Federal Communications Commission DA 09-749 Before the Federal Communications Commission WASHINGTON, D.C. 20554 In the Matters of 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, Telecommuni- cations Equipment and Customer Premises Equipment by Persons with Disabilities Telecommunications 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 WT Docket No. 96-198 CG Docket No. 03-123 CC Docket No. 92-105 ORDER AND PUBLIC NOTICE SEEKING COMMENT Adopted: April 1, 2009 Released: April 1, 2009 By the Chief, Consumer & Governmental Affairs Bureau: I. INTRODUCTION 1. In this Order we extend for 90 days (until June 29, 2009) the limited waiver granted in the 2008 TRS 711 Waiver Order1 of the requirement that traditional telecommunications relay service (TRS) providers must automatically and immediately call an appropriate Public Safety Answering Point (PSAP) when receiving an emergency 711-dialed call placed by an interconnected VoIP user.2 Further, in the Public Notice we seek comment on the remaining technical, operational, or other issues that currently prevent traditional TRS providers from being able to reliably identify the appropriate PSAP to call when receiving an emergency call via 711 and an interconnected VoIP service. We also seek comment 1 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 Relay Services and Speech-to- Speech Services for Individuals with Hearing and Speech Disabilities, WC Docket No. 04-36, WT Docket No. 96- 198, CG Docket No. 03-123 & CC Docket No. 92-105, Order, 23 FCC Rcd 5707, 5712-15, paras. 9-14 (CGB April 4, 2008) (2008 TRS 711 Waiver Order). 2 See 2008 TRS 711 Waiver Order, 23 FCC Rcd at 5715-17, paras. 15-17; see also 47 C.F.R. §§ 9.3, 54.5 (defining “interconnected VoIP service” and “interconnected VoIP provider”). Federal Communications Commission DA 09-749 2 regarding the usage of traditional TRS to place calls through interconnected VoIP service, particularly the incidence of such calls for purposes of obtaining emergency assistance. II. BACKGROUND 2. TRS, created by Title IV of the Americans with Disabilities Act of 1990 (ADA), enables individuals with hearing or speech disabilities to access the public telephone system to communicate with voice telephone users through a communications assistant (CA) at a TRS relay center.3 The CA relays conversations between persons using various types of assistive communication devices and persons who do not require such assistive devices. A traditional TRS call is accomplished via text-to-voice or voice- to-text, with the text provided by a TTY. Although such calls typically are placed over the public switched telephone network (PSTN) (i.e., with a traditional wireline telephone service paired with a TTY), a traditional TRS call may also be made using a TTY via an interconnected VoIP service (i.e., by plugging a TTY into an interconnected VoIP handset or device). 3. The Commission’s TRS rules require common carriers providing telephone voice transmission services to offer 711 abbreviated dialing access to traditional TRS as a toll-free call.4 711 abbreviated dialing allows TRS users (both persons with hearing or speech disabilities and voice telephone users) to call a TRS provider to initiate a TRS call from anywhere in the country by dialing 711, so that TRS users do not have to dial or commit to memory (especially when traveling to another state) the ten-digit or 800 number of a particular state’s TRS provider. The Commission’s TRS rules also set forth operational, technical, and functional mandatory minimum standards applicable to the provision of TRS.5 As relevant here, these rules require traditional TRS providers to handle emergency calls by using a system that “automatically and immediately transfers the caller to an appropriate [PSAP].”6 The Commission has defined an “appropriate PSAP” as “either a PSAP that the caller would have reached if he had dialed 911 directly,” or “a PSAP that is capable of enabling the dispatch of emergency services to the caller in an expeditious manner.”7 4. In the 2007 VoIP TRS Order, the Commission extended its pre-existing TRS rules to interconnected VoIP providers, including the duty to offer 711 abbreviated dialing access to TRS.8 The VoIP TRS Order required interconnected VoIP providers to offer 711 abbreviated dialing “to ensure that TRS calls can be made from any telephone, anywhere in the United States, and that such calls will be properly routed to the appropriate relay center.”9 Following release of the VoIP TRS Order, several 3 See 47 U.S.C. § 225; 47 C.F.R. § 64.601 et seq. (implementing regulations). 4 See 47 C.F.R. § 64.603; Use of N11 Codes and Other Abbreviated Dialing Arrangements, CC Docket No. 92-105, Second Report and Order, 15 FCC Rcd 15188, 15191, para. 3 (Aug. 9, 2000) (711 Order). 5 47 C.F.R. § 64.604 (the TRS mandatory minimum standards). 6 47 C.F.R. § 64.604(a)(4). 7 Id. 8 See 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 Relay Services and Speech-to- Speech Services for Individuals With Hearing and Speech Disabilities, WC Docket No. 04-36, WT Docket No. 96- 198, CG Docket No. 03-123 & CC Docket No. 92-105, Report and Order, 22 FCC Rcd 11275, 11291-97, paras. 32- 43 (June 15, 2007) (VoIP TRS Order). 9 Id., 22 FCC Rcd at 11296, para. 42. Federal Communications Commission DA 09-749 3 parties filed petitions for waiver raising two distinct issues: (1) the ability of interconnected VoIP providers to route the inbound leg of a 711-dialed call to an appropriate TRS provider, particularly when the caller’s telephone number does not correspond to the caller’s geographic location, and (2) the ability of TRS providers that receive, via an interconnected VoIP service, a 711-dialed call concerning an emergency to determine an appropriate PSAP to call.10 The petitions asserted that technical and operational difficulties prevented interconnected VoIP providers and TRS providers from complying with their respective obligations under the applicable TRS rules. 5. In the October 2007 Order and Notice, the Consumer & Governmental Affairs Bureau (Bureau) clarified the 711 requirement adopted in the VoIP TRS Order and granted interconnected VoIP providers a six-month waiver of the requirement to route the inbound leg of a 711-dialed call to an “appropriate TRS provider,” as defined by the Bureau.11 Based on the record, the Bureau found that interconnected VoIP providers were unable to consistently route interconnected VoIP-originated 711 calls to the “appropriate relay center” due to the fact that the telephone number associated with an interconnected VoIP call may not correspond to the geographic location of the caller.12 The Bureau also recognized that the VoIP TRS Order, by extending the 711 requirement to interconnected VoIP providers, effectively placed traditional TRS providers under a duty to handle such calls that involve an emergency in accordance with the Commission’s pre-existing emergency call handling rules. Based on the record, the Bureau determined that the geographic location identification challenges associated with interconnected VoIP-originated 711 calls rendered TRS providers unable to consistently identify the “appropriate” PSAP to which to route the call.13 On this basis, the Bureau found good cause to grant traditional TRS providers a six-month waiver of the obligation set forth in section 64.604(a)(4) of the Commission’s rules, i.e., to automatically and immediately route the outbound leg of an interconnected VoIP-originated emergency 711 call to an “appropriate” PSAP.14 10 See Motion for Stay or Waiver of the Voice on the Net (VON) Coalition (Sept. 14, 2007) (seeking to stay or waive 711 abbreviated dialing requirement, as applied to interconnected VoIP providers); United States Telecom Association Petition for Waiver of Certain Regulations Concerning Provision of 711 Dialing (Sept. 21, 2007) (seeking to waive 711 abbreviated dialing requirement insofar as it requires interconnected VoIP providers to route emergency 711 calls, including those involving a nomadic VoIP service or a non-geographic telephone number, to a relay center capable of identifying the appropriate PSAP); Hamilton Telephone Company d/b/a/ Hamilton Telecommunications, Petition for Waiver (Sept. 21, 2007) (seeking to waive the requirement that TRS providers “automatically and immediately” route VoIP-originated emergency 711 calls to an appropriate PSAP because TRS providers cannot necessarily determine the geographic location of 711 TRS callers using interconnected VoIP service). 11 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 Relay Services and Speech-to- Speech Services for Individuals with Hearing and Speech Disabilities, WC Docket No. 04-36, WT Docket No. 96- 198, CG Docket No. 03-123 & CC Docket No. 92-105, Order and Public Notice Seeking Comment, 22 FCC Rcd 18319 (CGB Oct. 9, 2007) (October 2007 Order and Notice). 12 Specifically, the record showed that, because an interconnected VoIP user’s telephone number does not necessarily correspond with the user’s actual geographic location, interconnected VoIP providers were unable to consistently route the call to the “appropriate relay center” as we have defined that term. See id., 22 FCC Rcd at 18323, paras. 10-11. 13 Id., 22 FCC Rcd at 18324-25, paras. 12-14. 14 Id., 22 FCC Rcd at 18324-25, paras. 12-15. Federal Communications Commission DA 09-749 4 6. In the accompanying Public Notice, the Bureau sought comment on “technical solutions” that would enable interconnected VoIP providers to route 711 calls to “an appropriate relay center,” as clarified in the Bureau’s order, and that would enable relay centers “to identify the appropriate PSAP to call” when receiving an emergency call via 711 and an interconnected VoIP service.15 In response, interested parties filed five comments and four reply comments.16 In addition, Qwest filed a petition for an extension of time (until the end of the first quarter of 2009) to implement the 711 requirement with respect to the routing of “nomadic” VoIP 711-dialed calls to an appropriate relay center, and Verizon filed a petition for an extension of time (also until the end of the first quarter of 2009) to implement the 711-dialing requirement with respect to the routing of 711-dialed calls to an appropriate relay center using its “nomadic VoiceWing” interconnected VoIP service.17 7. In the 2008 TRS 711 Waiver Order, we extended and modified the 711 waivers, as they apply to interconnected VoIP providers and traditional TRS providers. First, we granted interconnected VoIP providers an extension of time, until March 31, 2009, to route 711-dialed calls to an appropriate relay center, but only in the context of 711-dialed calls in which the calling party’s telephone number may not reflect his or her geographic location (because the caller is using a non-geographically relevant telephone number or a nomadic interconnected VoIP service).18 Second, we granted traditional TRS providers an extension of time, until March 31, 2009, to fulfill their obligation to implement a system to automatically and immediately call an appropriate PSAP when receiving an emergency 711-dialed call via an interconnected VoIP service, based on the significant technical challenges presented by this requirement and on our finding that the delivery of the inbound leg of a 711-dialed call by an interconnected VoIP provider to an appropriate relay center is a predicate to the delivery by the relay center of the outbound leg of such a call to an appropriate PSAP.19 8. On March 20, 2009, AT&T and Sprint (Petitioners) filed a petition seeking a one year extension of the current waiver of section 64.604(a)(4) to the extent that provision requires traditional TRS providers to automatically and immediately route to an appropriate PSAP emergency 711-dialed calls placed by interconnected VoIP users.20 Petitioners assert that “technical and operational difficulties” continue to prevent traditional TRS providers from receiving “reliable geographic location information” from VoIP-originated 711 calls, and thus traditional TRS providers remain unable to consistently identify the appropriate PSAP to which to route the call.21 In particular, Petitioners state that, even if all 15 October 2007 Order and Notice, 22 FCC Rcd at 18325, para. 16. 16 Comments of Sprint Nextel (filed December 3, 2007); Comments of the VON Coalition (filed December 3, 2007); Comments of Hamilton Relay, Inc. (filed December 3, 2007); Comments of National Emergency Number Association (NENA) (filed December 3, 2007); Comments of Wireless Communications Association International (WCA) (filed December 3, 2007); Reply Comments of Qwest Communications Corporation, Inc. (filed December 17, 2007); Reply Comments of Coalition of Organizations for Accessible Technology (COAT) (filed December 17, 2007); Reply Comments of Verizon (filed December 17, 2007); Reply Comments of WCA (filed December 17, 2007). 17 See Qwest Communications Corporation Petition for an Extension of Time to Implement VoIP 711-Dialing in a Nomadic Context (filed March 7, 2008) (Qwest Petition); Petition of Verizon for Extension of Waiver (filed March 27, 2008) (Verizon Petition). 18 2008 TRS 711 Waiver Order, 23 FCC Rcd at 5712-15, paras. 9-14. 19 Id., 23 FCC Rcd at 5715-17, paras. 15-17. 20 See Petition of AT&T and Sprint Nextel for Extension of Waiver at 1-2 (filed March 20, 2009) (Petition). 21 Id. at 3. Federal Communications Commission DA 09-749 5 interconnected VoIP providers successfully meet their obligation to route 711 calls to the appropriate relay center by March 31, 2009, implementing a solution to allow TRS providers to route emergency calls to the appropriate PSAP will take additional time beyond that date.22 Although Petitioners assert that progress is being made, they contend that until a solution is devised to allow traditional TRS providers to obtain interconnected VoIP users’ Registered Location information, TRS providers will continue to be unaware of the location of VoIP customers who call 711 in an emergency and will be unable to automatically and immediately route those calls to the appropriate PSAP.23 For these reasons, Petitioners ask the Commission to extend for an additional year the waiver of section 64.604(a)(4) with respect to traditional TRS providers’ duty to automatically and immediately route emergency 711 calls that originate on the network of an interconnected VoIP provider.24 III. DISCUSSION 9. The Commission may waive a provision of its rules for “good cause shown.”25 For the reasons set forth below, we find good cause exists to extend for 90 days (until June 29, 2009) the current waiver of section 64.604(a)(4) of the Commission’s rules,26 to the extent it applies to traditional TRS providers’ obligation to automatically and immediately route the outbound leg of an interconnected VoIP- originated emergency 711 call to an appropriate PSAP. 27 10. As noted above, section 64.604(a)(4) requires TRS providers to use a system for incoming emergency calls that “automatically and immediately” routes the outbound leg of a TRS call to an appropriate PSAP.28 The Bureau has previously noted that, although the VoIP TRS Order did not 22 Id. 23 Id. at 4. The Petitioners state that one proposed solution under discussion would allow for VoIP providers to route all 711 calls to the appropriate relay center via “state specific toll free numbers,” which would allow TRS providers to identify calls that originate over VoIP service. Id. at n. 7. 24 Id. at 5. 25 47 C.F.R. § 1.3; see generally Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Report and Order, Order on Reconsideration, and Further Notice of Proposed Rulemaking, CC Docket Nos. 90-571 & 98-67, CG Docket No. 03-123, 19 FCC Rcd 12475, 12520, para. 110 (June 30, 2004) (2004 TRS Report & Order) (discussing standard for waiving Commission rules). 26 47 C.F.R. § 64.604(a)(4). 27 Based on the record, we allow the waiver relief previously granted to interconnected VoIP providers of the requirement to route 711-dialed calls to an appropriate relay center to expire after the March 31, 2009 deadline. To our knowledge, no interconnected VoIP provider has filed a petition seeking an extension of the waiver. In addition, the record reflects that progress has been made toward resolving technical difficulties previously associated with the routing of 711-dialed calls by interconnected VoIP providers. See, e.g., Letter to Marlene H. Dortch, FCC, from Richard T. Ellis, Verizon (dated Dec 22, 2008) (Verizon Ex Parte) (“Verizon expects to be in compliance with the Commission’s [711 dialing] requirements by the March 31, 2009 deadline”). Accordingly, upon expiration of the current waiver, interconnected VoIP providers will be required to properly route all 711-dialed calls to an appropriate relay center (i.e., the relay center serving the state in which the caller is geographically located or that corresponds to the caller’s last registered address). Given that compliance issues remain, however, with respect to traditional TRS providers’ handling and routing of the outbound leg of emergency 711 VoIP calls, (as discussed herein), interconnected VoIP providers must continue to take steps to remind persons with speech or hearing disabilities to dial 911 directly (as a TTY-to-TTY call), rather than dialing 711 (as a relay call), in the event of an emergency. See note 36, infra. 28 47 C.F.R. § 64.604(a)(4). Federal Communications Commission DA 09-749 6 specifically address TRS providers’ obligation to handle 711 emergency calls placed by interconnected VoIP customers via TTY, by extending the 711 abbreviated dialing requirement to interconnected VoIP providers, the order effectively placed traditional TRS providers under a duty to handle and route these calls as prescribed by the Commission’s pre-existing emergency call handling rules.29 11. Our reasons for extending the waiver for traditional TRS providers are, again, three- fold.30 First, petitioners note that the routing of the outbound leg of a VoIP-originated, 711-dialed call to an appropriate PSAP by a TRS provider continues to present significant technical and operational challenges.31 Second, to the extent that interconnected VoIP providers are only recently able to consistently deliver the inbound leg of a 711-dialed call to the appropriate relay center, we agree with the Petitioners that implementation of a solution to allow TRS providers to properly route emergency 711- dialed VoIP calls will take additional time beyond the March 31, 2009 deadline for Interconnected VoIP providers.32 Third, as the Petition reflects, addressing these challenges requires further collaboration among a variety of stakeholders including TRS providers, interconnected VoIP providers and their vendors, PSAPs, the emergency services community, and the consumers.33 In light of the foregoing, we find good cause to grant traditional TRS providers an extension of the current waiver of section 64.604(a)(4) for 90 days (until June 29, 2009). 12. During the period of this waiver, we will continue to require a traditional TRS provider that cannot automatically and immediately route to an appropriate PSAP the outbound leg of an interconnected VoIP-originated emergency 711 call, as required by section 64.604(a)(4), to maintain a manual system for doing so, to the extent feasible, that accomplishes the proper routing of emergency 711 calls as efficiently as possible.34 Further, during this period, TRS providers must continue to take steps to remind individuals with hearing or speech disabilities to dial 911 directly (as a text-to-text, TTY-to-TTY call) in an emergency, whether using a PSTN-based service or interconnected VoIP service, rather than making a TRS call via 711 in an emergency.35 We also expect TRS providers to continue their collaboration with industry stakeholders in order to address any remaining issues, such that a further extension of this waiver will be unnecessary.36 29 October 2007 Order and Notice, 22 FCC Rcd at 18324, para. 14. 30 See 2008 TRS 711 Waiver Order, 23 FCC Rcd at 5715-16, para. 16. 31 See Petition at 3-5 (describing present difficulties in TRS routing of VoIP-originated 711 calls to the appropriate PSAP). 32 See id. 33 See id. at 2 (“TRS providers need additional time to collaborate with interconnected VoIP providers, their vendors and other interested parties to develop an appropriate solution”). 34 October 2007 Order and Notice, 22 FCC Rcd at 15324-25, para. 15. 35 Id. 36 Notwithstanding this action, we note that if a caller using a TTY connected to an interconnected VoIP service calls a PSAP directly as a 911-dialed emergency call (as a text-to-text, or TTY-to-TTY call), the 911-dialed call will be routed automatically and immediately through the selective router over the wireline E911 network to the PSAP that serves the caller’s Registered Location, just as it would be for a hearing caller via an interconnected VoIP service. See 2008 TRS 711 Waiver Order, 23 FCC Rcd 5706, at n.10. See also http://www.fcc.gov/cgb/consumerfacts/711.html (stating that, in an emergency, “TTY users should call 911 directly, and not make a TRS call via 711”). Federal Communications Commission DA 09-749 7 IV. PUBLIC NOTICE SEEKING COMMENT 13. Although we grant the Petition to extend the waiver as set forth above (for 90 days), we seek specific comment on the remaining technical, operational, or other issues that currently prevent traditional TRS providers from being able to reliably identify the appropriate PSAP to call when receiving an emergency call via 711 and an interconnected VoIP service. In particular, we seek comment on the specific steps that remain to be taken in order for traditional TRS providers to be able to consistently route interconnected VoIP-originated 711 emergency calls in the manner prescribed by section 64.604(a)(4) of the Commission’s rules. We also ask providers for an estimate of the costs and the timeframe associated with each of these steps. Further, we seek comment from interconnected VoIP providers and TRS providers regarding the total number of interconnected VoIP-originated 711 TRS calls that are processed annually by each provider (estimates, if actual figures are unavailable) and the proportion of those calls that are of an emergency nature. 14. We also seek comment from interconnected VoIP and TRS providers, as well as from consumers and disability rights advocates, concerning the continuing use of TTYs by individuals with hearing or speech disabilities and, in particular, the use of TTYs with an interconnected VoIP service. We seek comment on the overall effectiveness of providers’ outreach efforts in educating consumers about the importance of dialing 911 directly in an emergency, rather than dialing 711 to place an emergency call via TRS. Further, commenters are encouraged to comment on any impediments consumers have encountered in attempting to dial 911 directly in an emergency situation (when using a TTY and an interconnected VoIP service). Finally, we seek comment on the continuing need, from the consumer’s perspective, of dialing 711 via TRS in an emergency, rather than dialing 911 directly. V. PROCEDURAL MATTERS 15. Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 C.F.R. §§ 1.415, 1.419, interested parties may file comments in this proceeding 21 days after the date of publication in the Federal Register and reply comments may be filed 31 days after the date of publication in the Federal Register. When filing comments, please reference WC Docket No. 04-36, CG Docket No. 03-123, WT Docket No. 96-198, and CC Docket No. 92-105. Comments may be filed using: (1) the Commission's Electronic Comment Filing System (ECFS), (2) the Federal Government’s eRulemaking Portal, or (3) by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24,121 (1998). Comments filed through the ECFS can be sent as an electronic file via the Internet by accessing the ECFS: http://www.fcc.gov/cgb/ecfs or the Federal Rulemaking Portal: http://www.regulations.gov. Filers should follow the instructions provided on the website for submitting comments. If multiple docket or rulemaking numbers appear in the caption of this proceeding, commenters must transmit one electronic copy of the comment to each docket or rulemaking number referenced in the caption. In completing the transmittal screen, commenters 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, commenters should send an e-mail to ecfs@fcc.gov, and should include the following words in the body of the message, "get form." A sample form and directions will be sent in reply. 16. Parties who choose to file by paper must file an original and four copies of each filing. If more than one docket or rulemaking number appears in the caption of this proceeding, commenters must submit two additional copies for each additional docket or rulemaking number. Filings can be sent by hand or messenger delivery, by electronic media, by commercial overnight courier, or by first-class or overnight U.S. Postal Services mail (although we continue to experience delays in receiving U.S. Postal Service mail). All filings must be addressed to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission. The Commission's contractor will receive hand-delivered or Federal Communications Commission DA 09-749 8 messenger-delivered paper filings or electronic media for the Commission's 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 and electronic media sent by 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 mail, Express Mail, and Priority Mail should be addressed to 445 12th Street, SW, Washington, D.C. 20554. 17. Parties who choose to file by paper should also submit their comments on a compact disc. The compact discs should be submitted, along with three paper copies, to: Dana Wilson, Consumer & Governmental Affairs Bureau, Disability Rights Office, 445 12th Street, SW, Room 3-C418, Washington, D.C. 20554. Such a submission should be on a compact disc formatted in an IBM compatible format using Word 2003 or compatible software. The compact disc should be accompanied by a cover letter and should be submitted in "read only" mode. The compact disc should be clearly labeled with the commenter's name, the proceedings (including the docket numbers) in this case, WC Docket No. 04-36, CG Docket No. 03-123, WT Docket No. 96-198, and CC Docket No. 92-105, type of pleading (comment or reply comment), date of submission, and the name of the electronic file on the compact disc. The label should also include the following phrase "Disc Copy - Not an Original." Each compact disc should contain only one party's pleadings, preferably in a single electronic file. In addition, commenters must send compact disc copies to the Commission's copy contractor, Portals II, 445 12th Street, SW, Room CY- B402, Washington, D.C. 20554. 18. Pursuant to section 1.1206 of the Commission’s rules, 47 C.F.R. § 1.1206, this proceeding will be conducted as a permit-but-disclose proceeding in which ex parte communications are subject to disclosure. 19. The full text of this document and copies of any subsequently filed documents in this matter will be available for public inspection and copying during regular business hours at the FCC Reference Information Center, Portals II, 445 12th Street, SW, Room CY-A257, Washington, D.C. 20554. This document and copies of subsequently filed documents in this matter may also be purchased from the Commission’s duplicating contractor at Portals II, 445 12th Street, SW, Room CY-B402, Washington, DC 20554. Customers may contact the Commission’s contractor at their web site www.bcpiweb.com or by calling 1-800-378-3160. A copy of the underlying petitions for waiver may also be found by searching ECFS at http://www.fcc.gov/cgb/ecfs. 20. 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), (202) 418-0432 (TTY). This document can also be downloaded in Word or Portable Document Format (PDF) at: http://www.fcc.gov/cgb/dro/trs.html#orders. For further information, please contact Dana Wilson, Consumer & Governmental Affairs Bureau, Disability Rights Office, at (202) 418-2247 (voice), (202) 418-7898 (TTY), or e-mail at Dana.Wilson@fcc.gov. VI. ORDERING CLAUSES 21. Accordingly, IT IS ORDERED that, pursuant to sections 1, 2, and 225 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, and 225, and sections 0.141, 0.361, and 1.3 of the Commission’s rules, 47 C.F.R. §§ 0.141, 0.316 & 1.3, this Order IS ADOPTED. 22. IT IS FURTHER ORDERED that the traditional TRS Providers ARE GRANTED an extension of time, until June 29, 2009, to implement a system, as set forth in section 64.604(a)(4) of the Federal Communications Commission DA 09-749 9 Commission’s rules, 47 C.F.R. § 64.604(a)(4), to automatically and immediately call an appropriate PSAP when receiving an emergency 711-dialed call via an interconnected VoIP service. 23. IT IS FURTHER ORDERED that the Petition of AT&T and Sprint Nextel for Extension of Waiver IS GRANTED to the extent provided herein. 24. IT IS FURTHER ORDERED that comments shall be filed within 21 days after the date of publication of this item in the Federal Register, and reply comments shall be filed 31 days after the date of publication of this item in the Federal Register. 25. IT IS FURTHER ORDERED that this Order SHALL BE effective upon release. FEDERAL COMMUNICATIONS COMMISSION Catherine Seidel, Chief Consumer & Governmental Affairs Bureau