficiently and to avoid 
number exhaust and also provides some control over who may access numbering databases and 
personnel.90  Thus, to the extent that a provider of Internet-based TRS is licensed or certificated as a 
carrier under the Act and relevant state law (as appropriate), it may obtain numbering resources directly 
from the NANPA or PA.91
(Continued from previous page)    
numbers in a manner similar to smaller VoIP service providers, including through resellers and other avenues 
outside of direct assignment from an ILEC or even CLEC carriers.); GoAmerica Refresh Comments at 17 (The 
most efficient methodology would be for relay providers to make numbers available for consumers.); NeuStar 
Refresh Comments at 4 (proposing that Internet-based TRS providers obtain NANP numbers as VoIP providers do); 
Sorenson Refresh Comments at 19 (Providers will have to assign users with NANP numbers); TRS Advisory 
Council Refresh Comments at 1.
83 See GoAmerica Refresh Comments at 17 (Deaf and hard of hearing users should have the same functionally 
equivalent choice of obtaining their NANP numbers from the equivalent of voice telecommunications providers
relay service providers.); see also AT&T Refresh Comments at 23; Dash Refresh Comments at 6; NeuStar 
Refresh Comments at 4; NeuStar Refresh Reply Comments at 21 ([S]tandards compliant devices should be able to 
use [a method] to dial anyone just as a hearing person can.).
84 CSDVRS Refresh Reply Comments at 5 (Some consumers who use IP relay or VRS perceive their relay 
providers to be the equivalent of a telephone company that distributes telephone numbers to voice users.).
85 ATIS Report at 13, 19, paras. 4.1.1, 4.1.6, 5.1.1.
86 Id. at 13, 2021, paras. 4.1.3, 4.1.5, 5.1.3.
87 Id. at 13, 1920, paras. 4.1.2, 5.1.2.
88 See Administration of the North American Numbering Plan, CC Docket No. 99-200, Order, 20 FCC Rcd 2957, 
2959, 296162, paras. 4, 9 (Feb. 1, 2005) (SBCIS Waiver Order).  We reiterate the Commissions existing rule of 
general applicability regarding eligibility for direct access to numbering resources.  See VoIP LNP Order, 22 FCC 
Rcd at 19542, para. 20; Numbering Resource Optimization, CC Docket No. 99-200, Report and Order and Further 
Notice of Proposed Rulemaking, 15 FCC Rcd 7574, 7615, para. 97 (Mar. 31, 2000) (NRO First Report and Order) 
(stating that carriers must provide evidence demonstrating that they are licensed and/or certified to provide service 
prior to accessing numbering resources).  We note that petitions seeking waivers similar to the relief granted in the 
SBCIS Waiver Order are pending.  See, e.g., Wireline Competition Bureau Seeks Comment on Qwest 
(continued.)
Federal Communications Commission FCC 08-151
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31. We recognize, however, that many, if not all, providers of Internet-based TRS will not be 
licensed or certificated as carriers.  Internet-based TRS providers that have not obtained a license or 
certificate of public convenience and necessity from the relevant states or otherwise are not eligible to 
receive numbers directly from the NANPA or PA may make numbers available to their customers 
through commercial arrangements with carriers (i.e., numbering partners).  This method has proven 
successful in the context of interconnected VoIP,92 is consistent with our numbering rules,93 and is cost 
effective.94 TRS providers can easily obtain numbers from certified carriers the same way interconnected 
(Continued from previous page)    
Communications Corporation Petition for Limited Waiver of Section 52.15(g)(2)(i) of the Commissions Rules 
Regarding Access to Numbering Resources, CC Docket No. 99-200, Public Notice, 20 FCC Rcd 8765 (May 4, 
2005).  This Order does not in any way prejudge the outcome of the Commissions consideration of those petitions.
89 47 C.F.R.  52.15(g)(2).
90 NRO First Report and Order, 15 FCC Rcd at 7615, para. 97.
91 See 47 C.F.R.  52.15(g)(2)(i); see also VoIP LNP Order, 22 FCC Rcd at 19542, para. 20; NRO First Report and 
Order, 15 FCC Rcd at 7615, para. 97.
92 See, e.g., NeuStar Refresh Comments, Attach. at 4 (This model works well in the VoIP environment and would 
be the same mechanism for providing telephone numbers to relay providers.); see also NeuStar Refresh Comments 
at 4 (This is exactly the same manner through which most VoIP providers obtain and distribute telephone numbers 
today.); AT&T Refresh Comments at 2; Sorenson Refresh Comments at 67.  We disagree with the Nebraska PSC 
that assigning Internet-based TRS users numbers from a pool of numbers associated with an Internet-based TRS 
provider could be potentially discriminatory as the only individuals receiving such numbers would be part of the 
deaf and hard-of-hearing community.  Nebraska PSC Refresh Comments at 4.  Internet-based TRS service providers 
will not draw numbers from a pool dedicated to Internet-based TRS, but instead will obtain geographically 
appropriate numbers from numbering partners that are indistinguishable from numbers provided to subscribers of 
interconnected VoIP service or traditional local exchange service.  The general availability of numbers to Internet-
based TRS providers through numbering partners likewise addresses the concern that Internet-based TRS users will 
be limited to those providers with numbering resources in the rate center where they reside.  Id. To the extent a 
geographically appropriate number is not available to Internet-based TRS providers, one of the workarounds
discussed in paragraph 41 may be utilized until numbers become available, through numbering partners or number 
portability.  Finally, we disagree with the Nebraska PSC that allowing Internet-based TRS providers to distribute 
numbers obtained from numbering partners will contribute to numbering exhaust.  Internet-based TRS providers, 
which generally are not certificated as carriers, will have neither the ability nor the incentive to obtain numbers in 
thousand blocks for each rate center in which they have a Registered Internet-based TRS User.  Rather, those 
providers will be able to obtain as many or as few numbers as they need for each rate center from their numbering 
partners.  See NeuStar Refresh Comments, Attach. at 45; GoAmerica Refresh Comments at 21 ([R]elay providers 
will only have to obtain what [numbers] they need, or in worse case carry a minimal inventory far below the current 
minimum allocation obtained through NANPA (of 1,000 blocks or larger).).
93 Our rules require that only carriers that are licensed or certified as carriers under the Act may receive numbering 
resources.  47 C.F.R.  52.15(g)(2)(i) (applicants for numbering resources must be authorized to provide service in 
the area for which numbering resources are being requested).
94 See AT&T Refresh Reply Comments at 2 (VRS providers can easily obtain [NANP] numbers from voice service 
providers . . . and then provide such numbers to relay users at a low price (generally $1 or less per line per 
month).); NeuStar Refresh Comments at 13 (noting that the rate for assigning a number from a carrier to an 
Internet-based TRS provider is from $0.75 to $0.95 per transaction).  We disagree with CSDVRSs argument that 
allowing Internet-based TRS providers to obtain and distribute NANP numbers link[s] numbers and equipment
and is plainly anti-competitive. CSDVRS Refresh Reply Comments at 13.  First, CSDVRS complains that a 
consumer who obtains a number from one VRS provider is more than likely to use that same provider to make 
outgoing calls.  Id. at 13 n.12.  But even CSDVRS admits that under our interoperability rules that very consumer is 
free . . . to make outgoing calls on any providers network.  Id. Second, its complaint that VRS providers who can 
obtain and distribute numbers will enjoy a substantial competitive advantage, id. at 14, is largely mooted by our 
(continued.)
Federal Communications Commission FCC 08-151
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VoIP providers obtain numbers today.
32. In any case, Internet-based TRS providers and their numbering partners shall be entitled 
to obtain and use numbering resources only to the extent they comply with the requirements of this 
Order.  We also remind all parties that telephone numbers are a public resource, not private property.95  
They may not be bought or sold.96 They may, however, be provided as part of a package of services that 
includes, for example, interconnection, connectivity, or 911 service.
33. In light of record support for, and the demonstrated success of interconnected VoIP 
providers in, obtaining NANP telephone numbers from carriers, we decline to appoint a neutral third
party to obtain numbers from the NANPA or from numbering partners for distribution to providers of 
Internet-based TRS or Internet-based TRS users.97 Allowing a third-party administrator direct access to 
numbering resources is not consistent with general Commission policy  as discussed above, absent a 
waiver, our rules allow only carriers direct access to NANP numbering resources.98 Further, the record 
reflects that a third-party administrator would add another layer of personnel, process, and cost in the 
number procurement process.99
c. Local Number Portability
34. The record is clear that the ability to port numbers (1) from one Internet-based TRS
provider to another, and (2) between Internet-based TRS providers and other entities subject to LNP (such 
as carriers and interconnected VoIP providers) is a priority in any numbering plan for Internet-based 
TRS.100 Accordingly, we find that Internet-based TRS providers and their numbering partners are subject 
(Continued from previous page)    
extension of local number portability to numbers obtained from VRS providers.  See infra paras. 3436; CSDVRS 
Refresh Reply Comments at 14 n.14 (admitting that users will always be able to port their numbers to [other] 
providers); see also NeuStar Refresh Reply Comments at 1314 (explaining that [s]tandards based equipment
can smooth an Internet-based TRS users transition from one provider to another).
95 See Toll Free Service Access Codes, CC Docket No. 95-155, Fourth Report and Order and Memorandum Opinion 
and Order, 13 FCC Rcd 9058, 9061, para. 6 n.14 (Mar. 31, 1998); Toll Free Service Access Codes, CC Docket No. 
95-155, Notice of Proposed Rulemaking, 10 FCC Rcd 13692, 13702, para. 36 (Oct. 5, 1995) (Toll Free Access 
Notice); Administration of the North American Numbering Plan, CC Docket No. 92-237, Report and Order, 11 FCC 
Rcd 2588, 2591, para. 4 (July 13, 1995) (These numbers are a public resource, and are not the property of the 
carriers.); see also, e.g., In re StarNet, Inc., 355 F.3d 634, 637 (7th Cir. 2004).
96 Cf. Toll Free Access Notice, 10 FCC Rcd at 13697, para. 16 n.41 (800 Numbers are not to be treated as 
commodities which can be bought or sold, and no individual or entity is granted a proprietary interest in any 800 
number assigned.).
97 See CSDVRS Refresh Comments at 13 (The ONS will acquire [NANP telephone] number blocks from 
wholesale carriers . . . and the major local exchange carriers . . . .).
98 See supra para. 30.
99 ATIS Report at 22; see also GoAmerica Refresh Comments at 1718 ([T]he third party issuer would have less 
incentive than relay providers to efficiently distribute numbers and thus should not be the only option available to 
obtain numbers. . . . [C]reating a third party to manage network connectivity between the PSTN and the various 
providers would create a potential single point of failure in the networks that could disrupt all calls from hearing to 
deaf users in the event of a problem.); NeuStar Refresh Reply Comments at 7 (noting that a third-party system is 
inefficient because it would force[] Relay Providers to query the [central] database for every call rather than just a 
subset of calls).
100 See, e.g., Dash Refresh Comments at 5 (Full number portability is required by the concept of functional 
equivalency as set forth in Section 225 of the Communications Act of 1934, as amended.); NeuStar Refresh 
Comments, Attach. at 5; GoAmerica Refresh Comments at 1516; TRS Advisory Counsel Refresh Comments at 2; 
Sorenson Refresh Comments at 18; TDI Coalition Refresh Comments at 5; AAPD Refresh Reply Comments at 2; 
(continued.)
Federal Communications Commission FCC 08-151
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to the same porting obligations, with the sole exception of contributing to meet shared numbering 
administration costs and LNP costs, as the Commission set forth in the VoIP LNP Order.101
35. As discussed above, the plenary numbering authority that Congress granted this 
Commission under section 251(e)(1) provides ample authority to extend the LNP requirements to 
Internet-based TRS providers and their numbering partners.102  In addition, we believe we have a separate 
additional source of authority under Title I of the Act to impose LNP obligations on Internet-based TRS 
providers.103  Therefore, by this Order, we expand the scope of our LNP rules to include Internet-based 
TRS providers, so that the full array of obligations relating to the porting of numbers from one service 
provider to another service provider are applicable when an Internet-based TRS user wishes to port a 
number, regardless of whether the service providers involved are carriers, interconnected VoIP providers, 
or Internet-based TRS providers.  However, for the sake of clarity, we note that as applied to an Internet-
based TRS provider, the rules adopted in the VoIP LNP Order require that an Internet-based TRS
provider and its numbering partner must facilitate a users port request to or from another Internet-based 
TRS provider.  This means the Internet-based TRS provider has an affirmative legal obligation to take all 
steps necessary to initiate or allow a port-in or port-out itself or through its numbering partner on behalf 
of the Internet-based TRS user, subject to a valid port request, without unreasonable delay or 
unreasonable procedures that have the effect of delaying or denying porting of the number.  Moreover 
Internet-based TRS providers and their numbering partners may not enter into agreements that would 
prohibit or unreasonably delay an Internet-based TRS user from porting between Internet-based TRS
providers and will be subject to Commission enforcement action for any such violation of the Act and the 
Commissions LNP rules.104
36. To the extent that an Internet-based TRS provider is licensed or certificated as a carrier, 
that carrier is eligible to obtain numbering resources directly from the NANPA, subject to all relevant
rules and procedures applicable to carriers, including LNP requirements.  Under these circumstances, the 
Internet-based TRS provider would not have a numbering partner, and would thus be solely responsible 
for compliance with the Commission rules at issue here.105
37. Numbering Administration Costs.  Section 251(e)(2) provides that [t]he cost of 
establishing telecommunications numbering administration arrangements and number portability shall be 
borne by all telecommunications carriers on a competitively neutral basis as determined by the 
Commission.106 Carriers and interconnected VoIP providers that benefit from LNP generally are 
(Continued from previous page)    
see also GoAmerica Refresh Reply Comments at 3 ([A]ll commenters agree that numbers assigned under the 
Internet-based numbering solution must be portable so that consumers may freely choose their Internet-based TRS 
default providers.).
101 See VoIP LNP Order, 22 FCC Rcd at 1954851, paras. 3037.  This order, which became effective shortly 
before the Nebraska PSC filed its comments, addresses the Nebraska PSCs concerns regarding the number of LNP 
complaints resulting from the indirect assignment of numbers to interconnected VoIP providers and, now, Internet-
based TRS providers.  See 73 FR 9463 (Feb. 21, 2008) (announcing effective date of March 24, 2008).
102 See supra paras. 1819.
103 See supra note 64.
104 See, e.g., Wireless Number Portability Order, 18 FCC Rcd at 20975, para. 11 (interpreting the Acts number 
portability definition to mean that customers must be able to change carriers while keeping their telephone number 
as easily as they may change carriers without taking their telephone number with them).
105 See VoIP LNP Order, 22 FCC Rcd at 19542, para. 20 n.62.
106 47 U.S.C.  251(e)(2).
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required to contribute to meet shared LNP costs.107
38. We decline to extend to Internet-based TRS providers the obligation to contribute to meet 
shared LNP costs at this time.  Unlike other providers that benefit from LNP, providers of Internet-based 
TRS are not permitted to recover their costs from their end users.  Rather, Internet-based TRS providers 
are compensated by the Interstate TRS Fund for the costs of providing relay service.  Money in the 
Interstate TRS Fund is collected from various providers of telecommunications and related services 
many of which already contribute to meet shared LNP costs.108 It makes little sense to require Internet-
based TRS providers to contribute to defray shared LNP costs covered by the same providers that 
ultimately provide the money Internet-based TRS providers will use to make such contributions.
39. Implementation. Since the ultimate responsibility for numbers obtained from the 
numbering administrator is unchanged by this Order, there is no need to detail a separate implementation 
schedule for porting to or from a provider of Internet-based TRS.  Thus, consistent with the 
implementation schedule set forth below, Internet-based TRS LNP must be fully implemented no later 
than December 31, 2008.109
40. Enforcement. If any service provider experiences problems with another service provider 
when attempting to port a consumers number, or if a consumer experiences problems with porting, we 
expect the provider or consumer to file a complaint with the Commission.110 We take very seriously our 
obligation to effectuate number portability and our oversight of numbering resources.  The Commission 
will act expeditiously to ensure that consumers have the option to switch providers, subject to our LNP 
rules, without the loss of their telephone numbers or service.
d. Geographically Appropriate Numbers
41. Voice telephone users that subscribe to local exchange service are provided with a
geographically appropriate telephone number by virtue of the architecture of the PSTN.  In the vast 
majority of cases, subscribers to interconnected VoIP services likewise have the ability to obtain a 
geographically appropriate NANP telephone number.111 In the interest of functional equivalency, and 
consistent with the recommendations of the ATIS Report, we find that Internet-based TRS users should 
be assigned geographically appropriate NANP numbers, as happens today for hearing users.  We note that 
there may be unusual and limited circumstances in which an Internet-based TRS provider may not be able 
to obtain a geographically appropriate number for a particular end user.112  While we do not expect this to 
be a common occurrence, Internet-based TRS providers may temporarily employ suitable workarounds in 
  
107 See VoIP LNP Order, 22 FCC Rcd at 1955152, paras. 3839.
108 See generally Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing 
and Speech Disabilities, CG Docket No. 03-123, Report and Order and Declaratory Ruling, 22 FCC Rcd 20140 
(Nov. 19, 2007) (2007 TRS Rate Methodology Order); Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order, 22 FCC Rcd 11706, 
1170608, paras. 14 (CGB June 29, 2007) (2007 Bureau TRS Rate Order).
109 See infra Section III.G.
110 47 U.S.C.  208 (authorizing complaints against common carriers); 47 C.F.R.  1.1 (authorizing interested parties 
to petition the Commission to open, among other things, an enforcement proceeding).
111 See GoAmerica Refresh Reply Comments at 4 (In most locations throughout the U.S., TRS providers will have 
no problem obtaining local telephone number[s] for use by their users.); Sorenson Refresh Comments at 7 (noting 
that the VoIP approach to numbering acquisition . . . has proven successful).
112 NeuStar Refresh Comments, Attach. at 5 ([W]holesale carriers do not serve every rate center and therefore will 
not have truly local numbers available for every location.).
Federal Communications Commission FCC 08-151
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such circumstances, such as the assignment of a number which is reasonably close to the Internet-based 
TRS users rate center, or the use of remote call forwarding.113 Such workarounds may be employed only 
until a geographically appropriate number becomes available, unless the end user chooses to retain the 
originally assigned number.114
e. Default Provider Registration 
42. Every provider of Internet-based TRS is required to provide Internet-based TRS users 
with the capability to register with that Internet-based TRS provider as a default provider and provide 
or port for that user a NANP telephone number.115 Such registration is required: (1) to allow the Internet-
based TRS provider to take steps to associate the Internet-based TRS users telephone number with their 
IP address to allow for the routing and completion of calls;116 (2) to facilitate the provision of 911 
service;117 and (3) to facilitate the implementation of appropriate network security measures.118
43. The Internet-based TRS provider with which an Internet-based TRS user has registered 
will serve as the Internet-based TRS users default provider.119 For all Internet-based TRS users, all 
inbound and outbound calls will, by default, be routed through the default provider.  Such a default 
provider arrangement is functionally equivalent to services provided on the PSTN and via interconnected 
VoIP.  For example, voice telephone users that subscribe to a particular carrier for long distance service 
will make all of their long distance calls on that carriers network unless they choose to dial around to 
an alternative long distance provider.  Likewise, and in keeping with the Interoperability Declaratory 
Ruling and FNPRM, calls made to and from an Internet-based TRS user will be handled by the default 
provider, unless the calling Internet-based TRS user specifically dials around in order to utilize an 
alternative provider.120 Individuals calling an Internet-based TRS user likewise will have the option of 
dialing around an Internet-based TRS users default provider in order to utilize the services of a 
  
113 Id. We find such workarounds to be a more flexible solution than, and thus preferable to, mandating that any 
telephone provider of last resort be required to provide numbers to Internet-based TRS providers.  See GoAmerica 
Refresh Reply Comments at 4.
114 Because the use of remote call forwarding may inhibit some functionally equivalent services such as Caller ID, 
NeuStar Refresh Comments, Attach. at 5, we emphasize that such a workaround must be only a temporary solution 
until the Internet-based TRS provider can obtain a geographically appropriate number for the Internet-based TRS 
user by ordinary means.
115 The deaf and hard-of-hearing community generally agrees that registration for these purposes is appropriate.  
See, e.g., TDI Coalition Refresh Comments at 56.
116 See infra Section III.B.2.a.
117 See infra paras. 8081; see also Interim Emergency Call Handling Order, 23 FCC Rcd at 5269, para. 23 (We 
believe that user registration is critical to achieving the goal of providing location identification to first responders in 
the context of emergency calls placed over Internet-based TRS).
118 For example, with registration Internet-based TRS providers can limit access to their databases to only 
Registered Internet-based TRS Users and other Internet-based TRS providers, reducing the exposure of a providers 
databases to slamming, hacking, or other abuses.  See NeuStar Refresh Comments, Attach. at 9; see also infra
Section III.E.
119 For the purposes of this Order, an Internet-based TRS providers Registered Internet-based TRS Users are 
those users that have registered with that particular provider as their default provider.
120 Although VRS and IP Relay providers will be the default providers for Internet-based TRS users under this 
Order, nothing in this Order detracts from a TRS providers interoperability obligations.  See generally
Interoperability Declaratory Ruling and FNPRM, 21 FCC Rcd 5442.
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different TRS provider.  Consistent with the LNP discussion above, an Internet-based TRS user may 
select and register with a new default provider at any time and have his or her number ported to that 
provider.
44. As of December 31, 2008, Internet-based TRS providers must, prior to the initiation of 
service for an individual that has not previously utilized Internet-based TRS, register that new Internet-
based TRS user, provide that user with a ten-digit NANP telephone number, obtain that users Registered 
Location, and fulfill all other requirements set forth in this Order that pertain to Registered Internet-based 
TRS Users.  We find that allowing Internet-based TRS users to opt-in to or, for that matter, opt-out of 
registration, which is required for the provision of E911 service, is fundamentally inconsistent with our 
obligation to encourage and support efforts by States to deploy comprehensive end-to-end emergency 
communications infrastructure and programs.121
45. Our numbering plan must be implemented such that ten-digit numbers are available to 
Internet-based TRS users no later than December 31, 2008.122  We recognize, however, that every existing 
Internet-based TRS user will not be able to register with a default provider on that day.  We therefore 
recognize that we must adopt a registration period for the existing base of Internet-based TRS users to 
migrate to the new numbering plan.  In the Further Notice, we seek comment on the registration period
timeframe.123
2. Centralized Numbering Directory Mechanism
46. The record demonstrates consensus that a centralized numbering directory mechanism be 
employed to support calls between Internet-based TRS users using different providers of Internet-based 
TRS and between Internet-based TRS users and callers using the PSTN.124 Specifically, consensus exists 
that there is need for a central database mechanism that maps the NANP telephone numbers assigned to 
Internet-based TRS users to an appropriate Internet address.125  Commenters agree that this centralized 
numbering directory mechanism should be administered by a neutral third party.126
  
121 Wireless Communications and Public Safety Act of 1999, Pub. L. No. 106-81, 113 Stat. 1286,  3(b) (1999); see 
also VoIP 911 Order, 20 FCC Rcd at 1027172, para. 47.
122 See supra para. 1.
123 See infra Section IV.2.
124 See, e.g., CSDVRS Refresh Comments at 2 (CSD and CSDVRS enthusiastically support the establishment of a 
global, uniform ten-digit telephone numbering system for all Internet-based video and text relay users.); Dash 
Refresh Comments at 4 (There appears to be no dispute within the relay industry that a central numbering database 
is a base requirement for a 10-digit NANP numbering plan.); Nebraska PSC Refresh Comments at 6 (fully 
supporting a centralized database managed by a third party); TDI Coalition Refresh Comments at 2 (stating that 
[e]stablishing a numbering system linked to the NANP for IP-based relay services is a critical component in 
achieving functional equivalency); AT&T Refresh Comments at 1; AG Bell Refresh Reply Comments at 1 
(supporting the establishment of a single and open numbering directory); AAPD Refresh Reply Comments at 2; 
Sonny Refresh Reply Comments at 1.  We note that the record contains a number of different possible labels or 
descriptions of the centralized numbering directory mechanism.  See, e.g., ATIS Report at 8, para. 3.3 (Central 
Routing Database); CSDVRS Refresh Comments at 89 (TN database or TN information database); Dash 
Refresh Comments at 4 (Central Numbering Database); NeuStar Refresh Comments, Attach. at 6 (central 
database).
125 See, e.g., ATIS Report at 9, para. 3.3.4; Dash Refresh Comments at 3 (supporting using NANP numbers to obtain 
users IP addresses); AT&T Refresh Comments at 1; Sprint Nextel Refresh Comments at 4.
126 See, e.g., Sprint Refresh Comments at 5 (There is no dispute that a central database managed by a neutral third 
party must be deployed to support interoperability by ensuring that calls are correctly routed to the Relay provider 
(continued.)
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47. The efforts of the end-user community, industry, and the Commission, have not, 
however, been sufficient to reach consensus on how such a centralized numbering directory mechanism 
should be implemented.  Indeed, the record currently reflects three proposals (Industry Proposals) for 
implementing a centralized numbering directory mechanism:  NeuStars Telephone Numbers for Relay 
Users (TRU); AT&T, GoAmerica, Hands On, and Dashs (Joint Proposal) Open Relay Database (ORD); 
and CSDVRSs One Number System (ONS).127
48. The core of each of the Industry Proposals is quite similar.  Each proposes to establish a 
database into which routing information is provisioned,128 and to make that routing information available 
via a query system built on industry-standard domain naming system (DNS) and/or telephone number 
mapping (ENUM) technology.129 The differences amongst the Industry Proposals, at the highest level, 
can be narrowed to three critical, but severable, issues: (1) the nature of the information contained in the 
central database; (2) the means by which the central database is provisioned with that information; and 
(3) the choice of who will be authorized to access the central database.130  Further, the Industry Proposals 
are not all or nothing, but consist of severable design components.131
(Continued from previous page)    
chosen by the user of an Internet-based Relay service.); GoAmerica Refresh Comments at 12 (supporting the use of 
a neutral third-party database administrator); CSDVRS Refresh Comments at 9; NeuStar Refresh Comments at 15; 
Sorenson Refresh Comments at 17; TDI Coalition Refresh Comments at 3.
127 See NeuStar Refresh Comments, Attach.; Letter from Richard L. Fruchterman, III, Public Policy and Regulatory 
Counsel, NeuStar, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. (filed May 9, 2008); 
AT&T Refresh Comments at 13; Dash Refresh Comments at 79; GoAmerica Refresh Comments at 2125; Letter 
from Toni R. Acton, Director, AT&T, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. (filed 
Apr. 17, 2008) (AT&T Ex Parte); CSDVRS Refresh Comments at 1032.
128 See Letter from Richard L. Fruchterman, III, Public Policy and Regulatory Counsel, NeuStar, to Marlene H. 
Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. (filed May 20, 2008) (discussing how NPAC database fits 
into NeuStars TRU plan) (NeuStar TRU Supplement); Letter from Kelby Brick, Vice President of Legal and 
Strategic Policy, GoAmerica, Inc., to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. (filed 
May 21, 2008) (GoAmerica ORD Supplement) (discussing ORD database); Letter from George L. Lyon, Jr., 
Counsel, GoAmerica, Inc., to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. (filed May 28, 
2008) (GoAmerica ORD Responsive Supplement) (comparing the three databases); Letter from Karen Peltz Strauss, 
Legal Consultant, CSDVRS, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. at 5 (filed May 
5, 2008) (CSDVRS Workshop Deck) (discussing ONS database).  The NPAC is the local number portability 
database of record in the United States and Canada and is administered by NeuStar.  Today it associates ported and 
pooled NANP telephone numbers with PSTN routing and other information.
129 See NeuStar TRU Supplement at 2; GoAmerica ORD Supplement at 31, 38; GoAmerica ORD Responsive 
Supplement at 12; CSDVRS Workshop Deck at 6; see also NeuStar Refresh Reply Comments at 7 n.20 (All three 
proposals contemplate that DNS in general, and ENUM in specific, will be used to query the database).  As 
described in the ATIS report, DNS is the industry standard name for the Internet resource translation mechanism.  
Various capabilities built on DNS, e.g., delegation, Telephone Number Mapping (ENUM), and Dynamic DNS 
(DDNS), provide a range of methods to support relay interoperability.  DDNS is an existing DNS capability used to 
link domain names to IP addresses when those addresses are dynamically rather than statically assigned.  See ATIS 
Report at 17, para. 4.2.2.1.
130 One additional, and unique, aspect of the CSDVRS ONS plan is its proposal to have a neutral third party 
establish a full ONS VoIP Network to support the termination of . . . calls at the designated relay provider.  See
CSDVRS Refresh Comments at 14.
131 See Letter from Toni R. Acton, Director, AT&T Services Inc., to Marlene H. Dortch, Secretary, FCC, CG Docket 
No. 03-123, Attach. at 13 (filed May 5, 2008) (AT&T Workshop Deck); Letter from Richard L. Fruchterman, III, 
Public Policy and Regulatory Counsel, NeuStar, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, 
Attach. at 4 (filed May 9, 2008) (NeuStar Workshop Deck); Letter from Michael B. Fingerhut, Director of 
(continued.)
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49. As discussed in greater detail below, there are benefits and drawbacks to each of the 
Industry Proposals. We find that no single Industry Proposal represents the best implementation of a 
centralized numbering directory mechanism, but instead find that a combination of different elements of 
the Industry Proposals will best serve the interests of Internet-based TRS users, Internet-based TRS 
providers, and the general public.  Specifically, and as discussed in greater detail below, we find that the 
best centralized numbering directory mechanism shall: (1) be provisioned with Uniform Resource 
Identifiers (URIs) that contain, inter alia, end-user IP addresses for VRS and domain names and user 
names for IP Relay; (2) be provisioned by Internet-based TRS providers on behalf of their Registered 
Internet-based TRS Users; and (3) limit central database access to Internet-based TRS providers.  We 
further find that industry-standard DNS and ENUM technology is well-suited for implementing and 
querying the database.
a. Information to be Provisioned to the Central Database
50. The primary purpose of the central database will be to map each Internet-based TRS 
users NANP telephone number to his or her end device.  This can be accomplished by: (1) provisioning 
the database with each Internet-based TRS users IP address (either alone or as part of a URI);132 or 
(2) provisioning the database with URIs that contain domain names and user names  such as an instant-
message service and screen-name  that can be subsequently resolved to reach the users end device.133
51. As an initial matter, we note that the central database must contain domain names and 
user names for IP Relay.134  Domain names and user names are required for this form of Internet-based 
TRS in light of the wide array of IP-based text communication applications, services, and user identifiers 
that can be used for the leg of an IP Relay call between the Internet-based TRS user and a CA.135  We 
further note that for a VRS user the central database must contain information other than a users IP 
address (e.g., a device-specific protocol identifier and, in some instances, a non-standard port number) 
(Continued from previous page)    
Governmental Affairs, Sprint, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, Attach. at 1 (filed 
May 19, 2008) (calling the numbering and database management issues separable design decisions).
132 At its simplest, a URI specifies both how (the protocol) and where (the address) to access a resource on the 
Internet.  Thus a URI that contains an IP address might take the form H323:128.000.000.001, in which H323 
specifies the protocol to be used and 128.000.000.001 specifies the resources address.  URIs that contain domain 
names and user names might similarly take the forms H323:2025551212@siprelay.com or 
IM:IMUser@aol.com.  The Joint Proposal and NeuStars TRU contemplate that ENUM will be utilized to query 
the central database, and ENUM returns URIs in the form of Naming Authority Pointers (NAPTR). See NeuStar 
Refresh Reply Comments at 7 n.20.  To the extent that URIs provisioned to the central database must contain 
information other than IP addresses or domain names and user names (e.g., a protocol identifier, port number, etc.)
in order to allow a call to be completed as discussed in this Order, we require that such information also be 
contained in URIs provisioned to the central database.
133 Domain names and user names have the advantage of being relatively static (i.e., they do not need to be updated 
frequently), although additional DNS queries are required to resolve a domain name and user name to an IP address.  
IP addresses do not require additional DNS queries to complete routing, but they can be dynamic, changing 
frequently.  We note that a single database can accommodate both URIs that contain IP addresses and other URIs 
that contain domain names and user names.
134 ATIS Report at 16, 17, paras. 4.2.1.2, 4.2.2.2; Sorenson Refresh Comments at 89; NeuStar Workshop Deck at 
6.
135 See Sorenson Refresh Comments at 89 (Because IP Relay addresses are often associated with a screen name, 
or some identifier other than an IP address . . . association of a number with an IP address will not work for IP 
Relay. . . . IP addresses . . . do not provide information about the protocols or systems employed by the end-users 
device; and they do not work for users with multiple devices served by a single IP address.).
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and that this information can be included in a URI.136  We therefore decline to adopt the ONS 
recommendation that the central database be provisioned only with IP addresses,137 and instead require 
that URIs be provisioned to the central database.
52. With respect to VRS, URIs containing domain names and user names or URIs containing 
IP addresses can be provisioned to the central database and used by a querying party to properly route a 
call to a VRS user.138  The choice of what information is contained in URIs provisioned to the central 
database will determine the signaling path required to establish the call.139 In particular, the choice will 
directly impact how signaling is effectuated for calls between VRS users that have selected different 
default providers.140
53. Based on the record before us, we find that the central database should be provisioned 
with URIs containing IP addresses for VRS users.  Provisioning URIs containing IP addresses to the 
central database will result in a simplified, and more efficient, call setup process by eliminating the need 
to query an Internet-based TRS users default provider before completing every call.141  Further, the use 
of a domain name in the URI normally would create a dependency on the global Domain Name System 
and thereby introduce those additional security vulnerability issues associated with the global DNS.  
Finally, eliminating the terminating partys default provider from the call flow also improves Internet-
based TRS user privacy by limiting the number of Internet-based TRS providers that have access to call 
signaling data,142 and limits any ability the terminating partys default provider might have to block or 
otherwise degrade calls initiated through a competitor.143
54. Registered Location information.  CSDVRSs ONS plan contemplates that the central 
database serve as a repository of Registered Location information used to deliver E911 service.144  As 
discussed below in Section III.C, we decline to require that Internet-based TRS providers utilize a single 
provider of 911 related services. We likewise decline to require that Registered Location information be 
stored in the central database.145 There is nothing in the record to indicate that providers of 911 service 
  
136 See supra note 132.
137 See CSDVRS Refresh Comments at 2122; CSDVRS Workshop Deck at 3.
138 See ATIS Report at 1517, paras. 4.2.1.1, 4.2.2.1.
139 See generally ATIS Report, Appendix 1.
140 Compare, e.g., Sorenson Refresh Comments at 1011 & Attach. 2 at 3 (explaining that, if the databases URIs
contain domain names and user names and two Internet-based TRS users have different service providers, a call 
would need to be routed from the calling user, to one service provider, to the database, back to the first service 
provider, then to the other service provider and to the receiving user), with ATIS Report at 17, para. 4.2.2.1 
(explaining that, if the databases URIs contain IP addresses, callers could avoid the step of querying the receiving 
users service provider). Similar call routing occurs when a PSTN user calls an Internet-based TRS user and 
chooses not to utilize the terminating partys default provider.  See NeuStar TRU Supplement at 1, 3; Sorenson 
Refresh Comments at 1011 & Attach. 2 at 3; AT&T Workshop Deck at 4.
141 See, e.g., AT&T Workshop Deck at 4; ATIS Report, Appendix 1; Sprint Refresh Comments at 6; see also supra
note 140.
142 Cf. CSDVRS Refresh Comments at 1819.
143 See AT&T Refresh Reply Comments at 5.
144 See infra paras. 8081 (discussing Registered Location requirement).
145 We anticipate that, consistent with the practice of interconnected VoIP service providers, Registered Location 
data will be maintained by Internet-based TRS providers and/or their 911 service provider partners.  See infra paras. 
8081.
Federal Communications Commission FCC 08-151
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utilize a uniform format for storing registered location information, and requiring that Registered 
Location information be stored in the central database potentially could interfere with Internet-based TRS 
providers ability to leverage existing 911 technologies.  Further, the record does not indicate a pressing 
need for Internet-based TRS providers to have access to the Registered Location information of Internet-
based TRS users other than their Registered Internet-based TRS Users.146
b. Means for Provisioning the Central Database
55. The Industry Proposals set forth three alternatives for populating and updating the central 
database.  Under CSDVRSs ONS, Internet-based TRS users would directly provision information to the 
central database.  Specifically, CSDVRSs ONS would require installation, at the user location, of a One 
Number Service Module (ONSM), which would periodically update the central database with the 
Internet-based TRS users IP address.147 We reject the CSDVRS ONS proposal.  Such an approach poses 
significant security risks that are not present under other provisioning systems, as discussed below.  In 
addition, we have significant questions about the feasibility and cost of ensuring that every Internet-based 
TRS user has installed new software or hardware on their TRS customer premises equipment (CPE) or 
home networks prior to December 31, 2008.148
56. Both NeuStars TRU and the Joint Proposal would require Internet-based TRS providers 
to provision routing information to the central database.  NeuStars TRU proposes that the necessary 
routing information be provisioned to a new field created in the NPAC, which generally would require 
Internet-based TRS providers to provision information into the NPAC through their numbering 
partners.149 The Joint Proposals ORD, by contrast would have Internet-based TRS providers provision 
Internet-based TRS user routing information directly to the central database.150
57. NeuStars TRU and the Joint Proposals ORD share certain benefits as compared to 
CSDVRSs ONS.151 Neither NeuStars TRU nor the Joint Proposals ORD require modifications to end 
user equipment or networks.  Both proposals also reduce central database security risks by limiting access 
to a limited set of registered entities.152 We further find, however, that the benefits of utilizing a 
provisioning method like that discussed in the Joint Proposals ORD outweigh those of using the NPAC.
58. First, we note that NeuStar argues that its TRU proposal is best suited to ensuring the 
  
146 See infra para. 86.
147 CSDVRS Refresh Comments at 2124.  CSDVRS states that the ONSM would consist of a software application 
on a PC connected to the same LAN as the videophone or a piece of hardware installed on the Internet-based TRS 
users home network. Id. at 22.
148 See, e.g., AT&T Refresh Comments at 3 ([S]ome existing customer equipment does not have the capability to 
automatically update the national database).
149 ATIS Report at 16, para. 4.2.1.1; NeuStar Workshop Deck at 10.  Only carriers, or entities operating under a 
letter of agency from a carrier, are permitted to update the NPAC.  NeuStar Workshop Deck at 19.
150 GoAmerica Refresh Comments at 15; AT&T Refresh Comments at 3 ([T]he most feasible way to update the 
national database is to require VRS providers to do so upon receipt of updated IP addresses from their customers).
151 See Letter from Walter Magnussen, President, ACUTA:  The Association of Communication Technology 
Professionals in Higher Education, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 03-123, at 2 (May 28, 
2008) (ACUTA Ex Parte) ([O]f the three proposals offered, the AT&T and Neustar proposals were more open to 
use with various types of telecommunications systems that would be in use on college campuses . . . .).
152 Only carriers can access the NPAC, see NeuStar Refresh Comments, Appendix A at 9; only Internet-based TRS 
providers could access the Joint Proposals database, see AT&T Ex Parte.
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Commissions December 31, 2008 deadline is met.153  NeuStar argues that the processes and procedures 
necessary to provision information to and obtain information from the NPAC are well established.154 As 
discussed in greater detail below, however, we believe it is possible to build a new central numbering 
database as set out in the Joint Proposals ORD with appropriate governance structures prior to the 
Commissions deadline.155
59. In the absence of compelling evidence that NeuStars TRU approach is more likely to be 
implemented by our deadline, there is little reason to adopt a solution that causes Internet-based TRS 
providers to be anything other than directly responsible for provisioning routing information to the central 
database.  We do not believe that requiring the insertion of a third party  such as a carrier that is an 
authorized NPAC user  into the process of provisioning and obtaining information from the central 
database is beneficial to the efficient operation of Internet-based TRS.  Further, the record reflects 
concerns that carriers may not have the incentive to make changes necessary to fully automate the process 
of provisioning routing information for Internet-based TRS providers to the central database.156 Finally, 
NeuStars TRU proposal appears to have less flexibility with respect to modifications and updates that 
may be necessary in the future.  Any additional changes to the NPAC would require the approval of the 
North American Portability Management (NAPM) LLC and a North American Numbering Council 
(NANC) working group.157 These entities, which consist primarily of carriers, will not be possessed of 
the same incentives as Internet-based TRS providers when considering ways to optimize the provision of 
information to the central database.  Thus, the Joint Proposals ORD provides an easier and more flexible 
path to modifying the information in the central database.
60. Obligations of Default Providers and Former Default Providers.  This approach imposes 
certain obligations on default providers.  Default providers must obtain current routing information, 
including URIs containing IP addresses or domain names and user names, from their Registered Internet-
based TRS Users, provision such information to the central database, and maintain it in their internal 
databases and in the central database.158 An Internet-based TRS users CPE should directly provide 
necessary routing information to the Internet-based TRS users default provider.  All CPE issued, leased, 
or otherwise provided to Internet-based TRS users by Internet-based TRS providers must be capable of 
facilitating the fulfillment of these requirements.
61. Conversely, Internet-based TRS providers (and, to the extent necessary, their numbering 
partners) must take such steps as are necessary to cease acquiring routing information from any Internet-
based TRS user that ports his or her number to another provider or otherwise selects a new default 
provider.  Specifically, every Internet-based TRS provider must ensure that all CPE they have issued, 
leased, or otherwise provided to Internet-based TRS users delivers routing information or other 
information only to the users default provider, except as is necessary to complete or receive dial 
around calls on a case-by-case basis.
  
153 NeuStar Refresh Comments at 4.
154 NeuStar states that modifications to the NPAC can be completed in two weeks, with necessary upgrades to 
provider systems and processes requiring three to four months.  NeuStar Workshop Deck at 21.
155 See infra paras. 6970.
156 See GoAmerica ORD Supplement at 14 (asserting that carrier updates to SOA will take significant time, if they 
are made at all); GoAmerica ORD Responsive Supplement at 10 (raising concerns that NeuStars approach would 
require a new cycle of LNPA/NPAM LLC work and interface development by all parties to add new URIs).
157 See AT&T Refresh Reply Comments, Attach. 1.
158 See supra paras. 51, 53; see also Letter from Rosaline Hayes Crawford, Director, Law and Advocacy Center, 
National Association of the Deaf, to Marlene H. Dortch, Secretary, FCC, CG Docket 03-123 (filed June 5, 2008).
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62. In addition, Internet-based TRS providers and their numbering partners also must 
communicate among themselves as necessary to ensure that only the default provider provisions routing 
information to the central database, and that providers other than the default provider are aware that they 
must query the central database in order to obtain accurate routing information for a particular user of 
Internet-based TRS.
63. In order to ensure that the telephone numbers of Internet-based TRS users are fully 
portable, that their devices are interoperable, and their privacy is protected, if an Internet-based TRS 
provider cannot provide service to a particular user in the manner described in this Order, the Internet-
based TRS provider must not provide service to that user without seeking prior approval of the 
Commission.
c. Authorized Access to the Central Database
64. We next address the issue of who will be authorized to query the central database for the 
purpose of obtaining information from the database to complete calls.
65. CSDVRSs ONS proposes to allow the public direct access to the central database.  The 
CSDVRS ONS is logically a part of the global DNS hierarchy that supports the Internet, and CSDVRS 
argues that such open access is comparable to the addressing system utilized by the public Internet.159  
Thus, any individual with access to the Internet would also be allowed to query the central database in 
order to obtain an Internet-based TRS users IP address.
66. We decline to adopt a public direct access model.  The record reflects that there are 
significant concerns regarding the ability to maintain the security of the central database if public direct 
access is allowed.160 The record also reflects that allowing public direct access to the central database 
would jeopardize the privacy of Internet-based TRS users.161
67. NeuStars TRU proposal restricts access to the central database to a limited number of 
authorized NPAC users  generally carriers or specialty service providers.162 Similarly, the Joint 
Proposals ORD would restrict access to the central database to the universe of Internet-based TRS 
providers.163 Although these proposals make use of industry-standard DNS and ENUM technology, they 
are not logically part of the global DNS.  As is the case with provisioning information to the central 
database,164 there is little compelling reason to insert a third party into the process of querying the central 
database for routing information. Further, the record reflects that restricting access to the universe of 
  
159 See CSDVRS Refresh Reply Comments at 6 (noting that the ONS database would be built on . . . the same 
system that provides address resolution for the Internet); id. at 12 (claiming an open access platform, like the 
Internet, is needed to prevent Internet-based TRS providers from restricting innovation in new TRS platforms).
160 AT&T Refresh Reply Comments at 5; NeuStar Refresh Reply Comments at 19; Sorenson Refresh Reply 
Comments at 10.  Even CSDVRS admits that its public access model requires additional measures to protect[] 
the user from attacks on the Internet. CSDVRS Refresh Comments at 37.
161 NeuStar Refresh Reply Comments at 19.  We also note CSDVRSs assertion that a key benefit of public direct 
access is that it would enable anyone equipped with a computer, an IP-enabled video camera, and an Internet 
connection to directly connect to Internet-based TRS users without the direct involvement of any Internet-based 
TRS provider.  See CSDVRS Refresh Reply Comments at 2.  We note that such calls are not TRS calls and therefore 
are not regulated or compensated under section 225.  See Interoperability Declaratory Ruling and FNPRM, 21 FCC 
Rcd at 5448 n. 53.  This potential benefit is therefore outside the scope of this order.
162 See NeuStar Refresh Comments, Attach. at 9.
163 See AT&T Ex Parte.
164 See supra para. 59.
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Internet-based TRS providers will help to ensure the security of the central database and the privacy of 
the data contained therein.165 We therefore adopt the Joint Proposals suggestion to restrict access to 
Internet-based TRS providers.
d. Other Considerations
68. Architecture.  Commenters observe that the DNS-based ENUM technology is a natural 
choice for the central database mechanism.166 We note that a DNS database structure can be implemented 
through a variety of architectures, and are not, in selecting a DNS structure for the central database of the 
centralized numbering directory mechanism, mandating the creation of a single, monolithic DNS database 
or otherwise limiting options for implementation of the central DNS database.  One of the key strengths 
of the DNS approach is its flexibility, and we defer to the neutral third party administrator discussed in 
section III.B.3 below to determine the most appropriate database architecture.
69. Implementation Time.  Selection of the Joint Proposals ORD structure does raise 
potential areas of concern.  Because the Joint Proposals ORD requires the selection of a new database 
operator and the creation of operational procedures for updating the database, commenters have raised 
concerns with respect to the likelihood that the Commissions December 31, 2008 implementation 
deadline will be met if a DNS structure is selected.167 By contrast, the NPAC already exists, is already 
managed by a neutral third party operator, and the processes and procedures necessary to provision 
information to and obtain information from the NPAC are well established.168
70. While timing will be a challenge, the record evidence indicates it is possible to build a 
new central numbering database as set out in the Joint Proposals ORD with appropriate governance 
structures prior to the Commissions deadline.169 Given the assertions that both NeuStars TRU and the 
Joint Proposals ORD could be implemented prior to our deadline, we believe that the benefits of utilizing 
the Joint Proposals ORD structure described above outweigh the relative time advantage of using 
NeuStars TRU.  Further, as discussed in greater detail in section III.G, the Commission today takes steps 
to ensure that the Commissions deadline is met.
71. Privacy and Security.  NeuStar also argues that the database mechanisms, as utilized in 
the CSDVRS ONS and the Joint Proposals ORD, raise potential security and privacy considerations.170  
In particular, NeuStar argues that the database mechanism described in the CSDVRS ONS and the Joint 
Proposals ORD could be subject to unauthorized access or make available sensitive personal information 
or competitive information.171 By contrast, under the rules by which the NPAC is administered, only 
service providers authorized by NeuStar are allowed access to the central database itself, and NeuStars 
existing implementation has the facility to restrict the data that an authorized user can see and the amount 
  
165 See AT&T Refresh Reply Comments at 5; GoAmerica Refresh Reply Comments at 1112.
166 See, e.g., CSDVRS Refresh Comments at 15 (noting that these technologies are scalable and expandable to meet 
the evolving needs of the deaf and hard of hearing community); AT&T Refresh Reply Comments at 34 (noting 
that a DNS system is preferable for a central database mechanism as it is already in place and used in the VoIP 
context).
167 See NeuStar Refresh Reply Comments at 1618; Sorenson Refresh Reply Comments at 46.
168 NeuStar states that modifications to the NPAC can be completed in two weeks, with necessary upgrades to 
provider systems and processes requiring three to four months.  See NeuStar Workshop Deck at 21.
169 See AT&T Workshop Deck at 10 (showing implementation timeline); Dash Refresh Reply Comments at 12.
170 Although these issues overlap with who gets access to information, the fact that the NPAC already exists and has 
established access procedures is germane to the task of selecting a central database mechanism.
171 See NeuStar Refresh Reply Comments at 1415, 1820.
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of data that can be downloaded.172
72. We believe the security and privacy advantages NeuStar attributes to use of its proposal 
are attributable to the rules that limit access to the central database to a limited set of registered entities, 
rather than to any particular technical aspect of the NPAC itself.  The record indicates that comparable 
registration and restricted access requirements can be implemented to secure a central database.173 As 
discussed in section III.B.2.c, we require that access to the central database be limited so as to adequately 
address those concerns.174
3. Neutral Administrator
73. Building, maintaining, and operating the central database will best be done by a neutral 
third-party administrator under contract to the Commission and compensated through the Fund.  Other, 
similar numbering functions are handled by third parties pursuant to contract, such as the NANPA and the 
PA.  Indeed, as we have noted with regard to those functions, section 251(e)(1) directs that [t]he 
Commission shall create or designate one or more impartial entities to administer telecommunications 
numbering and to make such numbers available on an equitable basis.175 The record reflects consistent 
support for using this approach to support a central numbering database in this context as well.176
74. Time is of the essence.177 The neutral database administrator must be selected, and must 
construct the database, work with industry to populate the database, test the functionality of the database, 
and be prepared to support ten-digit numbers for Internet-based TRS users by December 31, 2008.178  
Given the extremely tight timeline for accomplishing all these tasks  a timeline warranted by the public 
safety and functional equivalency that the ten-digit numbering solution will provide to the deaf and hard-
of-hearing community  we establish the following process for how we will contract with a neutral 
administrator.
  
172 NeuStar Workshop Deck at 19.
173 NeuStar itself noted that its suggestions on security are independent of the choice of database. NeuStar 
Refresh Reply Comments at 10.
174 NeuStar also raises the concern regarding the security of the link between Internet-based TRS providers and their 
end-users.  Although mandatory user registration should allay some of these concerns, see supra note 118, we seek 
comment on NeuStars remaining suggestions in the Further Notice, see infra Part IV.
175 47 U.S.C.  251(e)(1).
176 See, e.g., GoAmerica Refresh Comments at 12 (supporting the use of a neutral third-party database 
administrator); CSDVRS Refresh Comments at 9; NeuStar Refresh Comments at 15; Sorenson Refresh Comments 
at 17; Sprint Refresh Comments at 5; TDI Coalition Refresh Comments at 3.
177 See Letter from Sheri Farinha Mutti, Chief Executive Officer, NorCal Services for Deaf and Hard of Hearing, to 
Marlene H. Dortch, Secretary, FCC, at 1 (June 5, 2008) (Of prime importance for the purposes of E9-1-1 is the need 
for the Commission to enforce strict deadlines with regard to the established timeline, i.e., December 31, 2008, for 
full implementation of the numbering plan.); Letter from Claude L. Stout, Executive Director, Telecommunications 
for the Deaf and Hard of Hearing, Inc., to Marlene H. Dortch, Secretary, FCC, at 1 (June 5, 2008) (noting the 
pressing public interest need for Commission action on the numbering matter prior to the June 30, 2008 deadline 
previously established by the Commission); Letter from Rosaline Hayes Crawford, Director of the Law and 
Advocacy Center, National Association of the Deaf, to Marlene H. Dortch, Secretary, FCC, at 1 (June 5, 2008) 
(There remains a pressing public interest need for . . . implementation of a numbering system prior to the December 
31, 2008 deadline previously established by the Commission.).
178 See infra Section III.G.
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75. In the interest of time, we are not referring this issue to the NANC, as we have for past 
numbering contracts.179 Rather, we delegate authority to the Office of the Managing Director (Managing 
Director), with the assistance of the Wireline Competition Bureau, the Consumer & Governmental Affairs 
Bureau, and the Office of General Counsel, to select the neutral administrator based on a competitive 
bidding process.  As soon as possible after release of this Order, the Managing Director shall begin the 
contracting process.
76. Any database administrator must meet certain neutrality criteria, both with respect to 
being selected as the administrator and in performing its functions.  Consistent with the other numbering 
functions performed under contract, we believe that the neutral administrator should be a non-
governmental entity that is not aligned with any particular telecommunications industry segment.180 The 
neutral administrator must be fair and impartial.  It must also meet neutrality criteria similar to those we 
have established for the NANPA181 and the PA,182 but adjusted as appropriate to reflect the purposes of 
this particular database.
77. There are two proposals on the record for neutrality criteria that should apply to the 
neutral administrator.  Both ATIS183 and Sorenson184 suggest that the Commission adopt neutrality criteria 
very similar to those already in place for the NANPA.  We agree that this is the best approach, as 
demonstrated by our successful experience working with those neutrality criteria in another context.  We 
therefore conclude that:  (1) the neutral administrator must be a non-governmental entity that is impartial 
and is not an affiliate185 of any Internet-based TRS provider; (2) the neutral administrator and any affiliate 
may not issue a majority of its debt186 to, nor derive a majority of its revenues from, any Internet-based 
TRS provider; and (3) notwithstanding the neutrality criteria set forth in (1) and (2) above, the neutral 
  
179 Administration of the North American Numbering Plan; Toll Free Service Access Codes, CC Docket Nos. 99-
237, 95-155, Third Report and Order and Third Report and Order, 12 FCC Rcd 23040, 23049, para. 15 (Oct. 9, 
1997) (NANP Administration Third Report and Order).
180 See NRO First Report and Order, 15 FCC Rcd at 7642, para. 153.
181 See 47 C.F.R.  52.12(a)(1) (listing neutrality criteria for the NANPA).
182 See 47 C.F.R.  52.20(d)(1) (applying NANPA neutrality criteria to PA).
183 See ATIS Report, Appendix 3  1.0.
184 See Sorenson Refresh Comments, Attach. 1.
185 We base our definition of affiliate on the statutory definition in section 3 of the Act.  See 47 U.S.C.  153(1) 
(defining affiliate).  We elaborate on that definition as follows:  Affiliate is a person who controls, is controlled 
by, or is under the direct or indirect common control of another person.  A person shall be deemed to control another 
if such person possesses, directly or indirectly, (1) an equity interest by stock, partnership (general or limited) 
interest, joint venture participation, or member interest in the other person ten percent (10%) or more of the total 
outstanding equity interests in the other person; or (2) the power to vote ten percent (10%) or more of the securities 
(by stock, partnership (general or limited) interest, joint venture participation, or member interest) having ordinary 
voting power for the election of directors, general partner, or management of such other person; or (3) the power to 
direct or cause the direction of the management and policies of such other person, whether through the ownership of 
or right to vote voting rights attributable to the stock, partnership (general or limited) interest, joint venture 
participation, or member interest of such other person, by contract (including but not limited to stockholder 
agreement partnership (general or limited) agreement, joint venture agreement, or operating agreement, or 
otherwise.  See 47 C.F.R.  52.12(a)(1)(i); see also NRO First Report and Order, 15 FCC Rcd at 7642, para. 154
n.354; NANP Administration Third Report and Order, 12 FCC Rcd at 23076, para. 69.
186 Majority means greater than 50%, and debt means stock, bonds, securities, notes, loans, or any other 
instrument of indebtedness.  See 47 C.F.R.  52.12(a)(1)(ii); NRO First Report and Order, 15 FCC Rcd at 7643, 
para. 154 n.356; NANP Administration Third Report and Order, 12 FCC Rcd at 23076, para. 69.
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administrator may be determined to be or not to be subject to undue influence by parties with a vested 
interest in the outcome of TRS-related numbering administration and activities.187 Any subcontractor that 
performs functions of the neutral administrator must also meet these neutrality criteria.
78. Consensus body.  The ATIS Report and certain commenters recommend formation of a 
competent body, or the use of an existing body, to effectively coordinate the development of 
implementation requirements and manage ongoing database operations with the designated database 
provider.188 Such a body could include providers of Internet-based TRS, representatives from the deaf 
and hard-of-hearing community, and other interested stakeholders.  We encourage providers of Internet-
based TRS to heed the ATIS Report recommendation in this regard, but decline at this time to mandate 
the formation of an appropriate body.
C. Emergency Call Handling Requirements
79. We stated in the Interim Emergency Call Handling Order our belief that the use of a 
Registered Location process, similar to that adopted in the VoIP 911 Order, constitutes an additional 
critical component of an E911 solution for Internet-based TRS providers,189 so that a CA may promptly 
determine an appropriate PSAP, designated statewide default answering point, or appropriate local 
emergency authority to call to respond to the emergency.190 Accordingly, as we required of all 
interconnected VoIP providers, we require that all Internet-based TRS providers obtain or have access to 
consumer location information for the purposes of emergency calling requirements.191  We also require all 
Internet-based TRS providers to obtain from their Registered Internet-based TRS Users their physical 
location, and we modify the call handling requirements adopted in the Interim Emergency Call Handling 
Order to reflect the adoption of a Registered Location requirement.192
80. Registered Location Requirement.  We recognize that it currently is not always 
  
187 See 47 C.F.R.  52.12(a)(1)(iii); NRO First Report and Order, 15 FCC Rcd at 7643, para. 154 & n.357; NANP 
Administration Third Report and Order, 12 FCC Rcd at 23076, para. 69.
188 ATIS Report at 14, para. 4.2; CSDVRS Refresh Comments at 10.
189 We note that the courts have upheld our adoption, under our Title I jurisdiction, of similar rules for 
interconnected VoIP.  See Nuvio Corp. v. FCC, 473 F.3d 302 (D.C. Cir. 2006).
190 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5268, para. 22 (citing VoIP 911 Order, 20 FCC 
Rcd at 10271, para. 46 (describing Registered Location requirement for interconnected VoIP providers); 47 C.F.R. 
 9.3 (defining Registered Location as the most recent information obtained by an interconnected VoIP service 
provider that identifies the physical location of an end user)).
191 See 47 C.F.R.  9.5(d)(1) (requiring interconnected VoIP providers to [o]btain from each customer, prior to the 
initiation of service, the physical location at which the service will first be utilized); VoIP 911 Order, 20 FCC Rcd 
at 10271, para. 46 (same); see also id. at 10272, para. 47 ([I]nterconnected VoIP providers must, as a condition of 
providing that service to a consumer, provide that consumer with E911 service as outlined [by the Commission.]).  
Numerous commenters supported this requirement.  See, e.g., TDI Coalition Refresh Comments at 56; NeuStar 
Refresh Comments at 78; TRS Advisory Council Refresh Comments at 2; NENA Refresh Reply Comments at 4.
192 The requirement to implement a system that ensures that providers answer an incoming emergency call before 
other non-emergency calls (i.e., prioritize emergency calls and move them to the top of the queue) remains 
unchanged.  Interim Emergency Call Handling Order, 23 FCC Rcd at 526566, para. 16.  We now require that in 
the event one or both legs of the call are disconnected (i.e., either the call between the Internet-based TRS user and 
the CA, or the outbound voice telephone call between the CA and the PSAP, designated statewide default answering 
point, or appropriate local emergency authority), Internet-based TRS providers must immediately re-establish 
contact with the Internet-based TRS user and/or the appropriate PSAP, designated statewide default answering 
point, or appropriate local emergency authority and resume handling the call in all circumstances.  Id.
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technologically feasible for providers of Internet-based TRS to automatically determine the location of 
their end users without end users active cooperation.193 We therefore require each provider of Internet-
based TRS to obtain location information from each of their Registered Internet-based TRS Users.194  
Specifically, providers of Internet-based TRS must obtain from each of their Registered Internet-based 
TRS Users, prior to the initiation of service, the physical location at which the service will first be 
utilized.195 The most recent location provided to an Internet-based TRS provider by a Registered Internet-
based TRS User is the Registered Location. Internet-based TRS providers can comply with this 
requirement directly or by utilizing the services of a third party.  Furthermore, providers of Internet-based 
TRS that can be utilized from more than one physical location must provide their Registered Internet-
based TRS Users one or more methods of updating information regarding the Registered Internet-based 
TRS Users physical location.  Although we decline to specify any particular method, we require that any 
method utilized allow a Registered Internet-based TRS User to update his or her Registered Location at 
will and in a timely manner, including at least one option that requires use only of the CPE necessary to 
access the Internet-based TRS.196  Further, Internet-based TRS providers may not charge users to update 
their Registered Location, as this would discourage Registered Internet-based TRS Users from doing so 
and therefore undermine this solution.197
81. The Interim Emergency Call Handling Order required Internet-based TRS providers to 
request, at the beginning of every emergency call, the callers name and location information.198  
Internet-based TRS providers no longer are required to request such information at the beginning of an 
emergency call if the Internet-based TRS provider has, or has access to, a Registered Location for the 
caller.199
82. Routing 911 Calls.  The Interim Emergency Call Handling Order permitted Internet-
based TRS providers to route 911 calls to PSAPs ten-digit administrative lines pending adoption of a 
Registered Location requirement.200  As of December 31, 2008, we require that an Internet-based TRS 
provider must transmit all 911 and E911 calls, as well as a call back number, the name of the relay 
provider, the CAs identification number, and the callers Registered Location for each call, to the PSAP, 
designated statewide default answering point, or appropriate local emergency authority that serves the 
  
193 See VoIP 911 Order, 20 FCC Rcd at 10271, para. 46; see also Sorenson Refresh Reply Comments at 6 n.13.
194 We emphasize that we are not requiring providers of Internet-based TRS to automatically determine the location 
of their end users.  Nothing in these rules, however, prevents an Internet-based TRS provider from automatically 
obtaining an accurate Registered Location if it is capable of doing so.
195 Internet-based TRS providers also must obtain from their existing default users, no later than December 31, 
2008, the physical location at which the service is being utilized.
196 Cf. 47 C.F.R.  9.5(d)(2) (requiring interconnected VoIP providers to offer customers one or more methods of 
updating their Registered Location, including at least one option that requires use only of the CPE necessary to 
access the interconnected VoIP service); VoIP 911 Order, 20 FCC Rcd at 10271, para. 46 (noting that any method 
utilized for updating interconnected VoIP customers Registered Location must allow an end user to update the 
Registered Location at will and in a timely manner).
197 Cf. VoIP 911 Order, 20 FCC Rcd at 10271, para. 46.
198 Interim Emergency Call Handling Order, 23 FCC Rcd at 5265, para. 16.
199 Internet-based TRS providers may request verification of the Registered Location data during the course of 
handling a 911 call.  We also emphasize that a provider must use best efforts to handle an emergency call and place 
the outbound leg of such a call, even if the calling party refuses to provide his or her identity or a Registered 
Location.
200 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5265, para. 16 n.66.
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callers Registered Location and that has been designated for telecommunications carriers under section 
64.3001 of the Commissions rules.201 These calls must be routed through the use of ANI and, if 
necessary, pseudo-ANI,202 via the dedicated Wireline E911 Network,203 and the Registered Location must 
be available from or through the ALI Database.
83. Internet-based TRS providers may satisfy this requirement by interconnecting indirectly 
through a third party such as a competitive LEC, interconnecting directly with the Wireline E911 
Network, or through any other solution that allows an Internet-based TRS provider to offer E911 service 
as described above.  For the same reasons discussed in the VoIP 911 Order, an Internet-based TRS 
provider need only provide such call back and location information as a PSAP, designated statewide 
default answering point, or appropriate local emergency authority is capable of receiving and utilizing.204
84. We emphasize that as of December 31, 2008, Internet-based TRS providers may not 
fulfill their 911 obligations by routing 911 calls to ten-digit NPA-NXX numbers (so called 
administrative numbers) of PSAPs, designated statewide default answering points, or appropriate local 
emergency authorities where a Selective Router is utilized.205
85. 911 Service Providers. Based on the record before us, we continue to expect that 
Internet-based TRS providers will be able to use much of the same infrastructure and technology that is 
already in place for the delivery of 911 and E911 calls by interconnected VoIP service providers.206 The 
  
201 47 C.F.R.  64.3001; see also Implementation of 911 Act; The Use of N11 Codes and Other Abbreviated Dialing 
Arrangements, WT Docket No. 00-110, CC Docket No. 92-105, Fifth Report and Order, Memorandum Opinion and 
Order on Reconsideration, 16 FCC Rcd 22264, 2226977, paras. 1031 (Dec. 11, 2001).  The term PSAP has the 
same meaning as that set forth in section 20.3 of the Commissions rules.  47 C.F.R.  20.3.
202 The term pseudo-ANI as used herein has the same meaning as that set forth in section 20.3 of the 
Commissions rules.  47 C.F.R.  20.3. In light of the fact that TRS calls currently are not billed to TRS users, we 
must adopt a modified version of the term ANI as defined in  20.3.  The term ANI as used herein shall mean For 
911 systems, the ANI identifies the calling party and may be used as the callback number.
203 The term Wireline E911 Network as used herein has the same meaning as that set forth in section 9.3 of the 
Commissions rules.  47 C.F.R.  9.3.  In a typical implementation, the Wireline E911 Network includes the 
Selective Router, which receives 911 calls from competitive and incumbent LEC central offices over dedicated 
trunks.  The Selective Router, after querying an incumbent LEC-maintained Selective Router Database (SRDB) to 
determine which PSAP serves the callers geographic area, forwards the calls to the PSAP that has been designated 
to serve the callers area, along with the callers phone number (ANI). The PSAP then forwards the callers ANI to 
an incumbent LEC maintained Automatic Location Information database (ALI Database), which returns the callers 
physical address (that has previously been verified by comparison to a separate database known as the Master Street 
Address Guide (MSAG)).  The Wireline E911 Network thus consists of:  the Selective Router; the trunk line(s) 
between the Selective Router and the PSAP; the ALI Database; the SRDB; the trunk line(s) between the ALI 
database and the PSAP; and the MSAG.  VoIP 911 Order, 20 FCC Rcd at 10252, para. 15.
204 See VoIP 911 Order, 20 FCC Rcd at 1026970, paras. 4243.
205 See Interim Emergency Call Handling Order, 23 FCC Rcd at 527071, paras. 2728.
206 See VoIP 911 Order, 20 FCC Rcd at 1026769, paras. 3839; see also GoAmerica Refresh Comments at 17 
(noting that once Internet-based TRS users have NANP telephone numbers, emergency calls can be efficiently 
passed on to 911 systems for automatic routing to the appropriate PSAP in the same manner as VoIP calls are done 
today); NeuStar Refresh Comments at 78 (VRS and other IP-based relay services should use the same system for 
providing their users with E9-1-1 capability as is used by VoIP providers today.); Comments of the National 
Emergency Number Association, Attach. at 23 (Dec. 3, 2007) (indicating that an emergency call can be routed to a 
PSAP from a relay center using the same process that interconnected VoIP providers use); cf. id. at 2 n.4 (noting that 
OnStar, a telematics provider, routes emergency calls from its call centers to the appropriate PSAP over the Wireline 
E911 Network).
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record further reflects that there is a competitive market for the provision of such infrastructure and 
technology as well as related services,207 and competition has the effect of improving service and 
reducing prices.  We therefore reject CSDVRSs suggestion that all Internet-based TRS providers be 
required to utilize a single provider of 911 related services.208
86. We recognize that, because Internet-based TRS providers will be able to choose from 
among multiple providers of 911 related services, in instances in which an Internet-based TRS user places 
an emergency call through an Internet-based TRS provider other than the Internet-based TRS users 
default provider, the alternative provider may not have access to the Internet-based TRS users Registered 
Location information.209 We note, however, that providers must prioritize and answer emergency calls in 
accordance with the requirements set forth in the Interim Emergency Call Handling Order.210 Further, 
because of the importance of emergency call handling, providers must ensure adequate staffing of 
emergency call handling processes so that CAs are not required to disconnect non-emergency calls in 
order to process emergency calls. In light of these requirements and the nature of emergency calls, we 
expect that most, if not all, emergency calls will be dialed via an Internet-based TRS users default 
provider and thus will have associated Registered Locations.  Further, in light of the importance of access 
to emergency services for relay users, we ask below whether the Commission should take other steps in 
order to ensure that emergency calls are handled in an appropriate and expeditious manner.211
D. Consumer Outreach and Education
87. The Commission recognizes that effective consumer outreach and education are 
necessary to ensure a seamless transition to a ten-digit numbering system,212 and to ensure the successful 
implementation of the Registered Location requirement.213 To achieve these goals, we require Internet-
based TRS providers to expand upon the consumer advisory that we required them to issue in conjunction 
with the Interim Emergency Call Handling Order to include matters addressed in this Order pertaining to 
the assignment of ten-digit telephone numbers and the registration of Internet-based TRS users location 
information.  We also require Internet-based TRS providers, consistent with the VoIP 911 Order, to 
obtain, keep, and make available to the Commission upon request a record of affirmative 
acknowledgement by every user to whom they assign a ten-digit telephone number of having received 
and understood the advisory described below.
88. In the VoIP 911 Order, the Commission required interconnected VoIP providers to
specifically advise their subscribers of the circumstances under which E911 service may not be 
available through an interconnected VoIP service.214  The Commission also required interconnected 
  
207 See NeuStar Refresh Reply Comments at 5, 11; Dash Refresh Reply Comments at 5; Sorenson Refresh Reply 
Comments at 12; cf. GoAmerica Refresh Reply Comments at 10 (criticizing CSDVRS proposal for requiring 
Internet-based TRS providers to undo arrangements they are now making with 911 service providers).
208 See CSDVRS Refresh Reply Comments at 3132 (discussing the benefits of its proposed centralized common 
E9-1-1 system).
209 See CSDVRS Refresh Reply Comments at 9 (noting that other proposals do not explain if and how each 
providers address database information would be shared with other providers in real-time to support E9-1-1 
situations); Sprint Nextel Refresh Comments at 67; NeuStar Refresh Reply Comments at 1011.
210 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5269, para. 24; see also 47 C.F.R.  64.605.
211 See infra Section IV.1.
212 See supra Section III.B.
213 See supra paras. 8081.
214 VoIP 911 Order, 20 FCC Rcd at 10272, para. 48.
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VoIP providers to obtain and keep a record of affirmative acknowledgement by every subscriber, both 
new and existing, of having received and understood this advisory215 and to distribute labels warning 
subscribers if E911 service may be limited or not available and instructing the subscriber to place them on 
and/or near the CPE used in conjunction with the interconnected VoIP service.216 In light of these 
requirements, the Commissions VRS/IP Relay 911 NPRM sought comment on whether the Commission 
should impose similar consumer notification requirements on Internet-based TRS providers.217
89. In the Interim Emergency Call Handling Order, the Commission required Internet-based 
TRS providers to include an advisory on their websites and in any promotional materials directed to 
consumers, prominently and in plain language, explaining the circumstances under which emergency calls 
made via Internet-based TRS may be in some way limited by comparison to traditional E911 service.218  
We imposed this requirement based on our belief that it is important to educate consumers regarding the 
limitations of using the Internet-based forms of TRS to make emergency calls in the event that a 
consumer does place an emergency call via an Internet-based relay service.219 The Commission also 
noted that it may address additional consumer notification requirements, as appropriate, in a 
forthcoming order, consistent with the consumer notification requirements adopted in the VoIP 911 
Order.220
90. Because substantial consumer outreach efforts will be needed to ensure a seamless 
transition to a ten-digit numbering system and to ensure the successful implementation of the Registered 
Location requirement adopted herein, we require each Internet-based TRS provider to include an 
additional advisory on its website and in any promotional materials addressing the new requirements 
adopted herein.  This requirement is subject to the approval of the Office of Management and Budget 
(OMB).  If approved by OMB, this requirement shall become effective upon publication by the 
Commission of a notice in the Federal Register announcing the effective date.  At a minimum, the 
advisory must address the following issues:  (1) the process by which Internet-based TRS users may 
obtain ten-digit telephone numbers, including a brief summary of the numbering assignment and 
administration processes adopted herein; (2) the portability of ten-digit telephone numbers assigned to 
Internet-based TRS users; (3) the process by which persons using Internet-based forms of TRS may 
submit, update, and confirm receipt by the provider of their Registered Location information; and (4) an 
explanation emphasizing the importance of maintaining accurate, up-to-date Registered Location 
information with the users default provider in the event that the individual places an emergency call via 
an Internet-based relay service.  Consistent with the VoIP 911 Order, we also require Internet-based TRS 
providers to obtain and keep a record of affirmative acknowledgement by every user assigned a ten-digit 
telephone number of having received and understood the advisory described above.221
91. We conclude that imposing these requirements will help to ensure that consumers receive 
timely and complete information concerning the transition to a ten-digit numbering system and the 
  
215 Id.
216 Id. at 10273, para. 48.
217 VRS/IP Relay 911 NPRM, 20 FCC Rcd at 19486, para. 22.
218 Interim Emergency Call Handling Order, 23 FCC Rcd at 5270, para. 26.
219 Id. (citing VoIP 911 Order, 20 FCC Rcd at 10272, para. 48).
220 Id.
221 See, e.g., NENA Refresh Reply Comments at 45.
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implementation of the Registered Location requirement.222 We also agree with the comments of the TDI 
Coalition that significant outreach efforts both by providers and by the Commission will be needed in 
order to ensure a positive consumer experience during the transition to a ten-digit numbering system.223
To this end, the Commission directs the Consumer & Governmental Affairs Bureau to issue a consumer 
advisory to TRS users summarizing the requirements and obligations set forth in this Order, and to 
disseminate the advisory through the Consumer Information Registry.224  Commission staff will also 
continue to work closely with industry and consumer groups to ensure that TRS users are aware of and 
understand these new requirements.
E. IP Relay Fraud
92. Although Internet-based relay services have proven to be enormously popular with 
consumers, these services (and particularly IP Relay) may be more susceptible to misuse than other forms 
of TRS.  For example, the Commission has received complaints and anecdotal evidence that persons 
without a hearing or speech disability have misused IP Relay to defraud merchants by making purchases 
over the telephone using stolen, fake, or otherwise invalid credit cards.225 This misuse is enabled both by 
Internet-based TRS providers current difficulty in determining with certainty the geographic location of 
their users and by IP Relay providers inability to determine the identity of any particular user (because an 
IP Relay CA only receives the text of a users message).  In other words, IP Relay affords the user a 
degree of anonymity that is generally not possible with PSTN-based relay calls.226 This misuse harms 
both the merchants who are victimized and legitimate IP Relay users who may no longer be able to 
convince merchants to take their calls or accept their orders for merchandise.227 In addition, the misuse of 
IP Relay by hearing callers poses an added burden on the Fund  a burden ultimately borne by all 
consumers.228
93. In the IP Relay/VRS Misuse FNPRM, the Commission sought comment on specific ways 
  
222 Commenters support efforts to educate consumers about the transition to a ten-digit numbering system, including 
Registered Location requirements.  See, e.g., AAPD Refresh Reply Comments at 3; CSDVRS Refresh Reply 
Comments at 10; NENA Refresh Reply Comments at 5; TDI Coalition Refresh Comments at 6.
223 See TDI Coalition Refresh Comments at 6.
224 The Consumer Information Registry (CIR) is a consumer notification system developed by the Consumer & 
Governmental Affairs Bureau that delivers to subscribers free, customized information on various communications-
related topics of interest to the subscriber.  Consumers wishing to subscribe may access CIR at 
http://www.fcc.gov/cgb/contacts/welcome.html.  To receive announcements concerning Internet-based TRS 
numbering (and other disability-related issues), users should select Disability Issues from among the listed topics 
of interest on which the user wishes to receive e-mail notifications.
225 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Further Notice of Proposed Rulemaking, 21 FCC Rcd 5478, 548081, para. 6 
(May 8, 2006) (IP Relay/VRS Misuse FNPRM).
226 Id. Because TTY-based TRS calls are made over the PSTN, the call to the relay center includes identifying 
information, such as the calling partys number (e.g., the ANI).  That information is used to determine if the call is 
interstate or intrastate for compensation purposes under section 225, but also has the effect of deterring the misuse of 
this form of TRS.  Id. at 548081, para. 6 & n.19.
227 Id. at 5481, para. 7.  See Comments of Country Boy Trailers (June 1, 2006) (stating that they will be hesitant to 
accept TRS orders in the future because all experience with TRS in the past has been fraudulent).
228 IP Relay/VRS Misuse FNPRM, 21 FCC Rcd at 5481, para. 7.
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to curtail the misuse of IP Relay consistent with section 225 and the TRS regulations.229  The majority of 
the commenters urged the Commission to address this problem.230  In doing so, IP Relay providers 
generally asserted that a large portion of the fraudulent calls are placed by persons outside the United 
States using a stolen or fraudulent credit card to order goods to be shipped to a foreign location.231
94. We believe that registration of Internet-based TRS users with a default provider and 
provision of a Registered Location232 should reduce the misuse of IP Relay by persons seeking anonymity 
to make fraudulent credit card purchases and engage in other wrongdoing.233  We expect that the 
registration of Internet-based TRS users will gradually boost confidence amongst merchants that Internet-
based TRS calls are a valuable means of doing business within an often underserved community.  And 
because the curbing of IP Relay fraud is a collateral benefit of our registration requirements and because 
recent comments show that Internet-based TRS users do not object to registering for purposes of 
obtaining a ten-digit number and ensuring access to seamless emergency call handling services,234 we 
think the concerns of the commenters that opposed registration of IP Relay users solely as a means to curb 
fraud235 are moot.236
95. At the same time, we seek further comment on whether additional steps may be 
  
229 Id. at 548384, para. 1116.  Although the TRS statutory and regulatory regime does not contemplate that CAs 
should have a law enforcement role by monitoring the conversations they are relaying, id. at 5482, para. 9; 
Comments of Hamilton Relay, Inc. at 2 (July 6, 2006) (Hamilton TRS Fraud Comments), the Commission sought 
comment on whether CAs and Internet-based TRS providers should be given discretion to terminate calls they 
suspect to be fraudulent, IP Relay/VRS Misuse FNPRM, 21 FCC Rcd at 5483, para. 1113.  The item also sought 
comment on ways to curtail the use of VRS in circumstances where a fee-based in-person interpreter or a Video 
Remote Interpreting (VRI) service should be used.  Id. at 548485, para. 1721.
230 See, e.g., Comments of AT&T, Inc. at 1 (July 3, 2006) (AT&T TRS Fraud Comments); Hamilton TRS Fraud 
Comments at 12; Comments of Sorenson Communications, Inc. at 2 (July 3, 2006) (Sorenson TRS Fraud 
Comments); Comments of Verizon, Inc. at 1 (July 3, 2006) (Verizon TRS Fraud Comments).
231 See Sorenson TRS Fraud Comments at 4; Comments of Sprint Nextel Corporation at 34 (July 3, 2006) (Sprint 
TRS Fraud Comments).
232 See supra Section III.B.1.e & paras. 8081.
233 Merchants concerned about fraud can now require an NANP telephone number to call back to verify transactions 
and gain an additional level of confidence because only registered Internet-based TRS users will have such numbers.  
See Hamilton TRS Fraud Comments at 4 (asserting that mandatory user registration system would be an effective 
method of curbing fraudulent misuse of Internet-based TRS).
234 See, e.g., TDI Coalition Refresh Comments at 56; TDI Coalition Refresh Reply Comments at 2.
235 See AT&T TRS Fraud Comments at 7 ([I]mpaired consumers have repeatedly and strongly opposed user 
registration as a means to curb fraudulent activity.); Sprint TRS Fraud Comments at 7 (worrying that mandatory 
registration would impose undue burdens on the deaf and hard-of-hearing community); Comments of 
Telecommunications for the Deaf and Hard of Hearing, Inc., et al. at 7 (July 3, 2006) (opposing registration as a 
means of curbing fraud, but noting emergency call handling is not before the Commission in this FNPRM); 
Verizon TRS Fraud Comments at 9 (claiming that registration of Internet-based TRS user is unnecessary).
236 Sorensons concern that a fraudulent user might register with a fake name, see Sorenson TRS Fraud Comments at 
910, is tempered, in part, by the fact that a registering user will also be required to provide a physical address when 
registering.  Moreover, by endorsing the benefits of registration, the Commission does not rule on the particular 
practices of Internet-based TRS providers for curbing fraud within their own networks.  See, e.g., Sprint TRS Fraud 
Comments at 35 (describing Sprints efforts to combat IP Relay fraud).
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warranted to curtail the misuse of IP Relay.237
F. Cost Recovery Issues
96. Section 225 creates a cost recovery regime whereby TRS providers are compensated for 
their reasonable costs of providing service in compliance with the TRS regulations.238 The Commission 
has explained that for purposes of determining the reasonable costs that may be recovered . . . , the 
costs must relate to the provision of service in compliance with the applicable non-waived [TRS] 
mandatory minimum standards.239 Therefore, because we now require Internet-based TRS providers to 
offer ten-digit numbering and E911 services, providers of these services are entitled to recover their 
reasonable costs of complying with the new requirements as set forth below.240
97. Presently, both VRS and IP Relay are compensated at per-minute rates calculated 
pursuant to the cost recovery methodologies adopted in the 2007 TRS Rate Methodology Order.241 For IP 
Relay, we adopted a price cap plan that sets rates for a three-year period, subject to possible adjustment, 
including for exogenous costs.242 For VRS, we adopted tiered rates based on the providers projected 
costs and minutes of use, which are also set every three years.243 Although the VRS rates are not based 
on price caps, the Commission stated that providers would be permitted to seek exogenous cost 
adjustments if new costs are imposed that are beyond the providers control.244
98. Although we do not believe that the providers additional costs necessary to implement
the numbering and Registered Location requirements adopted herein will be substantial, they are costs for 
which the providers generally may be reimbursed.  These costs, of course, have not been factored into the 
present compensation rates, but reflect new costs related to new service requirements.245 Although we 
could adjust the current VRS and IP Relay rates to include these additional costs, we conclude that 
because the amount of these costs is presently uncertain, and may vary among the providers, we will 
compensate these costs separately from the other costs presently encompassed by the per-minute 
compensation rates.
99. Therefore, providers seeking compensation for their actual reasonable costs of complying 
with the new requirements adopted in this item must submit to the Interstate TRS Fund Administrator a 
  
237 See infra Section IV.11.
238 47 U.S.C.  225(d)(3); 47 C.F.R.  64.604(c)(5).  TRS users cannot be required to pay rates greater than the 
rates paid for functionally equivalent voice communication services with respect to such factors as duration of the 
call, the time of day, and the distance from point origination to point of termination. 47 U.S.C.  225(d)(1)(D).
239 2004 TRS Report & Order, 19 FCC Rcd at 1255152, para. 199; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Order on 
Reconsideration, 21 FCC Rcd 8050, 8057, paras. 1516 (July 12, 2006).
240 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5269, para. 23 n.87 (noting that the costs of 
compliance with that order are compensable from the Interstate TRS Fund as part of providing TRS service in 
compliance with the mandatory minimum standards).
241 22 FCC Rcd 20140.
242 Id. at 2015960, paras. 4344.  Exogenous costs are those costs beyond the control of the providers that are not 
reflected in other adjustments to the price cap rate.  Id. at 20160, para. 44.
243 Id. at 2016265, paras. 5256.
244 Id at 2016465, para. 56.
245 Id. at 20160, para. 44.
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reasonably detailed explanation of those costs incurred.  We will require that such costs be submitted 
every three months, beginning three months after the release date of this Order.  Costs submitted must be 
for those costs actually incurred during the prior three-month period.  The TRS Fund Administrator, and 
the Commission, shall review submitted costs and may request supporting documentation to verify the 
expenses claimed, and may also disallow unreasonable costs.  We will permit such filings until such time 
as new compensation rates are adopted that include the costs of complying with the requirements adopted 
herein, or the Commission otherwise re-addresses this issue.
100. Submitted costs may include those additional costs incurred by a provider that directly 
relate to:  (1) ensuring that database information is properly and timely updated and maintained; 
(2) processing and transmitting calls made to ten-digit numbers assigned pursuant to this Order; 
(3) routing emergency calls to an appropriate PSAP; (4) other implementation related tasks directly 
related to facilitating ten-digit numbering and emergency call handling; and (5) consumer outreach and 
education related to the requirements and services adopted in this Order.246  These costs do not include, 
however, costs relating to assigning numbers to the Internet-based TRS users nor costs relating to number 
portability.  Because voice telephone users generally bear these costs, we seek comment in the Further 
Notice below on whether Internet-based TRS users or the Fund should bear these costs.  We also remind 
Internet-based TRS providers, however, that these costs may not include costs related to facilitating non-
TRS peer-to-peer (or video-to-video) calls.247
101. We further note that some of the start-up expenses related to the database and the 
administration of the database might be more appropriately borne by the Fund rather than Internet-based 
TRS providers.  In this regard, we expect that the selection process for the database administrator may 
include contractual provisions addressing the direct compensation of the database administrator by the 
TRS Fund Administrator, as appropriate.  Therefore, to the extent necessary, we authorize the TRS Fund 
Administrator to pay the reasonable costs of providing necessary services consistent with this Order
directly to the database administrator rather than funnel the funding indirectly through providers. Finally, 
we note that to the extent the costs necessitated by the requirements adopted in this Order may require an 
adjustment to the Fund size, and therefore the carrier contribution factor, we expect the TRS Fund 
Administrator to monitor payments made from the Fund in connection with this Order and to recommend 
to the Commission, if and when appropriate, that the Fund size be adjusted.248
G. Timeline and Benchmarks
102. By this Order, the Commission has met its commitment to complete a final order on a 
ten-digit numbering plan in the second quarter of this year.249  Recognizing that Internet-based TRS 
  
246 These costs are recoverable only to the extent they are not already recovered as part of, or factored into the 
calculation of, current rates.
247 In this regard, we note that several consumer organizations suggest that hearing persons who communicate in 
American Sign Language should also be permitted to obtain a ten-digit number from Internet-based TRS providers 
so that they may benefit from the numbering system and make peer-to-peer calls to deaf persons.  See, e.g., TDI 
Coalition Refresh Reply Comments at 34.  We seek comment on that matter in the Further Notice.  See infra
Section IV.7.
248 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, CG Docket No. 03-123, Order, 23 FCC Rcd 1680 (CGB Feb. 6, 2008) (adjusting Fund size and carrier 
contribution factor for the 20072008 Fund year); Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CC Docket No. 98-67, Order, 19 FCC Rcd 2993 
(CGB Feb. 24, 2004) (adjusting Fund size and carrier contribution factor for the 20032004 Fund year).
249 See Interim Emergency Call Handling Order, 23 FCC Rcd at 5269, para. 24.
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providers and the neutral third-party administrator discussed above will require time to implement this 
Order, we require, consistent with the Interim Emergency Call Handling Order, that the ten-digit 
numbering plan be implemented such that ten-digit numbers are available to end users no later than 
December 31, 2008.250 In order to ensure this deadline is met, we authorize the Managing Director to 
include in the neutral third-party administration contract such benchmarks as are necessary to meet the 
implementation deadline.251
103. As a further means of ensuring that our implementation deadline is met, and recognizing 
that detailed implementation issues must be finalized prior to the implementation deadline, we hereby 
direct the Managing Director to include in the neutral third-party administration contract the requirement 
to refer all implementation disputes that it is unable to resolve in a reasonable time to the Chief, Wireline 
Competition Bureau.  We further authorize the Managing Director, if so requested by the Chief, Wireline 
Competition Bureau, to retain a technical advisor that will provide such assistance as the Chief, Wireline 
Competition Bureau, may require to resolve such disputes.
104. As noted above, the efforts of the end-user community, industry, and the Commission
were not until now sufficient to reach consensus on critical implementation issues.252  Our decision to 
provide a mechanism for the rapid resolution of implementation disputes should in no way be taken as a 
signal that we expect such failure of cooperation to continue.  Quite the opposite; this Order provides 
industry with the guidance it needs to move forward with implementation of the numbering system, 
emergency call processing, and other requirements set forth herein.  We emphasize that each stakeholder 
has the general obligation, and responsibility, to ensure that the requirements of this Order are fully and 
promptly implemented.  We will take any and all actions necessary to ensure that such obligations and 
responsibilities are fulfilled.
IV. FURTHER NOTICE OF PROPOSED RULEMAKING
105. Through this Further Notice, we seek comment on additional issues relating to the 
assignment and administration of ten-digit telephone numbers for Internet-based TRS.  These issues 
include:  (1) certain peripheral issues concerning the proper handling of 911 calls placed via Internet-
based TRS; (2) registration period; (3) the eligibility of Internet-based TRS users to receive multiple 
telephone numbers; (4) the use of toll free numbers; (5) what steps the Commission should take, if any, to 
facilitate implementation of standards-based signaling between service providers; (6) the assignment of a 
single telephone number to multiple services; (7) multi-line telephone systems; (8) eligibility to obtain 
Internet-based TRS telephone numbers; (9) the regulatory treatment of IP CTS; (10) additional security 
measures designed to ensure the integrity of the TRS system and Internet-based TRS equipment and 
networks; (11) verification of registration; (12) application of the anti-slamming rules to protect relay 
consumers against unauthorized default provider changes; (13) the extent to which the CPNI rules should 
apply to Internet-based TRS providers; and (14) whether, and to what extent, in connection with the 
compensation of Internet-based TRS providers for their reasonable actual costs of complying with this 
Order, the costs of acquiring numbers, and porting fees, should be passed on to Internet-based TRS users.
1. 911 Issues
106. We seek comment on whether we should modify the call completion rule to allow for 
  
250 See id.
251 See Workshop Webcast, http://www.fcc.gov/realaudio/mt042908.ram, at 4:53:034:56:08.
252 See supra para. 47.
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immediate answer of 911 calls.253 Under the current call completion rule, if a CA is conducting a relay 
call, that CA may not terminate the call for any reason, even if a 911 call is waiting in queue.  As 
demonstrated in the record, immediate response to 911 calls is critical so first responders can be deployed 
in an emergency.254 Thus, we seek comment on whether the call completion rule should be modified so 
that if a CA is handling a non-emergency relay call and identifies an incoming 911 call, the CA may 
terminate the existing call to answer the 911 call immediately.  If so, how should the rule be modified?  
What, if any, technical considerations must be addressed?
107. In addition, as noted above, if an Internet-based TRS user places an emergency call 
through an Internet-based TRS provider other than the Internet-based TRS users default provider, the 
default provider may not have access to the Internet-based TRS users Registered Location 
information.255 We seek comment on ways in which Registered Location information might be made 
available to alternative relay providers for the purpose of routing emergency calls.
108. NeuStar proposes to require inter-provider signaling, a process by which an alternative 
relay provider would route emergency calls to the 911 service provider utilized by the callers default 
Internet-based TRS provider, thus ensuring the call is routed according to the Internet-based TRS users 
Registered Location data.256 We seek comment on NeuStars inter-provider signaling proposal.  We also 
seek comment on whether other technical solutions are available to allow an alternative relay provider to 
obtain access to Registered Location data for the purpose of routing emergency calls.
2. Registration Period
109. We recognize that there must be a registration period to allow existing Internet-based 
TRS users to register with a default provider, provide their Registered Location, and obtain their new ten-
digit NANP telephone numbers.257 We also seek comment on the length of time necessary for this 
registration period.  Should there be a cut-off date upon which any Internet-based TRS user who has not
registered with a default provider will lose the ability to use Internet-based TRS until they register with a 
default provider?  Are there technical or other means by which Internet-based TRS providers could 
require an Internet-based TRS user to register prior to the reinitiation of service?  Are there any other 
issues we must consider in connection with the registration period?
3. Eligibility for Multiple Telephone Numbers
110. We note that Internet-based TRS providers will incur costs to acquire telephone numbers 
for their Registered Internet-based TRS Users.  There is some discussion in the record of how many 
numbers an Internet-based TRS user should be entitled to obtain from an Internet-based TRS provider, 
including allowing an Internet-based TRS user to obtain different numbers for use at particular locations 
(e.g., home and work), allowing one telephone number per device,258 and allowing one telephone number 
per household.259 The record does not, however, reflect a consensus on this issue, and we request further 
comment on whether Internet-based TRS users should be entitled to obtain multiple numbers, and if so at 
  
253 See 47 C.F.R.  64.604(a)(3)(i) (Consistent with the obligations of telecommunications carrier operators, CAs 
are prohibited from refusing single or sequential calls or limiting the length of calls utilizing relay services.).
254 See, e.g., TDI Coalition Refresh Comments at 6.
255 See supra para. 86.
256 NeuStar Refresh Reply Comments at 1112.
257 See supra para. 45.
258 See NeuStar Workshop Deck at 13, 16.
259 See Sonny Reply Refresh Comments at 2.
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what cost.
4. Use of Toll Free Numbers
111. We acknowledge that certain Internet-based TRS users currently use toll free numbers 
issued or assigned by Internet-based TRS providers or other carriers and may continue to do so.260 We 
seek comment on whether these Internet-based TRS users should be subject to a fee for use of a toll free 
number, as are hearing users.261 We also seek comment on any other issues involved in using toll free 
numbers for Internet-based TRS, including any impact the use of such numbers may have on the 
provision of 911 service.
5. Signaling
112. NeuStars TRU proposes that standards-based signaling be required between service 
providers.262 NeuStar suggests that inter-provider signaling using Session Initiation Protocol (SIP) for 
TRS will facilitate a transition from the current requirement that end devices implement H.323 protocols 
to an environment that will support H.323 standard and SIP end devices.263 Because our choice of a 
central database provisioned with IP addresses for VRS users obviates the immediate need for inter-
provider signaling, we decline to adopt NeuStars proposal at this time. However, we invite comments on 
NeuStars underlying objective of transitioning to SIP-based end devices and steps the Commission could 
take to facilitate the process.264 We also seek comment on what steps the Commission should take, if any, 
to facilitate implementation of standards-based signaling between service providers in other contexts, 
such as IP Relay.
6. Assignment of a Single Telephone Number to Multiple Services
113. The TDI Coalition asserts that functional equivalency requires that deaf and hard-of-
hearing users should have one NANP number for multiple devices, such as a stationary videophone and a 
portable wireless videophone.265 We note that currently, hearing users may not have one NANP number 
for multiple services, such as their home telephones and their portable wireless phones.  Indeed, hearing 
  
260 See supra note 72.
261 47 C.F.R.  52.101(f) (defining toll free numbers as numbers for which the toll charges for completed calls are 
paid for by the toll free subscriber).
262 See NeuStar Workshop Deck at 17; NeuStar TRU Supplement at 12.
263 Videophones and other devices that send video via the Internet to make VRS calls operate via specific call 
signaling protocols or standards that connect the two endpoints to the call.  H.323 identifies one set of standards for 
transmitting real-time voice and video over packet-based networks.  See International Telecommunication Union, 
Packet-based Multimedia Communications Systems, ITU-T Recommendation H.323 (July 2006).  SIP identifies 
another, newer, set of standards.  See Internet Engineering Task Force, SIP: Session Initiation Protocol, IETF RFC 
3261 (June 2002).
264 When we previously sought comment on whether VRS devices should be required to support a particular 
standard, see Interoperability Declaratory Ruling and FNPRM, 21 FCC Rcd at 546062, paras. 5157, commenters 
were divided on the issue, see, e.g., Comments of AT&T, Inc. at 5 (July 17, 2006) ([T]he Commission could adopt 
H.323 as the de facto standard, but allow VRS providers the option of using other protocols in lieu of H.323 to the 
extent such protocols interface with H.323.); Reply Comments of Snap Telecommunications, Inc. at 1 (asserting 
that opposition to mandatory standards was near unanimous and that such standards were unnecessary given the 
Commissions existing rules.).
265 TDI Coalition Refresh Reply Comments at 45; see also Dash Refresh Comments at 10 (discussing the 
possibility of assigning multiple devices to a single NANP telephone number); NeuStar Refresh Reply Comments at 
1516 (same).
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users generally need to employ some type of call forwarding functionality in order to make it possible to 
receive calls placed to a single telephone number from multiple devices.266 We seek comment on whether 
such a call forwarding system is sufficient for Internet-based TRS devices.  Alternatively, we seek 
comment on whether the functional equivalency standard requires that the numbering system adopted in 
this Order allow for a single NANP number to be assigned to multiple services. Whether and to what 
extent should the cost of such additional functionalities be passed on to Internet-based TRS users?
7. Multi-Line Telephone Systems
114. Many large enterprises, including school districts, colleges, and businesses, rely on 
private branch exchange, Internet-based private branch exchange, Centrex, and other multi-line telephone 
systems (MLTS).  In doing so, they regularly assign telephone numbers to their students, residents, and 
employees.  We seek comment on what, if anything, the Commission should do to ensure that Internet-
based TRS users who work in government buildings, live on college campuses, or otherwise use multi-
line telephone systems have access to functionally equivalent telephone numbers and E911 services as 
required by this Order.267 Can, and should, MLTS operators provide telephone numbers to Internet-based 
TRS users?  What procedures would be required to effectuate such a system?  What impact does the 
presence of a MLTS have on the ability of an Internet-based TRS user to select a default provider?  Are 
any additional safeguards necessary to assure that emergency calls are properly routed and handled for 
Internet-based TRS users using MLTS?
8. Eligibility to Obtain Internet-Based TRS Telephone Numbers
115. We seek comment on who should be eligible to obtain telephone numbers from Internet-
based TRS providers.268 Commenters should address any effect of their proposals on the Interstate TRS 
Fund.  Are there number exhaust concerns we should consider? What safeguards should be put in place, 
such as eligibility requirements and/or verification?  Are there other means by which the Commission or 
industry can or should facilitate the provision of point-to-point Internet-based communications among 
individuals with and without hearing or speech disabilities?  Commenters should also address the scope of 
section 225 with regard to these questions.
9. Regulatory Treatment of IP CTS
116. As noted above, IP CTS raises distinct technical and regulatory issues in the context of 
numbering.269 There is insufficient information in the record to make a finding on this form of Internet-
based TRS.  Accordingly, we seek comment on whether we should extend the numbering system adopted 
in this Order to IP CTS.  How are IP CTS calls routed and how does such call routing differ from VRS 
  
266 TDI Coalition Refresh Reply Comments at 5 (asking what actions deaf and hard-of-hearing users will need to 
take to forward calls received on one 10-digit number to be received on another 10-digit number, when using the 
same or different communication modalities).
267 With the exception of an ex parte from ACUTA, there is little in the record on this issue.  See ACUTA Ex Parte
at 12.
268 AG Bell Refresh Reply Comments at 1 (requesting that hearing users have access to VRS numbers as many 
deaf and hard of hearing . . . consumers have family members, friends, co-workers, and other associates who are 
hearing and who may wish to use [Internet-based TRS]); AAPD Refresh Reply Comments at 2 (arguing that the 
Commission should not take any action that could limit communication access in any way by making it difficult for 
hearing users to use telephone numbers to call persons who are deaf, persons who are hard of hearing or persons 
with speech disabilities either directly or through relay services); Nebraska PSC Refresh Comments at 2 (stating 
that Internet-based TRS must provide equal access to all users).
269 See supra note 5.
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and IP Relay services? Would the unique characteristics of IP CTS make it difficult or infeasible to map 
a NANP number to an IP address?  What jurisdictional and regulatory issues must be taken into 
consideration should the Commission decide to extend the numbering system adopted in this Order to IP 
CTS?
10. Security
117. NeuStar raises several concerns regarding the security of the TRS numbering system and 
of the equipment and networks used by Internet-based TRS users.  We seek comment on NeuStars 
proposals to require device registration, close firewalls, and close the network such that default 
Internet-based TRS providers only accept calls from their own Registered Internet-based TRS Users, from 
the PSTN, or from another Internet-based TRS provider.270 NeuStar notes that its suggestions on 
security are independent of the choice of database.271 We seek further comment on whether there are 
other security issues and measures that should be considered to ensure the integrity of the TRS system 
and the equipment and networks of Internet-based TRS users.  Does an Internet-based TRS users access 
ultimately need to be restricted to a single provider, as NeuStar proposes?  If so, what implications, if any, 
are there for the ability of users to dial around to alternative Internet-based TRS providers?  Would the 
Commission need to revise existing speed of answer requirements and, if so, how?  Alternatively, are 
there standards-based technical solutions for user authentication and for securing the user firewall 
traversal that would permit users to continue to make or receive relay calls directly through providers 
other than their default provider?  Could such technical solutions also enable two registered VRS users to 
connect directly to each other based only on information contained in a central database, without the need 
to rely on an intervening Internet-based TRS provider?  What specific consensus-based standards would 
be required?  We also seek comment on the Commissions authority to mandate the adoption of such 
security measures.
11. Verification of Registration
118. As noted, we believe that requiring Internet-based TRS providers to offer their users a 
means of registering will help reduce the abuse of IP Relay for fraudulent purposes.272 Nonetheless, we 
recognize that significantly reducing illegitimate IP Relay calls should benefit merchants, Internet-based 
TRS providers, Internet-based TRS users, and indeed all users of telecommunications services, and 
therefore seek comment on further rules that might curb these problematic practices.  Specifically, would 
a closed system requiring Internet-based TRS providers to validate the registration of users before 
completing non-emergency calls help curb IP Relay fraud?273 Would such a system be possible without 
imposing undue burdens on legitimate Internet-based TRS users?  And how are Internet-based TRS 
providers to verify that registration information itself is not fraudulent? Absent such a mandatory system, 
should the Commission specifically encourage (or even require) Internet-based TRS providers to filter out 
requests for Internet-based TRS that come from suspected illegitimate users, such as known fraudsters or 
overseas users?274  
  
270 NeuStar Refresh Comments at 10-11, Attach. at 9-10. NeuStars proposal would limit network access to only 
Registered Internet-based TRS Users and is identical to the process used by VoIP providers.  Id.
271 NeuStar Refresh Reply Comments at 10.
272 See supra Section III.E.
273 NeuStar proposes one such approach, which we discuss above.  See supra Section IV.10.
274 See Sorenson TRS Fraud Comments at 59.
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12. Slamming Issues
119. With our adoption of a ten-digit numbering mechanism for Internet-based TRS users, 
including giving users a choice of default Internet-based TRS providers to service their assigned numbers, 
we believe we should adopt rules to protect relay consumers against unauthorized default provider 
changes.  We seek comment on whether such protections are necessary and, if so, whether they should be 
similar to our current regulations to protect against, and remedy instances of, slamming.275 Where 
commenters support the adoption of protections analogous to our current slamming regulations, we seek 
specific proposed rule language and, in that regard, solicit comment on proposed rule language already 
submitted into the record by Sorenson.276
120. Background.  In the context of telecommunications services, slamming occurs when a 
company changes a subscribers carrier selection without that subscribers knowledge or explicit 
authorization.277 Section 258 of the Act and the Commissions implementing regulations explicitly 
prohibit slamming by telecommunications carriers.278 As the Commission previously has recognized, 
slamming nullifies the ability of consumers to select the telecommunications providers of their choice, 
and distorts the telecommunications market because it rewards those companies who engage in 
deceptive and fraudulent practices by unfairly increasing their customer base at the expense of those 
companies that market in a fair and informative manner and do not use fraudulent practices.279  
Comments we received in response to the Numbering PN support applying slamming rules to VRS and IP 
Relay providers as part of a ten-digit numbering plan, particularly in view of the fact that to obtain a ten-
digit telephone number, a TRS consumer will have to choose one of these providers as the default 
provider to service that number.  Commenters note that under this default provider system, there will be 
substantial competition among VRS or IP Relay providers for default status among relay consumers, 
which may lead to slamming by such providers.280
121. Current Commission rules, applicable to carriers in the provision of telecommunications 
service, require individual subscriber consent before a carrier change may occur.281 Such consent, 
moreover, must be obtained in compliance with the Commissions prescribed verification procedures, 
  
275 See 47 U.S.C.  258; 47 C.F.R. Part 64, Subpart K (47 C.F.R  64.1100 et seq.).
276 See Letter from Ruth Milkman, Counsel, Sorenson Communications, Inc., to Marlene H. Dortch, Secretary, FCC, 
at 23 & Attach. 3 (dated May 15, 2008) (Sorenson Rules Ex Parte); Letter from Ruth Milkman, Counsel, Sorenson 
Communications, Inc., to Marlene H. Dortch, Secretary, FCC, Attach. (dated May 19, 2008) (Sorenson Amended 
Rules Ex Parte).
277 Implementation of the Subscriber Carrier Selection Changes Provisions of the Telecommunications Act of 1996; 
Policies and Rules Concerning Unauthorized Changes of Consumers Long Distance Carriers, CC Docket No. 94-
129, Second Report and Order and Further Notice of Proposed Rulemaking, 14 FCC Rcd 1508, 1510, para. 1 (Dec. 
23, 1998) (1998 Slamming Order).
278 See 47 U.S.C.  258(a) (No telecommunications carrier shall submit or execute a change in a subscribers 
selection of a provider of telephone exchange service or telephone toll service except in accordance with such 
verification procedures as the Commission shall prescribe); see also, e.g., 47 C.F.R.  64.1120(a) (No 
telecommunications carrier shall submit or execute a change on the behalf of a subscriber in the subscribers 
selection of a provider of telecommunications service except in accordance with the procedures prescribed in this 
subpart).
279 1998 Slamming Order, 14 FCC Rcd at 151011, para. 1.
280 See CSDVRS Refresh Comments at 1517; Sorensen Refresh Comments at 1415; TDI Coalition Refresh 
Comments at 4; CSDVRS Refresh Reply Comments at 4; GoAmerica Refresh Reply Comments at 3.
281 47 C.F.R.  64.1120.
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which require that a carrier, prior to effecting a carrier change, either:  (1) obtain the subscribers written 
or electronically signed authorization; (2) obtain confirmation from the subscriber via a toll free number 
provided exclusively for the purpose of confirming orders electronically; or (3) utilize an independent 
third party to verify the subscribers order.282 Commission rules also allow a telecommunications carrier 
to acquire by sale or transfer either part or all of another carriers subscriber base, provided that the 
acquiring carrier complies with specific procedures.283 In addition, the Commissions incumbent 
slamming rules set forth carrier liability for slamming;284 procedures for resolution of an unauthorized 
change in carrier;285 procedures for resolving subscriber charges by an unauthorized carrier, whether the 
subscriber has paid the carrier or not;286 and procedures by which a subscriber can freeze his or her 
preferred carrier.287 Finally, the Commissions forfeiture guidelines currently establish a standard 
forfeiture amount of $40,000 for a violation of the Commissions rules against slamming.288
122. Scope of Slamming Rules.  We seek comment on whether we should adopt rules to 
safeguard against the unauthorized change of a relay users default provider.  In particular, we seek 
comment on whether such protections largely should track our current slamming regulations 
implementing section 258.289 We note that even though some Internet-based TRS providers are 
telecommunications carriers in other contexts, our current slamming regulations are not applicable to 
these carriers or other relay providers in the context of the provision of Internet-based TRS, because the 
Commissions slamming regulations apply to the provision of telecommunications service.  The 
Commission previously has concluded that TRS providers do not provide telecommunications services
within the meaning of the Act.290 Therefore, we seek comment on the adoption of a parallel set of 
slamming rules to apply specifically to VRS and IP Relay providers in the context of providing Internet-
based TRS, regardless of whether these providers are telecommunications carriers in other contexts.291  
We solicit input on whether those rules should be modeled after our current slamming regulations and, if 
so, how to account for the unique circumstances presented by slamming as it relates to the provision of 
ten-digit numbers to VRS and IP Relay users.  We also seek comment on whether our current slamming 
rules can be modified in such a way that they also may apply to VRS and IP Relay.
123. Jurisdiction. As a threshold matter, we seek comment generally on the Commissions 
authority with respect to extending slamming requirements to VRS and IP Relay providers.  Section 258, 
  
282 47 C.F.R.  64.1120(c).
283 47 C.F.R.  64.1120(e).
284 47 C.F.R.  64.1140.
285 47 C.F.R.  64.1150.
286 47 C.F.R.  64.1160, 64.1170.
287 47 C.F.R.  64.1190.  A preferred carrier freeze prevents a change in a subscribers preferred carrier selection 
unless the subscriber gives the carrier from whom the freeze was requested his or her express consent. 47 C.F.R. 
 64.1190(a).
288 47 C.F.R.  1.80(b)(4).
289 See 47 C.F.R. Part 64, Subpart K (Changes in Preferred Telecommunications Service Providers).
290 See 2000 TRS Order, 15 FCC Rcd at 517475, paras. 7981.
291 For instance, in lieu of applying to carriers, see 47 C.F.R.  64.1100(a)(d), these rules could apply to 
providers, defined to include Internet-based TRS providers.  See, e.g., Sorenson Rules Ex Parte, Attach. 3, at 1; 
Sorenson Amended Rules Ex Parte, Attach. at 1.
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by its own terms, applies only to telecommunications carrier[s],292 which do not include carriers or 
other relay providers in the context of their provision of relay services.293 We seek comment on whether, 
if we were to extend slamming rules to VRS and IP Relay providers, we can employ ancillary jurisdiction 
under Title I of the Act to do so.  The Commission can employ ancillary jurisdiction where it has subject 
matter jurisdiction over the service to be regulated and the assertion of jurisdiction is reasonably 
ancillary to the effective performance of our responsibilities.294  It is clear from section 225 and the 
Commissions implementing orders that the regulation of TRS falls within the Commissions 
jurisdiction.295  Furthermore, we tentatively conclude that, because of the risk of slamming engendered by 
the adoption of a numbering system for VRS and IP Relay providers, adopting anti-slamming rules is 
reasonably ancillary to our regulation of relay services and our statutory duty to ensure that relay 
services are available in the most efficient manner to hearing- and speech-impaired individuals.296 We 
seek comment on this tentative conclusion.  We also seek comment on whether using our Title I ancillary 
jurisdiction in this manner is consistent with other instances where we have extended Title II obligations 
to Internet-based providers,297 and extended our TRS requirements to interconnected VoIP providers 
pursuant to section 225(b) of the Act and our Title I ancillary jurisdiction.298
124. Substance of Anti-Slamming Rules.  We seek comment on the specific measures we 
should adopt to protect against slamming that may result from the adoption of a ten-digit numbering 
mechanism for Internet-based TRS users.299 More specifically, we seek comment on whether any rules 
we adopt should prohibit covered TRS providers from submitting or executing a change on behalf of a 
TRS user in the selection of a default provider except in accordance with prescribed procedures.  We also 
  
292 47 U.S.C.  258(a).
293 Though some relay providers are telecommunications carriers in the context of providing telecommunications 
service, these same relay providers are not considered telecommunications carriers in the context of providing 
relay services.  See 2000 TRS Order, 15 FCC Rcd at 517475, paras. 7981.
294 U.S. v. Southwestern Cable Co., 392 U.S. 157, 17778 (1968).
295 See 47 U.S.C.  225(b) (granting Commission authority to administer and enforce section 225s relay services 
mandate); 47 U.S.C.  225(d) (directing Commission to develop and implement regulations governing the provision 
of relay services); 2000 TRS Order, 15 FCC Rcd at 514142, para. 1 (Section 225 requires the Commission to 
ensure that interstate and intrastate relay services are available throughout the country and to establish regulations to 
ensure the quality of relay service.).
296 See 47 U.S.C.  225(b)(1).
297 See IP-Enabled Services; Implementation of Sections 255 and 251(a)(2) of The Communications Act of 1934, as 
Enacted by The Telecommunications Act of 1996: Access to Telecommunications Service; Telecommunications 
Equipment and Customer Premises Equipment by Persons with Disabilities; Telecommunications and Relay 
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; The Use of N11 
Codes and Other Abbreviated Dialing Arrangements, WC Docket No. 04-36, CC Docket No. 92-105, WT Docket 
No. 96-198, CG Docket No. 03-123, Report and Order, 22 FCC Rcd 11275, 1128283, para. 15 (June 15, 2007) 
(Sections 225/255 VoIP Order) (describing Commissions application of E911 calling, universal service 
contribution, and customer proprietary network information obligations to interconnected VoIP providers).
298 See id. at 1129293, para. 35.  We extended our TRS requirements to interconnected VoIP providers based on 
our finding that doing so will serve the core objectives of section 225 and our TRS rules by making TRS widely 
available and by providing functionally equivalent services for the benefit of individuals with hearing or speech 
disabilities.  Id. at 11293, para. 35.
299 As noted above, a threshold difference between the current slamming rules and the rules that we could adopt to 
apply to VRS and IP Relay providers is that the new rules could be addressed to TRS providers and users, as 
opposed to telecommunications carriers and subscribers.
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seek comment on how to ensure and verify that consumer consent was obtained before a provider change 
is effectuated.  Would it suffice to require that a provider, prior to effectuating a provider change, either:  
(1) obtain the TRS users written or electronically signed authorization; or (2) obtain the TRS users 
electronic authorization?  We do not at this juncture propose utilization of an independent third party to 
verify the TRS users order regarding the default provider change, as we do not think such a step is 
necessary where the relay users written or electronically signed authorization may be obtained readily, as 
is the case with Internet-based relay.300 We believe that if experience dictates a need for verification 
procedures other than the two we propose, we can revisit this issue at a later point.  We seek comment on 
these proposed verification procedures, including the absence of a third-party verification mechanism.
125. In addition, we seek comment on how to craft liability provisions for violations of any 
new slamming rules that we adopt for Internet-based TRS providers.  Specifically, we seek comment on 
whether, as with our current slamming regulations, different liability mechanisms should exist depending 
on whether the unauthorized provider already has been paid.  We seek comment on liability provisions in 
circumstances where the unauthorized provider has not yet been reimbursed by the Fund for minutes 
incurred by a user whose default provider was impermissibly transferred.  Section 64.1160 of the 
Commissions rules provides that, in the telecommunications service context, an unauthorized carrier 
must remove from a subscribers bill all charges incurred for service provided during the first 30 days 
after the alleged unauthorized change occurred.301 Section 64.1160 was designed to provide carriers with 
the incentive to verify all carrier changes properly, in order to protect themselves against any possible 
inappropriate consumer claims of slamming, as well as to use methods that provide convincing proof of a 
subscribers authorization.  Relatedly, it provides incentive for carriers to implement strictly the 
Commissions verification rules because failure to comply may mean that the carriers will not get paid for 
any services rendered after an unauthorized switch.302  We seek comment on whether we should adopt a 
similar rule in the context of VRS and IP Relay.  For instance, should the unauthorized provider be 
required to remove all minutes from its monthly submission to the TRS Fund Administrator for services 
provided to the slammed user for the first 30 days after the alleged unauthorized change in providers 
occurred?  If so, do the Commission and the TRS Fund Administrator have sufficient safeguards in place 
to ensure that these minutes actually are excluded from the unauthorized providers monthly submission?  
We also welcome other suggestions for liability provisions in these circumstances.
126. In circumstances where the unauthorized provider already has been compensated from 
the Fund, should we require that provider to forward to the authorized provider an amount equal to 100% 
of all payments the unauthorized provider received from the Fund for minutes attributable to the slammed 
user?  We believe that as part and parcel of any slamming rules that we adopt for VRS and IP Relay, these 
liability amounts would not be recoverable from the Fund, nor could they be built into the cost data 
submitted to calculate the rates for subsequent Fund years.
127. We also seek comment on whether liability provisions, as applied to any new slamming 
rules we adopt for VRS and IP Relay providers, should differ from those in the existing slamming 
regulations in light of the fact that the costs of Internet-based TRS are not borne by TRS users, rather they 
are paid from the Fund.  Therefore, for example, unlike in the context of telecommunications services 
  
300 Cf. 47 C.F.R.  64.1120(c)(3) (permitting use of an independent third party to verify an authorized switch of 
telecommunications carrier).
301 See 47 C.F.R.  64.1160.
302 See Implementation of the Subscriber Carrier Selection Changes Provisions of the Telecommunications Act of 
1996; Policies and Rules Concerning Unauthorized Changes of Consumers Long Distance Carriers, CC Docket 
No. 94-129, First Order on Reconsideration, 15 FCC Rcd 8158, 816163, paras. 8, 10 (May 3, 2000) (citing 1998 
Slamming Order, 14 FCC Rcd at 151819, paras. 1314).
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billed to subscribers, there is no basis to relieve the VRS or IP Relay user of charges paid for service 
when a provider has been changed without authorization.  In this regard, we seek comment on whether 
unauthorized providers should be liable to remit to the Fund an additional 50% of the amount paid to the 
unauthorized provider for the provision of TRS to the slammed user, regardless of whether the 
unauthorized provider already has been reimbursed by the Fund.  This is analogous to our current 
slamming regulations, where the unauthorized carrier is liable to repay the authorized carrier and 
slammed subscriber a total of 150% of the charges incurred after the unauthorized carrier change, albeit 
only where the slammed subscriber already has paid the charges to the unauthorized carrier.303 We seek 
comment on whether a provision whereby an unauthorized provider is liable to remit a total of 150% of 
the payments associated with the users minutes of use after the unauthorized change is appropriate as a 
deterrent to slamming in the context of Internet-based TRS, or whether it is unnecessary if we adopt 
forfeiture provisions governing slamming by VRS and IP Relay providers.304 We also solicit input on 
whether any liability provisions that we adopt should constitute a different percentage of payments, 
should be distributed in a different proportion or to different recipients, or should be measured in a 
different manner altogether.
128. Regarding complaint resolution, we seek comment on what procedures to adopt when a 
provider is informed by a user of an unauthorized change in provider, including procedures by which the 
allegedly unauthorized provider may rebut the allegation that an unauthorized change occurred.  Does 
section 64.1150 of our current slamming regulations provide a good model for any such procedures that 
we adopt?305 Section 64.1150 generally sets forth procedures for resolution of unauthorized changes in 
preferred carrier, such as notifying the slammed subscriber of his or her options for filing a complaint or 
otherwise seeking resolution of the unauthorized change, and what an allegedly unauthorized carrier 
should do to rebut the allegation of an unauthorized carrier change.306 One element of section 64.1150 
that we would propose to omit from new slamming rules applicable to VRS and IP Relay providers is the 
provision for state commission administration of the slamming rules.307 Because states generally do not 
oversee the provision of VRS and IP Relay, and do not compensate VRS and IP Relay providers at this 
time, we propose to exclude an option for a state to resolve VRS and IP Relay slamming complaints or 
otherwise administer the slamming rules.  We seek comment on this proposal.  We also seek comment on 
whether there should be a deadline by which relay users must notify unauthorized providers of an alleged 
unauthorized provider change.  Has delay in notification of alleged unauthorized carrier changes or filing 
of slamming complaints been an issue under our current slamming regulations?
129. Furthermore, we seek comment on whether we should adopt other rules substantially 
similar to their counterparts in the current slamming regulations, though modified to apply to the specific 
circumstances of the numbering and default provider scheme for VRS and IP Relay.  For instance, should 
we allow a VRS or IP Relay provider to acquire, by sale or transfer, either part or all of another providers 
consumer base, provided that the acquiring provider complies with specific procedures?308 Should we set
forth requirements for a letter of agency to serve as a valid request for a change in default VRS or IP 
Relay provider?309 Should we adopt procedures by which a TRS user can freeze his or her default VRS 
  
303 See 47 C.F.R.  64.1140(a), 64.1170.
304 See infra para. 130.
305 See 47 C.F.R.  64.1150.
306 See id.
307 Cf. 47 C.F.R.  64.1110, 64.1150(b) (permitting state commissions to administer slamming rules).
308 See 47 C.F.R.  64.1120(e).
309 See 47 C.F.R.  64.1130.
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or IP Relay provider, which would prevent a change in providers unless the consumer gives the provider 
from whom the freeze was requested his or her express consent?310 The Commission adopted carrier 
freeze mechanisms nearly ten years ago in order to provide an extra measure of consumer protection 
against fraud and slamming.  In doing so, however, the Commission also recognized the potential for their 
implementation in an unreasonable or anticompetitive manner.311 Is the threat of slamming in the context 
of VRS and IP Relay sufficient to justify this extra protection?  We request that commenters addressing 
default provider freezes also discuss the positives and negatives of preferred carrier freezes in the 
telecommunications context through the lens of nearly ten years experience with them.
130. Finally, as noted above, the Commissions forfeiture guidelines currently establish a 
standard forfeiture amount of $40,000 for a violation of the Commissions rules against slamming.312  
Forfeitures pursuant to section 1.80(b)(4) are in addition to the carrier liabilities set forth in sections 
64.1160 and 64.1170 of the Commissions rules for unauthorized changes in preferred carrier.  We seek 
comment on the applicability of this provision to instances of slamming by VRS or IP Relay providers.  
As with the slamming liability amounts discussed above,313 unauthorized providers would not be 
permitted to recover forfeiture amounts levied under section 1.80(b)(4) of our rules from the Fund, and 
may not build them into cost data submitted to calculate the rates for subsequent Fund years.  In addition 
to the foregoing issues and proposals on which we seek comment, we solicit suggestions on whether there 
are any other provisions, either currently in our slamming regulations or otherwise, that should be applied 
to VRS and IP Relay providers if we adopt new anti-slamming rules for these Internet-based relay 
services.
13. Consumer Privacy
131. In this section, we seek comment on what, if any, specific actions the Commission should 
take to ensure the privacy and security of TRS consumers call records or other personally identifiable 
account or usage information, including the information users provide in connection with the Registered 
Location requirement discussed above.314
132. Section 222 and the Commissions CPNI Rules. To safeguard consumer privacy interests 
in a newly deregulated telecommunications market, in 1996 Congress added section 222 to the 
Communications Act315 to regulate telecommunications carriers use and disclosure of customer 
proprietary network information (CPNI) and other customer information obtained by carriers in their 
provision of telecommunications services.316  Designed to reflect a balance of competitive and 
consumer privacy interests with respect to CPNI, section 222 embodies the principle that customers 
must be able to control information they view as sensitive and personal from use, disclosure, and access 
  
310 See 47 C.F.R.  64.1190 (governing preferred carrier freezes).
311 See 1998 Slamming Order, 14 FCC Rcd at 157679, paras. 9399.
312 47 C.F.R.  1.80(b)(4).
313 See supra para. 126.
314 See supra paras. 8081.
315 47 U.S.C.  222.
316 See Telecommunications Carriers Use of Customer Proprietary Network Information and Other Customer 
Information; Implementation of the Non-Accounting Safeguards of Sections 271 and 272 of the Communications Act 
of 1934, as Amended, Second Report and Order and Further Notice of Proposed Rulemaking, CC Docket Nos. 96-
115, 96-149, 13 FCC Rcd 8061, 8061, para. 1 (Feb. 26, 1998) (CPNI Order) (explaining the regulatory backdrop of 
the enactment of section 222).
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by carriers.317  CPNI is information that relates to the quantity, technical configuration, type, 
destination, location, and amount of use of a telecommunications service that is available to a carrier 
solely by virtue of the carrier-customer relationship.318 As a practical matter, CPNI may include 
information such as the phone numbers called by a consumer; the frequency, duration, and timing of such 
calls; and any services purchased by the consumer, such as call waiting. Section 222(c)(1) provides that a 
carrier may only use, disclose, or permit access to customers CPNI in limited circumstances:  (1) as 
required by law; (2) with the customers approval;319 or (3) in its provision of the telecommunications 
service from which such information is derived, or in its provision of services necessary to, or used in, 
the provision of such telecommunications service.320
133. In the CPNI Order and subsequent orders, the Commission promulgated rules 
implementing the statutory requirements of section 222.321  In doing so, the Commission found that 
customer approval could be inferred from an existing carrier-customer relationship for certain uses of 
CPNI by the carrier itself.322 The Commission thus adopted a total service approach under which a 
carrier could, without notice to the customer, use CPNI to market new services incidental to the service 
  
317 Id. at 8065, para. 3.
318 See 47 U.S.C.  222(h)(1).  CPNI also includes information contained in customer bills.  Id.
319 The Commission identified two possible methods of ascertaining customer approval:  (1) to presume customer 
approval unless the customer specifies otherwise (opt-out approach); or (2) to require a customer to affirmatively 
indicate approval (opt-in approach).  In its first order interpreting section 222, the Commission determined that opt-
in best reflected Congresss intent to the extent that the term approval generally connotes an informed and 
deliberate response, and express approval [by opt-in] best insures such a knowing response.  CPNI Order, 13 
FCC Rcd at 8130, para. 91.  The United States Court of Appeals for the Tenth Circuit vacated on First Amendment 
grounds the Commissions decision requiring carriers to obtain opt-in consent before disclosing CPNI to a third 
party.  U.S. West v. FCC, 182 F.3d 1224, 123738 (10th Cir. 1999) (holding that opt-in approach did not advance 
FCCs asserted interest in protecting privacy of CPNI because of lack of evidence showing harm to privacy is real 
and because FCC failed to adequately consider less restrictive opt-out strategy).  In light of the Tenth Circuits 
objections to the opt-in approach, the Commission on remand adopted an opt-out approach for carriers own use of 
CPNI for marketing purposes and for disclosures of CPNI to third parties for those purposes.  Implementation of the 
Telecommunications Act of 1996: Telecommunications Carriers Use of Customer Proprietary Network Information 
and Other Customer Information, Third Report and Order and Third Further Notice of Proposed Rulemaking, CC 
Docket No. 96-115, 17 FCC Rcd 14860, 14874, para. 30 (July 25, 2002).  Last year, the Commission, in response to 
new circumstances, changed its rules once again to require opt-in consent before disclosing CPNI to a third party 
other than agents and affiliates that provide communications-related services.  Implementation of the 
Telecommunications Act of 1996:  Telecommunications Carriers Use of Customer Proprietary Network 
Information and Other Customer Information, Report and Order and Further Notice of Proposed Rulemaking, CC 
Docket No. 96-115, 22 FCC Rcd 6927, 6947, para. 37 (Apr. 2, 2007) (EPIC CPNI Order) (requiring opt-in for joint 
venture partners and independent marketing contractors), pet. for rev. pending, NCTA v. FCC, Docket No. 07-1312 
(D.C. Cir., filed Aug. 8, 2007).
320 See 47 U.S.C.  222(c)(1).
321 See 47 C.F.R.  64.2001 et seq.
322 See CPNI Order, 13 FCC Rcd at 8080, para. 23.  The Commission explained, the language of section 
222(c)(1)(A) and (B) reflects Congress judgment that customer approval for carriers to use, disclose, and permit 
access to CPNI can be inferred in the context of an existing customer-carrier relationship.  This is so because the 
customer is aware that its carrier has access to CPNI, and, through subscription to the carriers service, has implicitly 
approved the carriers use of CPNI within that existing relationship.  Id.
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already being provided (such as caller ID marketed to an existing local service customer).323 The total 
service approach did not extend to disclosure of CPNI beyond the carrier itself to third parties.
134. The Commission also adopted rules to ensure telecommunications carriers establish 
effective safeguards to protect against unauthorized use or disclosure of CPNI.324 Among other things, 
the rules require carriers to:  (1) implement a system by which the status of a customers CPNI approval 
can be clearly established prior to the use of CPNI;325 (2) train their personnel as to when they are and are 
not authorized to use CPNI (and establish an express disciplinary process);326 (3) maintain a record of 
instances in which CPNI has been disclosed or provided to third parties, or where third parties have been
allowed access to CPNI, and to maintain such records for at least one year;327 (4) establish a supervisory 
review process for outbound marketing campaigns under which sales personnel must obtain supervisory 
approval of proposed outbound marketing requests for customer approval;328 and (5) certify annually 
regarding its compliance with the Commissions CPNI requirements and to make this certification 
publicly available.329
135. In last years EPIC CPNI Order, the Commission adopted additional safeguards to 
protect customers CPNI in response to concerns raised in the record and in a petition for rulemaking filed 
by the Electronic Privacy Information Center (EPIC) regarding unauthorized disclosure and the practice 
of pretexting.330  The Commission defined pretexting as the practice of pretending to be a particular 
customer or other authorized person in order to obtain access to that customers call detail or other private 
communications records.331 Based on its review of the record, the Commission determined it must take 
additional steps to protect customers from carriers that have failed to adequately protect CPNI.332 In 
particular, the EPIC CPNI Order:  (1) restricted disclosure of CPNI over the telephone and required 
passwords to be used in customer-initiated calls seeking CPNI;333 (2) required passwords for on-line 
access to customer account information;334 and (3) adopted a number of notification requirements for 
changes in account status and unauthorized disclosures of CPNI.335 The Commission also changed its 
rules to require an opt-in approach for carrier disclosure to any third party other than agents and 
  
323 See id. (explaining total service approach to defining boundaries of  customers implied consent concerning use
of CPNI).
324 See id. at 8195, para. 193.
325 47 C.F.R.  64.2009(a); see also CPNI Order, 13 FCC Rcd at 8198, para. 198.
326 47 C.F.R.  64.2009(b); see also CPNI Order, 13 FCC Rcd at 8198, para. 198.
327 47 C.F.R.  64.2009(c); see also CPNI Order, 13 FCC Rcd at 819899, para. 199.
328 47 C.F.R.  64.2009(d); see also CPNI Order, 13 FCC Rcd at 8199, para. 200.
329 47 C.F.R.  64.2009(e); see also CPNI Order, 13 FCC Rcd at 8199, para. 201.
330 EPIC CPNI Order, 22 FCC Rcd at 6928, para. 1 n.1.
331 Id.  Call detail includes any information that pertains to the transmission of specific telephone calls including, 
for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the 
number from which the call was placed, and the time, location, or duration of any call.  Id. at 6936, para. 13 n.45.
332 Id. at 6933, para. 12.
333 Id at 693739, paras. 1517.
334 Id. at 694041, paras. 2022.
335 Id. at 6942, 694345, paras. 24, 2632.
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affiliates that provide communications-related services.336 Finally, relying on its ancillary jurisdiction 
under Title I of the Communications Act, the Commission extended the application of the CPNI rules to 
interconnected VoIP providers.337
136. Confidentiality of TRS Customer Information. In the 2000 TRS Order, the Commission 
considered whether the CPNI requirements of section 222 would apply to the transfer of customer 
profile information between two TTY-based TRS providers when there is a change in providers.338 In 
concluding that section 222s requirements would not restrict an exiting TTY-based TRS provider from 
transferring this information to an incoming provider (the transfer of which the Commission deemed 
necessary to ensure a smooth transition between providers), the Commission focused on the scope of the 
term telecommunications carriers in section 222.339 The Commission observed that the applicability of 
section 222 to TRS providers depends on whether TRS providers provide telecommunications services
and are therefore telecommunications carriers[,] as defined in the Communications Act.340 Concluding 
that TRS providers do not provide telecommunications within the meaning of the Act, the Commission 
determined that section 222 would not apply to an existing TRS providers transfer of customer profile 
information to a new provider.341
137. While it did not apply its CPNI rules to TRS, the Commission nevertheless emphasized 
that customer profile information may not be used for any purpose other than the provision of TRS.342  
  
336 47 C.F.R.  64.2007(b); see also EPIC CPNI Order, 22 FCC Rcd at 694753, paras. 3749 (finding that new 
circumstances  including the growing illicit demand for personal information, the significant harm that can result 
from breaches of confidentiality, and the increasing risk of disclosure  force us to reassess our existing 
regulations).
337 EPIC CPNI Order, 22 FCC Rcd at 695457, paras. 5459.  The Commission explained that it was extending the 
CPNI rules to interconnected VoIP providers based on consumer expectations that their telephone calls would be 
private, regardless of whether a call was made using the service of a wireline carrier, a wireless carrier, or an 
interconnected VoIP provider, given that these services are virtually indistinguishable from the perspective of a 
consumer making an ordinary telephone call.  Id. at 6956, para. 56.  The Commission also found that extending 
section 222s protections to interconnected VoIP service customers is necessary to protect the privacy of wireline 
and wireless customers who place calls to or receive calls from interconnected VoIP customers, insofar as CPNI of 
interconnected VoIP customers may include call information concerning both calling and called parties.  Id. at 
6956, para. 57.  The Commission determined that both elements for ancillary jurisdiction had been satisfied.  First, it 
reaffirmed its general subject matter jurisdiction over interconnected VoIP.  Second, it demonstrated that extending 
CPNI obligations to interconnected VoIP providers is necessary to the fulfillment of its duties to protect subscribers
private information under section 222 and to the fulfillment of its public safety duties under section 1, and, if the 
order motivates consumers to purchase additional interconnected VoIP services, could promote competition in the 
local telecommunications market.  Id. at 6957, para. 59.
338 2000 TRS Order, 15 FCC Rcd at 517375, paras. 7981.  Customer profile information refers to information 
gathered by a TRS provider to facilitate handling a call relating to a TRS users preferences regarding, among other 
things, the customers preferred interexchange carrier, blocking preferences, CA gender preferences, frequently 
dialed numbers for speed dialing, language preferences (English, American Sign Language, a foreign language), 
calling instructions, preferred CA typing speed, and so forth.  See id. at 5173, para. 77.
339 Id. at 5174, para. 79 (section 222 applies to telecommunications carriers only); see also 47 U.S.C.  222(a).
340 2000 TRS Order, 15 FCC Rcd at 5174, para. 79 (citing 47 U.S.C.  153(44) (defining telecommunications 
carrier), and 47 U.S.C.  153(46) (defining telecommunications service)).
341 Id.; see also 47 U.S.C.  222(a) (section 222 applies to telecommunications carriers).  In that order, the 
Commission did not consider whether it could assert its Title I ancillary jurisdiction to apply the CPNI requirements 
to TRS providers.
342 2000 TRS Order, 15 FCC Rcd at 5175, para. 83.
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Noting that the confidentiality of customer profile information is of paramount importance to TRS users 
and that unrestricted access to TRS user information would violate the reasonable privacy expectations
of relay users, the Commission concluded that TRS customer profile information shall not be used for 
any purpose other than to connect the TRS user, for whom the profile exists, with the called parties 
desired by that TRS user.343 The Commission further concluded that profile information shall not be 
sold, distributed, shared, or revealed in any way by the TRS provider or its employees, unless 
compelled to do so by lawful order or in compliance with our requirement regarding a change in 
vendor.344
138. The proper handling of TRS consumer information was subsequently addressed in the 
2005 TRS Marketing Practices PN,345 and in the recent Consumer Contacts Declaratory Ruling.346 In the 
2005 item, the Consumer & Governmental Affairs Bureau noted that apparently some providers use their 
customer database to contact prior users of their service and suggest, urge, or tell them to make more VRS
calls.347 The item concluded that this marketing practice constitutes an improper use of information 
obtained from consumers using the service, is inconsistent with the notion of functional equivalency, and 
may constitute a fraud on the Interstate TRS Fund because the Fund, and not the consumer, pays for the 
cost of the VRS call.348 Inasmuch as the purpose of TRS is to allow persons with certain disabilities to 
use the telephone system, the Bureau stated that entities offering TRS should not contact users of their 
service in order to encourage or require them to place more TRS calls; rather, the provider must be 
available to handle the calls that consumers choose to make.349
139. In the recent Consumer Contacts Declaratory Ruling, the Commission provided 
examples of permissible and prohibited uses of information derived from consumer or call databases 
established in conjunction with section 225 and clarified that, consistent with the Commissions rules and 
orders, providers may use information derived from such a database to contact users solely for purposes 
related to the handling of relay calls.350  Therefore, we explained that a provider reasonably could contact 
relay users (using TRS consumer or call database information) to inform users of a service outage, to 
respond to a consumers call for emergency services, to assist in the delivery of emergency services, or to 
provide technical support for TRS products or services used by the consumer.351 We further explained 
  
343 Id.
344 Id.
345 See FCC Clarifies that Certain TRS Marketing and Call Handling Practices are Improper, CC Docket No. 98-
67, CG Docket No. 03-123, Public Notice, 20 FCC Rcd 1471, 1473 (Jan. 26, 2005) (2005 TRS Marketing Practices 
PN).
346 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, Declaratory Ruling, CG Docket No. 03-123, FCC 08-138 (May 28, 2008) (Consumer Contacts
Declaratory Ruling).
347 See 2005 TRS Marketing Practices PN, 20 FCC Rcd at 1473.
348 Id. (internal footnotes omitted).
349 Id. In that same year, the Commission issued the VRS/IP Relay 911 NPRM.  In considering whether to adopt a 
proposed location registration requirement for VRS and IP Relay in that item, the Commission sought comment on 
what, if any, measures it should adopt to ensure the confidentiality of VRS and IP Relay users location information, 
assuming the adoption of such a requirement by the Commission.  VRS/IP Relay 911 NPRM, 20 FCC Rcd at 19485, 
para. 20.
350 Consumer Contacts Declaratory Ruling, FCC 08-138, para. 9.
351 Id.
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that providers may use customer data developed through participation in the TRS program to comply with 
a federal statute, a Commission rule or order, a court order, or other lawful authority.352  By contrast, 
we clarified that providers may not use consumer or call database information (or any other source of 
consumer information) to contact TRS consumers to offer financial or other incentives to generate 
additional or longer calls that can be billed to the Fund.353 Because a consumer or call database that a 
TRS provider develops and maintains through participation in the TRS program is inextricably tied to 
that federally funded program, we explained that the Commission may prohibit the use of a TRS 
consumer or call database for purposes unrelated to the handling of relay calls.354
140. Most recently, the Commission released the Numbering PN to refresh the record on 
numbering issues identified in the 2006 Interoperability Declaratory Ruling and FNPRM.355  Among 
other things, the Numbering PN requested comment on issues directly related to numbering, including 
application of the CPNI rules.356
141. Discussion. We seek comment on what, if any, specific actions the Commission should 
take to ensure the privacy and security of Internet-based TRS users personal information, including the 
information users provide in connection with the Registered Location requirement described in section 
III.C.  Comments addressing the issue of CPNI in response to the Numbering PN generally support 
extending the CPNI rules, or CPNI-like rules, to TRS providers in conjunction with the establishment of a 
ten-digit numbering plan.357 Only one party, however, in an ex parte submission filed after the close of 
the comment cycle, addresses with specificity how such rules would apply in the TRS context.358 In 
addition, none of the parties addresses whether or how the CPNI rules, if applied to TRS, would better 
serve the interests of TRS providers and TRS consumers than do the Commissions existing rules 
governing the use of TRS consumer or call database information, or how those provisions might 
interrelate.  Accordingly, we seek further comment on the specific issues set forth below.
142. Scope of Consumer Privacy Requirements. Assuming the Commission adopts additional 
safeguards governing the use and disclosure of TRS customer data, we seek comment on whether the new 
  
352 Id.
353 Id.
354 Id., para. 11.  We similarly clarified that the use of consumer or call database information acquired in the 
provision of federally subsidized TRS services for purposes of lobbying end users to support a service providers 
position before the Commission is likewise prohibited, as this purpose is not directly related to the purpose of 
handling relay calls.  Id.
355 Numbering PN; see also Interoperability Declaratory Ruling and FNPRM, 21 FCC Rcd at 545960, paras. 44
50 (seeking comment on the feasibility of establishing a global, uniform ten-digit telephone numbering system for 
VRS).
356 Id.
357 See, e.g., GoAmerica Refresh Reply Comments at 3 (stating that [a]ll commenters . . . agree that CPNI-like . . . 
rules are necessary as part of adopting a ten-digit numbering plan); CSDVRS Refresh Reply Comments at 5 
(support application of the Commissions CPNI rules to the universal numbering system); TDI Coalition Refresh 
Comments at 4 (Just as hearing users of telecommunications are entitled to the protections of the [CPNI rules], 
functional equivalency requires that TRS users should be entitled to the same CPNI protections . . . .).
358 Sorenson Rules Ex Parte at 2 (noting an attached redline of the CPNI rules showing the changes needed to 
extend those rules to protect users of [TRS], users who make point-to-point calls, and users who receive a ten-digit 
geographic NANP number from a TRS provider); cf. GoAmerica Refresh Comments at 20 (urging the Commission 
simply [to] amend section 64.2003(o) of its rules to include TRS providers as telecommunications carriers
subject to the Commissions CPNI rules for purposes of that subpart).
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rules should apply to all TRS providers, including traditional TTY-based providers, or only to VRS and 
IP Relay providers (or some other subset of TRS providers).  We also seek comment on whether the new 
rules should vary according to service type or whether the same rules should apply uniformly to all forms 
of TRS.
143. Extending the CPNI rules to TRS.  Assuming we apply the CPNI rules to TRS providers, 
we seek comment on whether we should modify the present CPNI rules in the TRS context and, if so, 
how.  Parties urging us to extend the application of our CPNI rules to TRS providers are asked to identify 
the specific CPNI rules they believe should apply, as well as any rule revisions that would be required to 
accommodate the unique nature of Internet-based TRS. In addition, we ask parties to comment on 
Sorensons proposed revisions to the CPNI rules in its May 15th ex parte submission.359 For example, we 
seek comment on the Commissions authority under section 225 to extend the CPNI protections, as 
suggested by Sorenson, to customers receiving point-to-point services, given the parameters established 
by section 225, under which TRS is designed to permit persons with hearing and speech disabilities to 
access the telephone system to call persons without such disabilities.360
144. In addition, if the Commission were to extend the CPNI rules to TRS, we seek comment 
on whether we may rely on our ancillary authority under Title I as the jurisdictional basis for doing so.  
As noted above, ancillary jurisdiction may be employed when Title I of the Act gives the Commission 
subject matter jurisdiction over the service to be regulated and the assertion of jurisdiction is reasonably 
ancillary to the effective performance of [its] various responsibilities.361  In the EPIC CPNI Order, the 
Commission used ancillary jurisdiction to extend the CPNI requirements of Title II to interconnected 
VoIP providers notwithstanding the fact that the Commission had not formally classified interconnected 
VoIP as a Title I information service or as a Title II telecommunications service within the meaning 
of the Act.362 Accordingly, assuming TRS is not a telecommunications service under the 
Communications Act definition, we seek comment on the use of ancillary jurisdiction to extend the 
application of the Commissions CPNI requirements to TRS providers.363
145. Interplay between CPNI requirements and existing restrictions on TRS customer data. If 
the Commission were to apply some or all of the CPNI requirements to TRS, we seek comment on how 
  
359 Sorenson Rules Ex Parte at 2 & Attach. 1 (proposing revisions to the CPNI rules).
360 47 U.S.C.  225(a)(3) (definition of TRS).  In its ex parte, Sorenson proposes to define point-to-point service 
as a video service that facilitates the transmission of non-relay calls in which a video end-user device (e.g., a 
videophone) connects to another such device via a ten-digit NANP number that has been assigned to the called 
device, allowing deaf, hard-of-hearing, speech-disabled, and other individuals to communicate directly in real-time 
via sign language without the assistance of an interpreter. Sorenson Rules Ex Parte, Attach. 1, at 2.
361 See United States v. Southwestern Cable Co., 392 U.S. 157, 17778 (1968).
362 EPIC CPNI Order, 22 FCC Rcd at 695457, paras. 5459.  In using ancillary jurisdiction to extend the 
Commissions CPNI rules to interconnected VoIP providers, the Commission found that:  (1) interconnected VoIP 
service is increasingly used to replace analog voice service, and that it is therefore reasonable for American 
consumers to expect that their calls will be private irrespective of whether they are using traditional telephone 
services or interconnected VoIP services; (2) because the CPNI of interconnected VoIP customers includes call 
histories to or from traditional phone service users, extending section 222s protection to interconnected VoIP 
service customers is necessary to protect the privacy of those traditional phone service users; and (3) applying the 
CPNI protections to interconnected VoIP providers may encourage customer migration to VoIP services and 
therefore spur technological development in the digital telephone realm.  Id. at 695657, paras. 5559.
363 Because the question of the proper classification of particular services as telecommunications services or 
information services under the Communications Act is beyond the scope of this proceeding, we examine our 
authority to extend the application of the CPNI rules to TRS only under our Title I ancillary authority.
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best to reconcile the CPNI rules with the existing TRS restrictions on TRS providers use of customer 
database information.  The Commission has repeatedly stated that TRS customer data may not be used for 
any purpose other than the provision of TRS.364 The Commission has also emphasized that, given that the 
obligation placed on TRS providers is to be available to handle calls consumers choose to make, when 
they choose to make them, i.e., to be the dial tone for a consumer that uses relay to call to a voice 
telephone user, and because consumers do not pay for this service but rather providers are compensated 
pursuant to Title IV of the ADA, providers may not offer relay users financial and similar incentives, 
directly or indirectly, to use their service.365 In contrast, section 64.2005(a) of the Commissions CPNI 
rules permits a carrier to use, disclose, or permit access to CPNI for the purpose of providing or 
marketing service offerings among the categories of service to which the customer already subscribes 
from the carrier,366 and section 64.2005(c)(3) permits the use or disclosure of CPNI to market services 
formerly known as adjunct-to-basic services.367 In light of these and other differences between TRS, 
where there traditionally has been no subscription agreement and consumers do not pay for the service, 
and other market-based communications services that are paid for by the consumer, we seek comment on 
whether, in the TRS context, we should apply CPNI requirements that permit the use or disclosure of 
personally identifiable consumer information for marketing purposes and, if so, whether this action is 
consistent with the Commissions existing TRS requirements. We also seek comment on how replacing 
existing protections with CPNI requirements would affect the privacy of TRS consumers with regard to 
customer profile information; specifically, would any data protected by the current rules not fall under the 
definition of CPNI?  Would extending the CPNI rules to cover TRS impede the provision of TRS?
146. We also seek comment on the comparative advantages and disadvantages of applying the 
CPNI rules to TRS providers, as opposed to expanding the existing TRS requirements governing 
permissible uses of database information to encompass any additional types of customer information (e.g., 
Registered Location information) that may be generated as a result of the numbering and registration 
measures we adopt today. Under either approach, we seek comment on whether our rules should require 
express consumer consent before a TRS provider may disclose customer records of a TRS user to third 
parties or to any specific type of third-party entity. Commenters are also asked to identify any additional 
protections or safeguards they believe are needed to ensure the privacy and security of TRS customer data 
in light of the numbering and Registered Location measures that we adopt above.  For example, should 
Internet-based TRS providers be required to remove all personally identifiable consumer information for
Registered Internet-based TRS Users that select a different default provider?  In addition, we ask 
commenters to describe any systems providers have in place currently to safeguard personally identifiable 
information of TRS users and indicate the degree to which those systems have succeeded in protecting 
consumers from unauthorized disclosure of personally identifiable customer data.
14. Cost Recovery Issues
147. As outlined above, we conclude that Internet-based TRS providers may seek 
compensation from the Fund for their actual reasonable costs of complying with the new requirements 
  
364 See, e.g., 2000 TRS Order, 15 FCC Rcd at 5175, para. 83 (stating that customer profile information shall not be 
used for any purpose other than to connect the TRS user, for whom the profile exists, with the called parties 
[identified] by that TRS user).
365 2007 TRS Rate Methodology Order, 22 FCC Rcd at 2017375, paras. 8994 (internal footnotes omitted); see 
also Consumer Contacts Declaratory Ruling, FCC 08-138, para. 13.
366 47 C.F.R.  64.2005(a).
367 47 C.F.R.  64.2005(c)(3).  Such adjunct-to-basic services may include, among others, speed dialing, 
computer-provided directory assistance, call monitoring, call tracing, call blocking, call return, repeat dialing, call 
tracking, call waiting, caller I.D., call forwarding, and certain centrex features.  Id.
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adopted in the foregoing Order. We have not included, however, those costs directly related to 
consumers acquiring a number or to the costs associated with number portability.  Because these costs 
generally are borne by voice telephone users,368 we seek comment on whether Internet-based TRS users 
acquiring ten-digit numbers should also bear these costs.
148. We note that although section 225 creates a cost recovery regime for the costs of 
providing relay, it also mandates that the Commissions regulations shall require that users of [TRS] pay 
rates no greater than the rates paid for functionally equivalent voice communication services with respect 
to such factors as the duration of the call, the time of day, and the distance from point of origination to 
point of termination.369 Congress therefore contemplated that TRS consumers would pay some costs 
associated with making a telephone call, just not those additional costs attributed to the use of a relay 
service to facilitate the call.
149. We therefore seek comment on whether, and to what extent, the costs of acquiring 
numbers, including porting fees, should be passed on to the Internet-based TRS users, and not paid for by 
the Fund. We note that because Internet-based TRS users will now have a default provider  e.g., the 
provider from which they obtained their number or a provider to which they ported their number  that 
provider can pass the costs of acquiring the number, or of porting the number, to the consumer.  We also 
seek comment on whether there are other specific costs that result from the requirements adopted in the 
Order that, mirroring voice telephone consumers, should be passed on to consumers, including, for 
example, E911 charges.
V. PROCEDURAL MATTERS
150. Comments and Reply Comments.  Pursuant to Sections 1.415 and 1.419 of the 
Commissions rules, 47 C.F.R.  1.415, 1.419, interested parties may file comments and reply comments 
on or before the dates indicated on the first page of this document.  Comments may be filed using:  (1) the 
Commissions Electronic Comment Filing System (ECFS), (2) the Federal Governments eRulemaking 
Portal, or (3) by filing paper copies.370 For additional information on this proceeding, please contact
Thomas Chandler in the Consumer & Governmental Affairs Bureau, at (202) 418-1475.
 Electronic Filers:  Comments may be filed electronically using the Internet by accessing the 
ECFS: http://www.fcc.gov/cgb/ecfs/ or the Federal eRulemaking Portal:  
http://www.regulations.gov.  Filers should follow the instructions provided on the website for 
submitting comments.  
 For ECFS filers, if multiple docket or rulemaking numbers appear in the caption of this 
proceeding, filers must transmit one electronic copy of the comments for each docket or 
rulemaking number referenced in the caption.  In completing the transmittal screen, filers 
should include their full name, U.S. Postal Service mailing address, and the applicable 
docket or rulemaking number.  Parties may also submit an electronic comment by 
Internet e-mail.  To get filing instructions, filers should send an e-mail to ecfs@fcc.gov, 
and include the following words in the body of the message, get form. A sample form 
and instructions will be sent in response.  
 Paper Filers:  Parties who choose to file by paper must file an original and four copies of each 
  
368 47 C.F.R.  52.17, 52.32 (requiring carrier contributions to support numbering administration and number 
portability); 47 C.F.R.  52.33 (setting forth method by which carriers may recover number portability costs).
369 47 U.S.C.  225(d)(1)(D).
370 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13 
FCC Rcd 11322, 11326, para. 8 (Apr. 6, 1998).
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filing.  If more than one docket or rulemaking number appears in the caption of this 
proceeding, filers must submit two additional copies for each additional docket or rulemaking 
number.  
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by 
first-class or overnight U.S. Postal Service mail (although we continue to experience delays 
in receiving U.S. Postal Service mail). All filings must be addressed to the Commissions 
Secretary, Office of the Secretary, Federal Communications Commission.
 The Commissions contractor will receive hand-delivered or messenger-delivered paper 
filings for the Commissions Secretary at 236 Massachusetts Avenue NE, Suite 110, 
Washington, D.C. 20002.  The filing hours at this location are 8:00 a.m. to 7:00 p.m.  All 
hand deliveries must be held together with rubber bands or fasteners.  Any envelopes 
must be disposed of before entering the building.
 Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority 
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.  
 U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th 
Street SW, Washington, D.C. 20554. 
151. People with Disabilities: To request materials in accessible formats for people with 
disabilities (Braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call 
the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice) or 202-418-0432 (TTY).  This 
Report and Order and Further Notice of Proposed Rulemaking can also be downloaded in Word and 
Portable Document Formats (PDF) at http://www.fcc.gov/cgb.dro.
152. Comments and reply comments must include a short and concise summary of the 
substantive discussion and questions raised in the Further Notice.  We further direct all interested parties 
to include the name of the filing party and the date of the filing on each page of their comments and reply 
comments.  We strongly encourage that parties track the organization set forth in this Further Notice in 
order to facilitate our internal review process.  Comments and reply comments must otherwise comply 
with section 1.49 and all other applicable sections of the Commissions rules.371
153. Ex Parte Rules. This matter shall be treated as a permit-but-disclose proceeding in 
accordance with the Commissions ex parte rules.372 Persons making oral ex parte presentations are 
reminded that memoranda summarizing the presentations must contain summaries of the substance of the 
presentations and not merely a listing of the subjects discussed.  More than a one or two sentence 
description of the views and arguments presented is generally required.373 Other requirements pertaining 
to oral and written presentations are set forth in section 1.1206(b) of the Commissions rules.
154. Regulatory Flexibility Certifications.  As required by the Regulatory Flexibility Act of 
1980 (RFA),374 the Commission has prepared a Final Regulatory Flexibility Certification in which it 
concludes that, under the terms of the RFA, there is no significant economic impact on small entities of 
the policies and rules addressed in this document.  The certification is set forth in Appendix C.
  
371 See 47 C.F.R.  1.49.
372 47 C.F.R.  1.200 et seq.
373 See 47 C.F.R.  1.1206(b)(2).
374 See 5 U.S.C.  604.
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155. As required by the RFA,375 the Commission also has prepared an Initial Regulatory 
Flexibility Certification of the possible significant economic impact on small entities of the policies and 
rules addressed in this document.  The certification is set forth in Appendix D.
156. Paperwork Reduction Act.  The Report and Order contains new or modified information 
collection requirements.  The Commission, as part of its continuing effort to reduce paperwork burdens, 
invites the general public and the Office of Management and Budget (OMB) to comment on the 
information collection requirements contained in this document, as required by the Paperwork Reduction 
Act of 1995 (PRA), Public Law 104-13.  Public and agency comments are due 60 days after the date of 
publication of this document in the Federal Register.  Comments should address: (a) whether the 
proposed collection of information is necessary for the proper performance of the functions of the 
Commission, including whether the information shall have practical utility; (b) the accuracy of the 
Commissions burden estimates; (c) ways to enhance the quality, utility, and clarity of the information 
collected; and (d) ways to minimize the burden of the collection of information on the respondents, 
including the use of automated collection techniques or other forms of information technology.
157. In addition, pursuant to the Small Business Paperwork Relief Act of 2002,376 we seek
specific comment on how we might further reduce the information collection burden for small business 
concerns with fewer than 25 employees.
158. In this present document, we have assessed the effects of imposing a requirement that 
Internet-based TRS providers implement a plan for assigning ten-digit, NANP telephone numbers to 
Registered Internet-based TRS Users.  We have taken steps to minimize the information collection burden 
for small business concerns, including those with fewer than 25 employees.  For example, in requiring 
that providers obtain users Registered Location, the Order allows providers to comply with this 
requirement directly or by utilizing the services of a third party.  The Commission also requires Internet-
based TRS providers to include an advisory on their websites and in any promotional materials addressing
the new requirements adopted in this Order.  The Commission believes that posting this information on 
provider websites and including it in any promotional materials that are directed to consumers should 
entail minimal burden and will prove critical to ensuring that consumers receive timely and complete 
information concerning the transition to a ten-digit numbering system and that consumers are aware of the 
need to submit accurate Registered Location information for the proper routing of emergency calls.  The 
Commission also finds that allowing providers until December 31, 2008, to implement the Registered 
Location requirement and other requirements adopted herein, under which providers must obtain or have 
access to consumer location information, as well as current routing information for their registered users, 
is a reasonable timeframe for both large and small providers. Finally, the Commission concludes that all 
Internet-based TRS providers, including small entities, will be eligible to receive compensation from the 
Interstate TRS Fund for their reasonable costs of complying with the numbering and registration 
requirements adopted in the Order.  These measures should substantially alleviate any burdens on 
businesses with fewer than 25 employees.
159. Congressional Review Act.  The Commission will send a copy of this Report and Order 
and Further Notice of Proposed Rulemaking in a report to be sent to Congress and the Government 
Accountability Office pursuant to the Congressional Review Act.377
  
375 See 5 U.S.C.  603.
376 Public Law 107-198, see 44 U.S.C.  3506(c)(4).
377 See 5 U.S.C.  801(a)(1)(A).
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VI. ORDERING CLAUSES
160. Accordingly, IT IS ORDERED that, pursuant to sections 1, 2, 4(i), 4(j), 225, 251, and 
303(r) of the Communications Act of 1934, as amended, 47 U.S.C.  151, 152, 154(i), 154(j), 225, 251, 
303(r), this Report and Order and Further Notice of Proposed Rulemaking IS ADOPTED.
161. IT IS FURTHER ORDERED that, pursuant to sections 1, 2, 4(i), 4(j), 225, 251, and 
303(r) of the Communications Act of 1934, as amended, 47 U.S.C.  151, 152, 154(i), 154(j), 225, 251, 
303(r), Parts 52 and 64 of the Commissions rules, 47 C.F.R. Parts 52, 64, ARE AMENDED, as set forth 
in Appendix B.
162. IT IS FURTHER ORDERED that this Report and Order and Further Notice of Proposed 
Rulemaking shall become effective 30 days after publication in the Federal Register, and all requirements 
set forth herein must be implemented by December 31, 2008, except for the information collections, 
which require approval by OMB under the PRA and which shall become effective after the Commission 
publishes a notice in the Federal Register announcing such approval and the relevant effective date(s).
163. IT IS FURTHER ORDERED that the Commissions Consumer & Governmental Affairs 
Bureau, Reference Information Center, SHALL SEND a copy of this Report and Order, including the 
Final Regulatory Flexibility Certification, to the Chief Counsel for Advocacy of the Small Business 
Administration.
164. IT IS FURTHER ORDERED that the Commissions Consumer & Governmental Affairs 
Bureau, Reference Information Center, SHALL SEND a copy of this Further Notice of Proposed 
Rulemaking, including the Initial Regulatory Flexibility Certification, to the Chief Counsel for Advocacy 
of the Small Business Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary
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APPENDIX A
List of Commenters
Consumer & Governmental Affairs Bureau Seeks to Refresh Record on Assigning Internet Protocol 
(IP)-Based Telecommunications Relay Service (TRS) Users Ten-Digit Telephone Numbers Linked to 
North American Numbering Plan (NANP) and Related Issues, CG Docket No. 03-123, Public Notice, 
23 FCC Rcd 4727 (Mar. 19, 2008)
Commenter/Date Filed Abbreviation
AT&T (Apr. 8, 2008) AT&T
Communication Service for the Deaf/CSDVRS (Apr. 8, 2008) CSDVRS
Dash Carrier Services (Apr. 8, 2008) Dash
GoAmerica/Hands On Video Relay Services (Apr. 8, 2008) GoAmerica
Interstate TRS Advisory Council (Apr. 8, 2008) TRS Advisory Council
Nebraska Public Service Commission (Apr. 8, 2008) Nebraska PSC
NeuStar (Apr. 8, 2008) NeuStar
Sorenson Communications, Inc. (Apr. 8, 2008) Sorenson
Sprint Nextel Corporation (Apr. 8, 2008) Sprint Nextel
Telecommunications for the Deaf and Hard of Hearing, Inc., TDI Coalition
Association of Late-Deafened Adults, Inc., 
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; California Coalition of Agencies
Serving the Deaf and Hard of Hearing (Apr. 8, 2008)
Reply Commenter/Date Filed Abbreviation
Alexander Graham Bell Association for the Deaf AG Bell
and Hard of Hearing (Apr. 18, 2008)
American Association of People with Disabilities (Apr. 18, 2008) AAPD
AT&T (Apr. 18, 2008) AT&T
Communication Access Center for the Deaf and Hard of Hearing CAC
(Apr. 18, 2008)
Communication Service for the Deaf/CSDVRS (Apr. 18, 2008) CSDVRS
Dash Carrier Services (Apr. 18, 2008) Dash
GoAmerica/Hands On Video Relay Services (Apr. 18, 2008) GoAmerica
National Emergency Number Association (Apr. 18, 2008) NENA
NeuStar (Apr. 18, 2008) NeuStar
Sonny Access Consulting (Apr. 18, 2008) Sonny
Sorenson Communications, Inc. (Apr. 18, 2008) Sorenson
Telecommunications for the Deaf and Hard of Hearing, Inc., TDI Coalition
Association of Late-Deafened Adults, Inc.,
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; California Coalition of Agencies
Serving the Deaf and Hard of Hearing (Apr. 18, 2008)
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Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing 
Disabilities, CG Docket No. 03-123, Declaratory Ruling and Further Notice of Proposed 
Rulemaking, 21 FCC Rcd 5442 (May 9, 2006)
Commenter/Date Filed Abbreviation
AT&T, Inc. (July 17, 2006) AT&T
Communication Service for the Deaf (July 17, 2006) CSD
Hands On Video Relay Services, Inc. (July 17, 2006) Hands On
Snap Telecommunications, Inc. (July 17, 2006) Snap
Sorenson Communications, Inc. (July 17, 2006) Sorenson
Sprint Nextel Corporation (July 17, 2006) Sprint Nextel
Telecommunications for the Deaf and Hard of Hearing, Inc.; TDI Coalition
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; and California Coalition of
Agencies Serving the Deaf and Hard of Hearing (July 17, 2006)
Verizon (July 17, 2006) Verizon
Reply Commenter/Date Filed Abbreviation
AT&T, Inc. (July 31, 2006) AT&T
Hands On Video Relay Services, Inc. (July 31, 2006) Hands On
Neustar, Inc. (July 31, 2006) Neustar
Snap Telecommunications, Inc. (July 31, 2006) Snap
Sorenson Communications, Inc. (July 31, 2006) Sorenson
Telecommunications for the Deaf and Hard of Hearing, Inc.; TDI Coalition
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; and California Coalition of
Agencies Serving the Deaf and Hard of Hearing (July 31, 2006)
Verizon (July 31, 2006) Verizon
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, CG Docket No. 03-123, Further Notice of Proposed Rulemaking, 21 FCC Rcd 
5478 (May 8, 2006)
Commenter/Date Filed Abbreviation
Alliance for Telecommunications Industry Solutions (July 3, 2006) ATIS
AT&T, Inc. (July 3, 2006) AT&T
Country Boy Trailers (June 1, 2006) Country Boy Trailers
Communication Service for the Deaf (June 28, 2006) CSD
Hamilton Relay, Inc. (July 6, 2006) Hamilton
Sorenson Communications, Inc. (July 3, 2006) Sorenson
Sprint Nextel Corporation (July 3, 2006) Sprint Nextel
Telecommunications for the Deaf and Hard of Hearing, Inc.; TDI Coalition
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; and California Coalition of
Agencies Serving the Deaf and Hard of Hearing (July 3, 2006)
Verizon (July 3, 2006) Verizon
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Reply Commenter/Date Filed Abbreviation
Hamilton Relay, Inc. (July 14, 2006) Hamilton
Sorenson Communications, Inc. (July 17, 2006) Sorenson
Telecommunications for the Deaf and Hard of Hearing, Inc.; TDI Coalition
National Association of the Deaf; Deaf and Hard of Hearing
Consumer Advocacy Network; and California Coalition of
Agencies Serving the Deaf and Hard of Hearing (July 17, 2006)
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, CG Docket No. 03-123, Notice of Proposed Rulemaking, 20 FCC Rcd 19476 
(Nov. 30, 2005)
Commenter/Date Filed Abbreviation
Communication Access Center (Feb. 22, 2006) CAC
Communication Service for the Deaf (Feb. 22, 2006) CSD
Hamilton Relay, Inc. (Feb. 22, 2006) Hamilton
National Association of the Deaf (Feb. 22, 2006) NAD
New Jersey Division of the Ratepayer Advocate (Feb. 22, 2006) NJ Ratepayer
Rehabilitation Engineering Research Center RERC
on Telecommunications Access (Feb. 22, 2006)
Sorenson Communications, Inc. (Feb. 22, 2006) Sorenson
Sprint Nextel Corporation (Feb. 22, 2006) Sprint Nextel
Telecommunications for the Deaf, Inc. (Feb. 22, 2006) TDI
Verizon (Feb. 22, 2006) Verizon
Reply Commenter/Date Filed Abbreviation
Hands On Video Relay Services, Inc. (Mar. 8, 2006) Hands On
Intrado (Mar. 8, 2006) Intrado
National Emergency Number Association (Mar. 8, 2006) NENA
New Jersey Division of the Ratepayer Advocate (Mar. 8, 2006) NJ Ratepayer
Sorenson Communications, Inc. (Mar. 8, 2006) Sorenson
TDI and NorCal Center on Deafness (Mar. 8, 2006) TDI & NorCal
Texas 9-1-1 Alliance and Texas Commission on Texas911 Alliance
State Emergency Communications (Mar. 8, 2006)
Verizon (Mar. 8, 2006) Verizon
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APPENDIX B
Final Rule Changes
Part 52 of Title 47 of the Code of Federal Regulations is amended as follows:
PART 52  NUMBERING
1.  The authority citation for part 52 continues to read as follows:
Authority:  Secs. 1, 2, 4, 5, 48 Stat. 1066, as amended; 47 U.S.C. 151, 152, 154 and 155 unless 
otherwise noted. Interpret or apply secs. 3, 4, 20105, 20709, 218, 22527, 25152, 271 and 332, 
48 Stat. 1070, as amended, 1077; 47 U.S.C. 153, 154, 20105, 20709, 218, 22527, 25152, 271 
and 332 unless otherwise noted.
2.  Section 52.21 is amended by redesignating paragraphs (i) through (n) as paragraphs (j) through (o), 
redesignating paragraphs (o) through (s) as paragraphs (q) through (u), and adding new paragraphs (i),
(p), and (v) to read as follows:
* * * * *
(i) The term IP Relay provider means an entity that provides IP Relay as defined by 47 C.F.R. 
 64.601.
* * * * *
(p) The term Registered Internet-based TRS User has the meaning set forth in 47 C.F.R.  64.601.
* * * * *
(v) The term VRS provider means an entity that provides VRS as defined by 47 C.F.R.  64.601.
* * * * *
3.  Section 52.34 is amended to read as follows:
 52.34 Obligations regarding local number porting to and from interconnected VoIP or 
Internet-based TRS providers.
(a) An interconnected VoIP or VRS or IP Relay provider must facilitate an end-user customers or a 
Registered Internet-based TRS Users valid number portability request, as it is defined in this subpart, 
either to or from a telecommunications carrier or an interconnected VoIP or VRS or IP Relay
provider.  Facilitate is defined as the interconnected VoIP or VRS or IP Relay providers 
affirmative legal obligation to take all steps necessary to initiate or allow a port-in or port-out itself or 
through the telecommunications carriers, if any, that it relies on to obtain numbering resources, 
subject to a valid port request, without unreasonable delay or unreasonable procedures that have the 
effect of delaying or denying porting of the NANP-based telephone number.
(b) An interconnected VoIP or VRS or IP Relay provider may not enter into any agreement that 
would prohibit an end-user customer or a Registered Internet-based TRS User from porting between 
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interconnected VoIP or VRS or IP Relay providers, or to or from a telecommunications carrier.
Part 64 of the Code of Federal Regulations is amended as follows:
PART 64  MISCELLANEOUS RULES RELATING TO COMMON CARRIERS
1.  The authority citation for part 64 continues to read as follows:
Authority:  47 U.S.C. 154, 254(k); secs. 403 (b)(2)(B), (C), Public Law 104-104, 110 Stat. 56.  
Interpret or apply 47 U.S.C. 201, 218, 225, 226, 228, and 254(k) unless otherwise noted.
2.  Section 64.601 is amended by redesignating paragraphs (a)(3) through (a)(9) as paragraphs (a)(4) 
through (a)(10), redesignating paragraph (a)(10) as paragraph (a)(14), redesignating paragraph (a)(11) as 
paragraph (a)(16), deleting paragraph (a)(12), redesignating paragraphs (a)(13) through (a)(17) as 
paragraphs (a)(19) through (a)(23), redesignating paragraphs (a)(18) and (a)(19) as (a)(26) and (a)(27), 
and by amending subsection (a) and adding new paragraphs (a)(3), (a)(11) through (a)(13), (a)(15), 
(a)(17), (a)(18), (a)(24), and (a)(25) to read as follows:
(a) For purposes of this subpart, the terms Public Safety Answering Point (PSAP), statewide default 
answering point, and appropriate local emergency authority are defined in 47 C.F.R.  64.3000; the 
terms pseudo-ANI and Wireline E911 Network are defined in 47 C.F.R.  9.3; the term affiliate is defined 
in 47 C.F.R.  52.12(a)(1)(i), and the terms majority and debt are defined in 47 C.F.R.  52.12(a)(1)(ii).  
* * *
* * * * *
(3) ANI.  For 911 systems, the Automatic Number Identification (ANI) identifies the calling party and 
may be used as the callback number.
* * * * *
(11) Internet-based TRS.  A telecommunications relay service (TRS) in which an individual with a 
hearing or a speech disability connects to a TRS communications assistant using an Internet Protocol-
enabled device via the Internet, rather than the public switched telephone network. Internet-based 
TRS does not include the use of a text telephone (TTY) over an interconnected voice over Internet 
Protocol service.
(12) Internet Protocol Captioned Telephone Service (IP CTS).  A telecommunications relay service 
that permits an individual who can speak but who has difficulty hearing over the telephone to use a 
telephone and an Internet Protocol-enabled device via the Internet to simultaneously listen to the 
other party and read captions of what the other party is saying.  With IP CTS, the connection carrying 
the captions between the relay service provider and the relay service user is via the Internet, rather 
than the public switched telephone network.
(13) Internet Protocol Relay Service (IP Relay).  A telecommunications relay service that permits an 
individual with a hearing or a speech disability to communicate in text using an Internet Protocol-
enabled device via the Internet, rather than using a text telephone (TTY) and the public switched 
telephone network.
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* * * * *
(15) Numbering Partner. Any entity with which an Internet-based TRS provider has entered into a 
commercial arrangement to obtain North American Numbering Plan telephone numbers.
* * * * *
(17) Registered Location.  The most recent information obtained by a VRS or IP Relay provider that 
identifies the physical location of an end user.
(18) Registered Internet-based TRS User.  An individual that has registered with a VRS or IP Relay
provider as described in section 64.611.
* * * * *
(24) TRS Numbering Administrator.  The neutral administrator of the TRS Numbering Directory
selected based on a competitive bidding process.
(25) TRS Numbering Directory.  The database administered by the TRS Numbering Administrator, 
the purpose of which is to map each Registered Internet-based TRS Users NANP telephone number 
to his or her end device.
* * * * *
3.  Section 64.605 is amended to read as follows:
 64.605  Emergency Calling Requirements
(a) Additional Emergency Calling Requirements Applicable to Internet-based TRS Providers.
(1) As of December 31, 2008, the requirements of paragraphs (a)(2)(i) and (a)(2)(iv) of this section 
shall not apply to providers of VRS and IP Relay.
(2) Each provider of Internet-based TRS shall:
(i) Accept and handle emergency calls and access, either directly or via a third party, a 
commercially available database that will allow the provider to determine an appropriate PSAP, 
designated statewide default answering point, or appropriate local emergency authority that 
corresponds to the callers location, and to relay the call to that entity;
(ii) Implement a system that ensures that the provider answers an incoming emergency call before 
other non-emergency calls (i.e., prioritize emergency calls and move them to the top of the 
queue);
(iii) Request, at the beginning of each emergency call, the callers name and location information, 
unless the Internet-based TRS provider already has, or has access to, a Registered Location for 
the caller;
(iv) Deliver to the PSAP, designated statewide default answering point, or appropriate local 
emergency authority, at the outset of the outbound leg of an emergency call, at a minimum, the 
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name of the relay user and location of the emergency, as well as the name of the relay provider, 
the CAs callback number, and the CAs identification number, thereby enabling the PSAP, 
designated statewide default answering point, or appropriate local emergency authority to re-
establish contact with the CA in the event the call is disconnected;
(v) In the event one or both legs of an emergency call are disconnected (i.e., either the call 
between the TRS user and the CA, or the outbound voice telephone call between the CA and the 
PSAP, designated statewide default answering point, or appropriate local emergency authority), 
immediately re-establish contact with the TRS user and/or the appropriate PSAP, designated 
statewide default answering point, or appropriate local emergency authority and resume handling 
the call; and 
(vi) Ensure that information obtained as a result of this section is limited to that needed to 
facilitate 911 services, is made available only to emergency call handlers and emergency response 
or law enforcement personnel, and is used for the sole purpose of ascertaining a users location in 
an emergency situation or for other emergency or law enforcement purposes.
(b) E911 Service for VRS and IP Relay
(1) Scope. The following requirements are only applicable to providers of VRS or IP Relay.  Further, 
the following requirements apply only to 911 calls placed by users whose Registered Location is in a 
geographic area served by a Wireline E911 Network.
(2) E911 Service. As of December 31, 2008:
(i) VRS or IP Relay providers must, as a condition of providing service to a user, provide that 
user with E911 service as described in this section;
(ii) VRS or IP Relay providers must transmit all 911 calls, as well as ANI, the callers Registered 
Location, the name of the VRS or IP Relay provider, and the CAs identification number for each 
call, to the PSAP, designated statewide default answering point, or appropriate local emergency 
authority that serves the callers Registered Location and that has been designated for 
telecommunications carriers pursuant to 64.3001 of this chapter, provided that all 911 calls is 
defined as any communication initiated by a VRS or IP Relay user dialing 911;
(iii) All 911 calls must be routed through the use of ANI and, if necessary, pseudo-ANI, via the 
dedicated Wireline E911 Network; and
(iv) The Registered Location, the name of the VRS or IP Relay provider, and the CAs 
identification number must be available to the appropriate PSAP, designated statewide default 
answering point, or appropriate local emergency authority from or through the appropriate 
automatic location information (ALI) database.
(3) Service Level Obligation. Notwithstanding the provisions in paragraph (b)(2) of this section, if a 
PSAP, designated statewide default answering point, or appropriate local emergency authority is not 
capable of receiving and processing either ANI or location information, a VRS or IP Relay provider 
need not provide such ANI or location information; however, nothing in this paragraph affects the 
obligation under paragraph (c) of this section of a VRS or IP Relay provider to transmit via the 
Wireline E911 Network all 911 calls to the PSAP, designated statewide default answering point, or 
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appropriate local emergency authority that serves the callers Registered Location and that has been 
designated for telecommunications carriers pursuant to 64.3001 of this chapter.
(4) Registered Location Requirement. As of December 31, 2008, VRS and IP Relay providers must:
(i) Obtain from each Registered Internet-based TRS User, prior to the initiation of service, the 
physical location at which the service will first be utilized; and
(ii) If the VRS or IP Relay is capable of being used from more than one location, provide their 
Registered Internet-based TRS Users one or more methods of updating their Registered Location, 
including at least one option that requires use only of the CPE necessary to access the VRS or IP 
Relay. Any method utilized must allow a Registered Internet-based TRS User to update the 
Registered Location at will and in a timely manner.
4.  Section 64.611 is added to read as follows:
 64.611 Internet-Based TRS Registration
(a) Default Provider Registration.  Every provider of VRS or IP Relay must, no later than December 31, 
2008, provide users with the capability to register with that VRS or IP Relay provider as a default 
provider.  Upon a users registration, the VRS or IP Relay provider shall:
(1) Either:
(i) Facilitate the users valid number portability request as set forth in 47 C.F.R.  52.34; or
(ii) If the user does not wish to port a number, assign that user a geographically appropriate North 
American Numbering Plan telephone number; and
(2) Route and deliver all of that users inbound and outbound calls unless the user chooses to place a 
call with, or receives a call from, an alternate provider.
(b) Mandatory Registration of New Users.  As of December 31, 2008, VRS and IP Relay providers must, 
prior to the initiation of service for an individual that has not previously utilized VRS or IP Relay, register 
that new user as described in paragraph (a) of this section.
(c) Obligations of Default Providers and Former Default Providers.
(1) Default providers must:
(i) Obtain current routing information, including IP addresses or domain names and user names, 
from their Registered Internet-based TRS Users;
(ii) Provision such information to the TRS Numbering Directory; and
(iii) Maintain such information in their internal databases and in the TRS Numbering Directory.  
(2) Internet-based TRS providers (and, to the extent necessary, their Numbering Partners) must:
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(i) Take such steps as are necessary to cease acquiring routing information from any VRS or IP 
Relay user that ports his or her number to another VRS or IP Relay provider or otherwise selects 
a new default provider; and
(ii) Communicate among themselves as necessary to ensure that:
(A) Only the default provider provisions routing information to the central database; and
(B) VRS and IP Relay providers other than the default provider are aware that they must 
query the TRS Numbering Directory in order to obtain accurate routing information for a 
particular user of VRS or IP Relay.
(d) Proxy Numbers.  After December 31, 2008, a VRS or IP Relay provider:
(1) May not assign or issue a proxy or alias for a NANP telephone number to any user; and
(2) Must cease to use any proxy or alias for a NANP telephone number assigned or issued to any
Registered Internet-based TRS User.
(e) Customer Premises Equipment (CPE).
(1) Every VRS or IP Relay provider must ensure that all CPE they have issued, leased, or otherwise 
provided to VRS or IP Relay users delivers routing information or other information only to the 
users default provider, except as is necessary to complete or receive dial around calls on a case-by-
case basis.
(2) All CPE issued, leased, or otherwise provided to VRS or IP Relay users by Internet-based TRS 
providers must be capable of facilitating the requirements of this section.
(f) User Notification. Every VRS or IP Relay provider must include an advisory on its website and in any 
promotional materials addressing numbering or E911 services for VRS or IP Relay.
(1) At a minimum, the advisory must address the following issues:  (i) the process by which VRS or 
IP Relay users may obtain ten-digit telephone numbers, including a brief summary of the numbering 
assignment and administration processes; (ii) the portability of ten-digit telephone numbers assigned 
to VRS or IP Relay users; (iii) the process by which persons using VRS or IP Relay may submit, 
update, and confirm receipt by the provider of their Registered Location information; and (iv) an 
explanation emphasizing the importance of maintaining accurate, up-to-date Registered Location 
information with the users default provider in the event that the individual places an emergency call 
via VRS or IP Relay.
(2) VRS and IP Relay providers must obtain and keep a record of affirmative acknowledgement by 
every Registered Internet-based TRS User of having received and understood the advisory described 
in this subsection.
5.  Section 64.613 is added to read as follows:
 64.613 Numbering Directory for Registered Internet-based TRS Users
(a) TRS Numbering Directory.
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(1) The TRS Numbering Directory shall contain records mapping the NANP telephone number of 
each Registered Internet-based TRS User to a unique Uniform Resource Identifier (URI).
(2) For each record associated with a VRS user, the URI shall contain the users Internet Protocol (IP) 
address.  For each record associated with an IP Relay user, the URI shall contain the users user name 
and domain name that can be subsequently resolved to reach the user.
(3) Only the TRS Numbering Administrator and Internet-based TRS providers may access the TRS 
Numbering Directory.
(b) Administration.
(1) Neutrality.
(A) The TRS Numbering Administrator shall be a non-governmental entity that is impartial and 
not an affiliate of any Internet-based TRS provider.
(B) Neither the TRS Numbering Administrator nor any affiliate may issue a majority of its debt 
to, nor derive a majority of its revenues from, any Internet-based TRS provider.
(C) Nor may the TRS Numbering Administrator nor any affiliate be unduly influenced, as 
determined by the North American Numbering Council, by parties with a vested interest in the 
outcome of TRS-related numbering administration and activities.
(D) Any subcontractor that performs any function of the TRS Numbering Administrator must 
also meet these neutrality criteria.
(2) Terms of Administration.  The TRS Numbering Administrator shall administer the TRS 
Numbering Directory pursuant to the terms of its contract.
(3) Compensation.  The TRS Fund, as defined by 47 C.F.R.  64.604(a)(5)(iii), may compensate the 
TRS Numbering Administrator for the reasonable costs of administration pursuant to the terms of its 
contract.
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APPENDIX C
Final Regulatory Flexibility Certification
1. The Regulatory Flexibility Act of 1980, as amended (RFA),1 requires that a regulatory 
flexibility analysis be prepared for rulemaking proceedings, unless the agency certifies that the rule will 
not, if promulgated, have a significant economic impact on a substantial number of small entities.2 The 
RFA generally defines small entity as having the same meaning as the terms small business, small 
organization, and small governmental jurisdiction.3 In addition, the term small business has the 
same meaning as the term small business concern under the Small Business Act.4 A small business 
concern is one which: (1) is independently owned and operated; (2) is not dominant in its field of 
operation; and (3) satisfies any additional criteria established by the Small Business Administration 
(SBA).5
2. In this Order, the Commission adopts a system for assigning ten-digit telephone numbers 
linked to the NANP to persons using Internet-based TRS.  This Order will further the functional 
equivalency of TRS mandated in Title IV of the Americans with Disabilities Act.  The Commission finds 
that utilization of NANP numbers will achieve the goal of making Internet-based TRS functionally 
equivalent to traditional circuit switched telephony, and will provide Internet-based TRS users a reliable 
and consistent means by which they may receive calls from voice telephone users in the same way that 
voice telephone users are called.  Under this Order, each Internet-based TRS provider must provide 
Internet-based TRS users with the capability to register with that provider as a default provider.  Upon a 
users registration, each provider must either facilitate the users valid number portability request or, if the 
user does not wish to port a number, assign that user a geographically appropriate NANP telephone 
number.  Each provider also must route and deliver all of its Registered Internet-based TRS Users 
inbound and outbound calls unless the user chooses to place a call with, or receives a call from, an 
alternate provider.   Further, this Order requires Internet-based TRS providers to obtain from each of their 
Registered Internet-based TRS users, prior to the initiation of service, the physical location at which the 
service will first be utilized.  Moreover, providers of Internet-based TRS that can be utilized from more 
than one physical location must provide registered users one or more methods of updating their 
Registered Location. As noted in the Order, the numbering system adopted enables individuals with 
hearing and speech disabilities using Internet-based TRS access to emergency services.  Specifically, the 
Order is intended to ensure that emergency calls placed by Internet-based TRS users will be routed 
directly and automatically to the appropriate emergency services authorities by Internet-based TRS 
providers.  The Commission also requires each Internet-based TRS provider to include an advisory on its 
website and in any promotional materials addressing the new requirements adopted in the Order.  
Providers must obtain and keep a record of affirmative acknowledgement by every user assigned a 
  
1 See 5 U.S.C.  603.  The RFA, see 5 U.S.C.  601612, has been amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996, (SBREFA) Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2 5 U.S.C.  605(b).
3 5 U.S.C.  601(6).
4 5 U.S.C.  601(3) (incorporating by reference the definition of small business concern in Small Business Act, 15 
U.S.C.  632).  Pursuant to 5 U.S.C.  601(3), the statutory definition of a small business applies unless an agency, 
after consultation with the Office of Advocacy of the Small Business Administration and after opportunity for public
comment, establishes one or more definitions of such term which are appropriate to the activities of the agency and 
publishes such definition(s) in the Federal Register.
5 Small Business Act, 15 U.S.C.  632. 
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number of having received and understood this advisory.  The Commission also states its belief that 
instituting a numbering system and a Registered Location requirement, as provided in the Order, will 
reduce the misuse of IP Relay by persons seeking to use this service for fraudulent purposes.  Finally, the 
Order concludes that Internet-based TRS providers will be compensated from the Interstate TRS Fund for 
their reasonable actual costs of complying with the new rules adopted in this item.
3. To the extent that all Internet-based TRS providers, including small entities, will be 
eligible to receive compensation from the Interstate TRS Fund for their reasonable costs of complying 
with these numbering and Registered Location requirements, the Commission finds that these 
requirements will not have a significant economic impact on a substantial number of small entities.  
Further, the Commission believes that allowing providers until December 31, 2008, to implement the ten-
digit numbering plan adopted in the Order is a reasonable timeframe for both large and small providers.  
The Commission also authorizes the Managing Director to include in the third-party administrator 
contract the requirement to refer all implementation disputes that it is unable to resolve in a reasonable 
time to the Chief of the Wireline Competition Bureau for resolution, which will ease burdens on 
providers, including small entities.  For all of these reasons, the Commission concludes that these 
measures will not have a significant economic impact on a substantial number of small entities, in 
particular because each small business will receive financial compensation for reasonable costs incurred 
rather than absorb an uncompensated financial loss or hardship.
4. With regard to whether a substantial number of small entities may be affected by the 
requirements adopted in this Order, the Commission notes that, of the 11 providers affected by the Order, 
only three meet the definition of a small entity.  The SBA has developed a small business size standard 
for Wired Telecommunications Carriers, which consists of all such firms having 1,500 or fewer 
employees.6 Currently, eleven providers receive compensation from the Interstate TRS Fund for 
providing VRS, IP Relay and IP CTS:  AT&T Corp.; CSDVRS; CAC; GoAmerica; Hamilton Relay, Inc.; 
Hands On; Healinc; Nordia Inc.; Snap Telecommunications, Inc; Sorenson; and Sprint.  Because only 
three of the providers affected by this Order are deemed to be small entities under the SBAs small 
business size standard, the Commission concludes that the number of small entities affected by our 
decision in this Order is not substantial.  Moreover, given that all affected providers, including the three 
that are deemed to be small entities under the SBAs standard, will be entitled to receive prompt 
reimbursement for their reasonable costs of compliance, the Commission concludes that the Order will 
not have a significant economic impact on these small entities.
5. Therefore, for all of the reasons stated above, the Commission certifies that the 
requirements of this Order will not have a significant economic impact on a substantial number of small 
entities.
6. The Commission will send a copy of the Order, including this Final Regulatory 
Flexibility Certification, in a report to Congress pursuant to the Congressional Review Act.7 In addition, 
the Order, including the Final Regulatory Flexibility Certification, will be sent by the Commissions 
  
6 13 C.F.R.  121.201, NAICS code 517110.  According to Census Bureau data for 1997, there were 2,225 firms in 
this category which operated for the entire year.  U.S. Census Bureau, 1997 Economic Census, Subject Series: 
Information, Establishment and Firm Size (Including Legal Form of Organization), Table 5, NAICS code 513310 
(issued Oct. 2000).  Of this total, 2,201 firms had employment of 999 or fewer employees, and an additional 24 
firms had employment of 1,000 employees or more.  Thus, under this size standard, the majority of firms can be 
considered small.  (The census data do not provide a more precise estimate of the number of firms that have 
employment of 1,500 or fewer employees; the largest category provided is Firms with 1,000 employees or more.)
7 See 5 U.S.C.  801(a)(1)(A).
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Consumer & Governmental Affairs Bureau, Reference Information Center to the Chief Counsel for 
Advocacy of the SBA and will be published in the Federal Register.8
  
8 See 5 U.S.C.  604(b).
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APPENDIX D
Initial Regulatory Flexibility Certification
7. The Regulatory Flexibility Act of 1980, as amended (RFA),1 requires that an initial 
regulatory flexibility analysis be prepared for notice-and-comment rulemaking proceedings, unless the 
agency certifies that the rule will not, if promulgated, have a significant economic impact on a 
substantial number of small entities.2 The RFA generally defines the term small entity as having the 
same meaning as the terms small business, small organization, and small governmental 
jurisdiction.3 In addition, the term small business has the same meaning as the term small business 
concern under the Small Business Act.4 A small business concern is one that: (1) is independently 
owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any additional criteria 
established by the Small Business Administration (SBA).5
8. In the Further Notice of Proposed Rulemaking, the Commission seeks comment on 
additional issues relating to the assignment and administration of ten-digit telephone numbers for VRS 
and IP Relay users.  For example, the Commission proposes a modification of the call completion 
requirement under the Commissions TRS rules so that if a CA is handling a non-emergency relay call 
and identifies an incoming 911 call, the CA may terminate the existing call to immediately answer the 
911 call.6 The Commission also seeks comment on ways in which Registered Location information might 
be made available to alternative relay providers for the purpose of routing emergency calls in the event 
that an Internet-based TRS user places an emergency call through an Internet-based TRS provider other 
than the users default provider.  The Commission seeks comment on how long a registration period 
Internet-based TRS providers should have to register their users.  The Commission also seeks comments 
on the eligibility of Internet-based TRS users for multiple telephone numbers and on whether Internet-
based TRS users should pay a fee for toll free numbers.  Further, the Commission seeks comment on the 
steps it should take, if any, to facilitate standards-based signaling between service providers.  The 
Commission seeks comment on whether functional equivalency requires that a single telephone number 
be assigned to multiple end-user devices and on whether multi-line telephone systems pose particular 
problems for the numbering and 911 requirements imposed here.  The Commission seeks comment on 
who should be eligible to obtain a telephone number from Internet-based TRS providers.  The 
Commission also contemplates additional security measures designed to ensure the integrity of the TRS 
system and the equipment and networks of Internet-based TRS users, and proposes to extend the 
numbering system to IP CTS.  The Commission proposes the application of the Commissions anti-
slamming rules to protect relay consumers against unauthorized default provider changes and the 
Commissions privacy rules to protect relay consumers against unauthorized disclosure of private 
information.  Finally, the Commission seeks comment on whether the costs of acquiring ten-digit 
  
1 See 5 U.S.C.  603.  The RFA, see 5 U.S.C.  601612, has been amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2 5 U.S.C.  605(b).
3 5 U.S.C.  601(6).
4 5 U.S.C.  601(3) (incorporating by reference the definition of small-business concern in the Small Business 
Act, 15 U.S.C.  632).  Pursuant to 5 U.S.C.  601(3), the statutory definition of a small business applies unless an 
agency, after consultation with the Office of Advocacy of the Small Business Administration and after opportunity 
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the 
agency and publishes such definition(s) in the Federal Register.
5 15 U.S.C.  632.
6 See 47 C.F.R.  64.604(a)(30)(i) ( Consistent with the obligations of telecommunications carrier operators, CAs 
are prohibited from refusing single or sequential calls or limiting the length of calls utilizing relay services.)
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telephone numbers, and porting those numbers, should be passed on to Internet-based TRS users.
9. The Commission concludes that these proposed changes may be necessary to ensure that 
users of Internet-based TRS receive functionally equivalent telephone service, as mandated by Title IV of 
the Americans with Disabilities Act.  Although the proposed changes may result in additional reporting 
and recordkeeping requirements on the part of the affected providers, including small entities, the 
providers will be promptly reimbursed from the Interstate TRS Fund for the costs of complying with the 
proposed rules, if adopted. Entities, especially small businesses, are encouraged to quantify the costs and 
benefits of any reporting requirement that may be established in this proceeding.  The modifications the 
Commission proposes consist of policies aimed at achieving a functionally equivalent telephone service 
for Internet-based TRS users and are not expected to have a substantial economic impact upon providers, 
including small businesses, because each small business will receive financial compensation for 
reasonable costs incurred rather than absorb an uncompensated financial loss or hardship.
10. With regard to whether a substantial number of small entities may be affected by the 
requirements proposed in this Further Notice, the Commission notes that, of the fourteen providers 
affected by the Further Notice, only four meet the definition of a small entity.  The SBA has developed a 
small business size standard for Wired Telecommunications Carriers, which consists of all such firms 
having 1,500 or fewer employees.7 Currently, fourteen providers receive compensation from the 
Interstate TRS Fund for providing any form of TRS:  Ameritech, AT&T Corp.; CSDVRS; CAC; 
GoAmerica; Hamilton Relay, Inc.; Hands On; Healinc; Kansas Relay Service, Inc.; Nordia Inc.; Snap 
Telecommunications, Inc; Sorenson; Sprint; and State of Michigan.  Because only four of the providers 
that would be affected by this Further Notice, if adopted, are deemed to be small entities under the SBAs 
small business size standard, the Commission concludes that the number of small entities potentially 
affected by our proposed rules is not substantial.  Moreover, given that all providers potentially affected 
by the proposed rules, including the four that are deemed to be small entities under the SBAs standard, 
would be entitled to receive prompt reimbursement for their reasonable costs of compliance, the 
Commission concludes that the Further Notice, if adopted, will not have a significant economic impact on 
these small entities.
11. Therefore, we certify that the proposals in this Further Notice, if adopted, will not have a 
significant economic impact on a substantial number of small entities.
12. The Commission will send a copy of the Further Notice, including a copy of this Initial 
Regulatory Flexibility Certification, to the Chief Counsel for Advocacy of the SBA.8 This initial 
certification will also be published in the Federal Register.9
  
7 13 C.F.R.  121.201, NAICS code 517110.  According to Census Bureau data for 1997, there were 2,225 firms in 
this category which operated for the entire year.  U.S. Census Bureau, 1997 Economic Census, Subject Series: 
Information, Establishment and Firm Size (Including Legal Form of Organization), Table 5, NAICS code 513310 
(issued Oct. 2000).  Of this total, 2,201 firms had employment of 999 or fewer employees, and an additional 24 
firms had employment of 1,000 employees or more.  Thus, under this size standard, the majority of firms can be 
considered small.  (The census data do not provide a more precise estimate of the number of firms that have 
employment of 1,500 or fewer employees; the largest category provided is Firms with 1,000 employees or more.)
8 5 U.S.C.  605(b).
9 5 U.S.C.  605(b).
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STATEMENT OF
CHAIRMAN KEVIN J. MARTIN
Re:  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 and WC 
Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking.
Re:  Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities; Speech-to-Speech and Internet Protocol (IP) Speech-to-Speech Telecommunications 
Relay Services, CG Docket Nos. 03-123 and 08-15, Notice of Proposed Rulemaking.
 Today we take additional steps to help improve the quality of life for individuals with disabilities.  We 
adopt a ten-digit numbering system for Internet-based Telecommunications Relay Services (TRS).  We 
also seek comment on ways to improve Speech-to-Speech service (STS) and whether IP STS should be 
compensated from the Interstate TRS Fund.  Through these actions, we make progress in fulfilling our 
statutory goal of ensuring that every person has equal access to this nations communications services.  
 We are well aware that there are many Americans with hearing or speech disabilities that depend on 
TRS services for their daily communication needs.  The Commission remains committed to improving the 
quality of life for individuals with disabilities by ensuring that they have the same access to 
communication technologies as people without such disabilities.  
 In March, the Commission committed to adopt an order providing a ten-digit numbering system for 
Internet-based TRS by the end of June and to require that the ten-digit numbering system be implemented 
no later than December 31, 2008.  I am pleased that we fulfill these commitments today.  Ten-digit 
numbering will enable Internet-based TRS users to make and receive calls like anyone else, eradicating 
another barrier that stands in the way of functional equivalency.  Functional equivalency means 
individuals with disabilities having access to the same services as everyone else.  This equal access is 
vital to accessing jobs, education, public safety, and simple communications with family, friends, and 
neighbors.  
 I also support our inquiry into ways to improve STS and our tentative conclusion that IP STS is a form 
of TRS eligible for compensation from the Interstate TRS Fund. IP STS has the potential to allow a 
broader range of individuals to communicate.  By not being constrained to a specific piece of equipment 
that resides in a particular location, users of this service would have tremendous flexibility in how and 
where they use this service.  Moreover, individuals with disabilities would have access to new 
technologies and, specifically, be able to realize the benefits of broadband services.
 I want to assure those of you with hearing or speech disabilities that we will not stop actively working 
to fulfill your need for functional equivalence.  We could not have taken todays actions without your 
valuable input.  We thank you for your participation in our proceedings and look forward to working with 
you and the service providers to implement the ten-digit numbering system and to improve speech to 
speech service.  It is by working together that we can best ensure that the tremendous advances in 
communications are enjoyed by all Americans.
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STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re:  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 and WC 
Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking.
Today the Commission takes another essential step towards making sure that come December 31, 2008 
the deaf and hard of hearing community will be able to obtain 10-digit phone numbers  something that 
most of us with a cell phone or home phone too often take for granted.  In doing so, users of Internet-
based Telecommunications Relay Services such as Video Relay Service and IP-Relay will be able to give 
their friends, family, doctors, and employers a phone number to reach them just like voice telephone 
users.  The Order requires that these phone numbers be portable and the consumer devices be 
interoperable. The Order also requires that emergency calls placed by these users be automatically and 
correctly connected with local emergency services.  I am pleased to support this Order and the 
Commissions decision to require that all of this be completed no later than December 31, 2008.  Deaf 
and hard of hearing consumers have waited too long for this service already and it is certainly consistent 
with the Americans with Disabilities Acts mandate of functional equivalency.  
Getting to this juncture has not been an easy road and there is still much work to do.  For this reason, I 
also support the Commissions Further Notice of Proposed Rulemaking seeking comment on certain 
implementation issues involving emergency calling, Customer Proprietary Network Information, and anti-
slamming rules. Comment is also sought on other important issues such as the appropriate timeline for
existing users to sign-up for a number, the assignment of multiple phone numbers to a user or a single 
phone number to multiple services, how costs for this new system should be covered, and ways to prevent 
fraud. These and other issues teed up in the Further Notice are all critical questions, many of them novel, 
and I would urge all stakeholders to provide the Commission with the benefit of their insights, knowledge 
and experience.
The Order also emphasizes the critical need for consumer outreach. The availability of phone numbers 
is a very big step in the advancement of functionally equivalent telephone service for the deaf and hard 
hearing community. With that will come many questions, probably some concerns, and inevitably I fear 
some confusion as we move to the system adopted today.  For these reasons, its incumbent upon the 
FCC, providers, and consumer advocacy organizations to engage in a coordinated campaign to inform the 
disability community.
As with most systemic and promising changes, it is essential that all stakeholders, particularly the 
disability community, provide the Commission with its ongoing input and ideas.  The FCC must do a 
good job of monitoring the process and be ready to respond to any unintended consequences.  In addition, 
the Commission must remain diligent in its efforts to oversee the integrity of these programs.  The move 
to a numbering system should afford the Commission, providers, and businesses additional tools in their 
efforts to combat fraud, particularly when it comes to IP-Relay. 
I want to thank Chairman Martin and all my colleagues for their support for this Order and their efforts 
in making it come to fruition.  I also appreciate the hard work and guidance provided by the deaf and hard 
of hearing community on these important issues.  Finally, I want to pay tribute to Cathy Seidel and Nicole 
McGinnis of the Consumer and Government Affairs Bureau, Tom Chandler of the Disabilities Rights 
Office, Dana Shaffer and Nick Alexander of the Wireline Competition Bureau, and their teams who in 
less than three months organized a stakeholder workshop, analyzed a refreshed record, and labored long 
hours on this technical, complicated and important Order.  While were not home yet, their ongoing 
efforts are worthy of recognition.
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STATEMENT OF
COMMISSIONER JONATHAN S. ADELSTEIN
Re:  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 and WC 
Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking.
Earlier this year, the Commission made a commitment to establish a permanent and automated 
emergency access solution and a ten-digit dialing plan for Internet-based relay services.  So, I am pleased 
that we honor that commitment today by adopting this Order, which sets us on a course to complete those 
tasks by December 31, 2008 and marks significant progress toward ensuring functionally equivalent 
service for consumers with hearing and speech disabilities.
With this Order, we adopt a permanent emergency access solution and a system of traditional ten-digit 
numbers for Internet-based relay services.  A permanent emergency access solution will enable Internet-
based relay service customers to automatically reach the appropriate emergency services, just as hearing 
users of interconnected VoIP services do.  It is telling that users of Internet relay services described 
emergency access as unequivocally the most important aspect of VRS and IP Relay functional 
equivalency.1 Similarly, the decision to adopt a true ten-digit dialing system will greatly improve the 
value of Internet-based relay services for consumers.  We establish a comprehensive system, for the first 
time, that will allow VRS and IP Relay Service users to call and be called by other relay service 
customers and by hearing customers.  It will also permit relay service users to port their numbers when 
they switch providers.  I am also pleased that the accompanying Further Notice seeks comment on 
consumer protection issues, like slamming and customer privacy.  Establishing appropriate consumer 
safeguards is another important element of ensuring functional equivalence. 
The progress we make today would not be possible were it not for the tireless efforts of the many 
consumer representatives who have championed these issues, participated in our stakeholder workshops, 
and provided critical input to my office and Commission staff. We have also benefited from the 
numerous providers who have shared their technical expertise and experience as we develop solutions to 
these long recognized problems, and we will need their continued cooperation as we implement the 
decisions reached here.  I am also grateful for the attention and input of leading members of Congress 
who on a bipartisan basis have recognized the importance of these issues and asked us to move quickly.2  
Finally, the talented staff from our Consumer and Governmental Affairs Bureau and Wireline 
Competition Bureau deserve particular praise for bringing their expertise and dedication to this task.  
They have done yeomans work sorting through complicated numbering proposals, comparing advantages 
and disadvantages, and crafting the best elements of each into the current approach.  We will need to rely 
on their continued efforts in order to meet the December 31st deadline for implementation, so I thank them 
for their contributions to this item and look forward to continuing the effort.
  
1  See Partial Opposition of Telecommunications For The Deaf And Hard Of Hearing, Inc.; Association Of Late-
Deafened Adults, Inc.; National Association Of The Deaf; Deaf And Hard Of Hearing  Consumer Advocacy 
Network; And California Coalition Of Agencies Serving The Deaf And Hard Of Hearing (Dec. 20, 2007).
2  See Letter from Chairman John D. Dingell, Ranking Member Joe Barton, Chairman Edward J. Markey, Ranking 
Member Fred Upton (Nov. 26, 2007).
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STATEMENT OF 
COMMISSIONER DEBORAH TAYLOR TATE
Re:  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 and WC 
Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking.
On March 19, 2008, in our VRS 911 Order, we adopted interim emergency call handling requirements 
for Internet-based TRS providers.  Pursuant to that Order on April 29, 2008, the Commission held a 
Stakeholder Workshop in which consumers and a cross-section of industry representatives discussed 
numbering issues, including three comprehensive numbering proposals reflected in the record. Today we 
fulfill our commitment in that Order and adopt a ten-digit telephone numbering system for users of 
Internet-based TRS, specifically Video Relay Service and IP Relay. Significantly, the ten-digit 
numbering system will further the functional equivalency mandate by permitting voice telephone users to 
call VRS and IP Relay users by dialing the relay users ten-digit telephone number, the same way that 
voice telephone users call other voice telephone users.  In addition, the item adopts registered location 
requirements similar to those applicable to interconnected VoIP providers to ensure that consumers can 
call emergency services via VRS and IP Relay and have their call automatically route to appropriate 
emergency services authorities.
As the Commission continues to consider the needs of the deaf and hard-of-hearing community, we 
must ensure that all Americans benefit from advances in telecommunications services and equipment.  
Today we acknowledge that significant numbers of persons with hearing disabilities are seeking 
innovative services.  I look forward to implementation of this plan by the end of 2008.