Federal Communications Commission DA 07-4178 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, Telecommunica- tions Equipment and Customer Premises Equip- ment 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: October 9, 2007 Released: October 9, 2007 By the Chief, Consumer & Governmental Affairs Bureau: I. INTRODUCTION 1. In this Order (Order), we grant in part and deny in part several petitions for waiver1 relating to the Commission’s recent VoIP TRS Order.2 In that order, the Commission extended the telecommunications relay service (TRS)3 requirements contained in Part 64 of the Commission’s rules to 1 See Motion for Stay or Waiver of the Voice on the Net (VON) Coalition (Sept. 14, 2007) (VON Coalition Petition); United States Telecom Association Petition for Waiver of Certain Regulations Concerning Provision of 711 Dialing (Sept. 21, 2007) (USTelecom Petition); Hamilton Telephone Company d/b/a/ Hamilton Telecommunications, Petition for Waiver (Sept. 21, 2007) (Hamilton Petition). 2 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, FCC 07-110, 2007 WL 1744291 (June 15, 2007) (VoIP TRS Order). This order became effective October 5, 2007. 3 TRS, created by Title IV of the Americans with Disabilities Act of 1990 (ADA), enables a person with a hearing or speech disability to access the nation’s telephone system to communicate with voice telephone users through a relay (continued….) Federal Communications Commission DA 07-4178 2 providers of interconnected voice over Internet Protocol (VoIP) services.4 Among the requirements extended to interconnected VoIP providers is the obligation to offer 711 abbreviated dialing access to traditional relay services via a voice telephone or a text telephone (TTY).5 The petitions for waiver raise issues concerning (1) the ability of an interconnected VoIP provider to route the inbound leg of a 711 call to an appropriate TRS provider, particularly when the caller’s telephone number does not correspond to the caller’s actual location, and (2) the ability of a TRS provider that receives, via an interconnected VoIP service, a 711 call concerning an emergency to determine an appropriate Public Safety Answering Point (PSAP) to call. 2. As set forth below, we recognize that in certain circumstances there are technical challenges to the ability of interconnected VoIP providers to route 711 calls to an appropriate relay center. Similarly, we recognize that in certain circumstances TRS providers receiving 711 emergency calls via an interconnected VoIP service may not be able to determine an appropriate PSAP to call in compliance with the TRS emergency call handling requirements.6 As a result, as set forth below, we waive for six months the requirement set forth in the VoIP TRS Order that interconnected VoIP providers must transmit 711 calls to an appropriate relay provider, as defined below. We also waive for six months traditional TRS providers’ obligation to call to an appropriate PSAP when receiving, via interconnected VoIP service, a 711 call concerning an emergency. Further, in the Public Notice we seek comment on the petitions for stay and/or waiver.7 II. BACKGROUND 3. TRS enables individuals with hearing or speech disabilities to access the public telephone system to communicate with voice telephone users through a CA at a TRS relay center. The CA relays conversations between persons using various types of assistive communication devices and persons who do not require such assistive devices. The Commission’s TRS rules require common carriers providing voice transmission services to offer 711 abbreviated dialing access to TRS as a toll-free call.8 711 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 (Continued from previous page) provider and a communications assistant (CA). See 47 U.S.C. § 225; 47 C.F.R. § 64.601 et seq. (implementing regulations). 4 VoIP TRS Order; see 47 C.F.R. §§ 9.3, 54.5 (defining “interconnected VoIP service” and “interconnected VoIP provider”). 5 VoIP TRS Order at paras. 42-43. See generally 47 C.F.R. § 64.603 (“each common carrier providing telephone voice transmission services shall provide, not later than October 1, 2001, access via the 711 dialing code to all relay services as a toll free call”); 47 C.F.R. §§ 64.601(1) (defining “711” as “[t]he abbreviated dialing code for accessing all types of relay services anywhere in the United States”) & 64.601(15) (defining TTY); 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). The Commission adopted 711 dialing access so that TRS users – both hearing persons and persons with a hearing or speech disability – could initiate a relay call, anywhere in the United States, without having to remember and dial a 7 or 10-digit toll free number, and without having to obtain different numbers to access local TRS providers when traveling from state to state. 711 Order, 15 FCC Rcd at 15191, para. 3. 6 See 47 C.F.R. § 64.604(a)(4). 7 See note 1, supra. 8 See 47 C.F.R. § 64.603; 711 Order. Federal Communications Commission DA 07-4178 3 state) the 10-digit 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.9 As relevant here, the mandatory minimum standards require TRS providers to handle emergency calls by using a system that “automatically and immediately transfers the caller to an appropriate [PSAP].”10 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.”11 4. In the VoIP TRS Order, the Commission extended the application of its pre-existing TRS rules to interconnected VoIP providers, including the duty to offer 711 abbreviated dialing access to TRS.12 The VoIP TRS Order requires 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.”13 The 711 abbreviated dialing requirement, as applied to interconnected VoIP providers, became effective October 5, 2007. 5. On September 14, 2007, the VON Coalition filed a “Motion for Stay or Waiver,” asking the Commission to stay the effective date of the TRS requirements, including the 711 dialing requirement, as applied to interconnected VoIP providers or, in the alternative, to waive those requirements.14 The VON Coalition asserts that relief from the October 5, 2007 effective date of the TRS rules is needed because “despite the best good faith efforts of the industry, many Interconnected VoIP providers will be unable to meet that deadline.”15 In support of its request, the VON Coalition states that additional time would allow interconnected VoIP providers to fully develop and test 711 abbreviated dialing services prior to their introduction to the public, and avoid diverting resources from these providers’ ongoing implementation of other recently imposed Commission requirements, such as E911 and customer proprietary network information (CPNI) obligations.16 6. On September 21, 2007, USTelecom filed a petition requesting a two-year waiver for interconnected VoIP providers of the requirement that they route emergency 711 calls to a TRS provider capable of determining the appropriate PSAP to call to respond to the emergency.17 Although USTelecom asserts its interconnected VoIP provider members expect to be in compliance with the general requirement to offer 711 abbreviated dialing,18 it asserts that in circumstances where the 9 47 C.F.R. § 64.604 (the TRS mandatory minimum standards). 10 47 C.F.R. § 64.604(a)(4). 11 Id. 12 VoIP TRS Order at paras. 32-43. 13 VoIP TRS Order at para. 42. 14 See VON Coalition Petition at 5. The VON Coalition does not seek a stay or waiver of section 64.604(c)(5)(iii)(A) or (B) governing carrier contributions to the Interstate TRS Fund. 15 VON Coalition Petition at 11. 16 VON Coalition Petition at 3. Although the VON Coalition requests additional time to implement all of the TRS requirements that were scheduled to take effect on October 5, 2007 (other than the provision requiring interconnected VoIP providers to contribute to the Interstate TRS Fund), it has provided specific evidence of implementation difficulties only with respect to the 711 abbreviated dialing requirement. 17USTelecom Petition (requesting limited waiver of emergency call handling rules on behalf of its members who are interconnected VoIP providers and those who are traditional TRS providers). 18 USTelecom Petition at 5-6 (i.e., to route the call to a relay provider). Federal Communications Commission DA 07-4178 4 subscriber’s telephone number does not reflect his or her geographic location (because the subscriber is using a “non-geographically relevant” telephone number or a “nomadic” VoIP service)19 the interconnected VoIP provider may route the call to a relay center that corresponds to the geographic location associated with the caller’s telephone number, not to the caller’s actual location.20 As a result, in these circumstances if the call involves an emergency the TRS provider may be unable to make the outbound call to an appropriate PSAP that corresponds to the caller’s actual location.21 7. For this reason, Hamilton Telephone Company (Hamilton) – a provider of traditional TRS services in various states – filed a request for waiver of the TRS emergency call handling requirements as applied to traditional TRS providers handling calls originating on interconnected VoIP networks.22 Hamilton asserts that it “and presumably other TRS providers” cannot necessarily determine the geographic location of 711 TRS callers using an interconnected VoIP service because the caller’s telephone number may not correspond to the caller’s actual location. Hamilton further asserts that, as a result, it cannot be certain that it has identified an appropriate PSAP to which it should route 711 calls from an interconnected VoIP subscriber.23 Hamilton contends that the public interest would not be served by requiring it to comply with the emergency call handling rule in this context “until such time as the interconnected VoIP industry has addressed this substantial shortcoming.”24 III. DISCUSSION A. Clarification and Limited Waiver of Requirement that Interconnected VoIP Providers Route 711 Calls to the “Appropriate Relay Center” 8. The Commission may waive a provision of its rules for “good cause shown.”25 Because the record reflects that transmitting 711 calls via an interconnected VoIP service, rather than the PSTN, to an appropriate relay provider creates technological challenges for interconnected VoIP providers, we find that good cause exists to waive for six months the requirement that interconnected VoIP providers route 711 calls to an appropriate relay center. 9. As an initial matter, we clarify that, in requiring an interconnected VoIP provider to route 19 USTelecom Petition at 6. To the extent that an interconnected VoIP provider allows its customers to select telephone numbers from distant geographies, such phone numbers are considered “non-geographically relevant” in the sense that they are associated with a distant location. A VoIP service is “nomadic” in the sense that it can be used from various locations. 20 USTelecom Petition at 6. USTelecom notes that some interconnected VoIP providers “are considering whether to route all VoIP 711 calls to a single TRS center.” Id. at 7, n.11. 21 USTelecom Petition at 6-7. Even if the TRS provider completes the call to the appropriate PSAP, the PSAP may be unable to determine the caller’s address or location by using the ANI provided by the TRS provider to check the ALI database, since the caller’s ANI does not “match” his or her location. Id. at 7. 22 Hamilton Petition. 23 Hamilton Petition at 2-3. 24 Hamilton Petition at 3. USTelecom’s petition also requests a two-year waiver of the emergency call handling requirement, as it applies to TRS providers’ obligation to accept and handle emergency calls when the caller uses an interconnected VoIP service and has a non-geographically relevant phone number or is using a VoIP service nomadically. USTelecom Petition at 9. 25 47 C.F.R. § 1.3; see generally 2004 TRS Report and Order, 19 FCC Rcd at 12520, para. 110 (discussing standard for waiving Commission rules). Federal Communications Commission DA 07-4178 5 711 calls to the “appropriate relay center,”26 the Commission intended to signify the relay center(s) serving the state in which the caller is geographically located, or the relay center(s) corresponding to the caller’s last registered address.27 We conclude that this is the most natural interpretation of the term “appropriate relay center” in the context where a 711 call is being transmitted via an interconnected VoIP service as a substitute for the PSTN. Clarifying “appropriate relay center” in this manner is also essential to ensuring that TRS providers can make the outbound leg of the TRS call to an “appropriate PSAP,” as discussed below.28 10. The record reflects that compliance issues regarding interconnected VoIP providers handling 711 calls arises from the fact that in some cases the telephone number associated with a VoIP call will not correspond to the geographic location of the caller. In such circumstances, when a consumer dials 711 (whether on a TTY or a voice telephone), the call may be routed to a relay center that corresponds to the geographic location associated with the telephone number, not the actual geographic location of the caller. For example, when a relay caller in Virginia using VoIP service with a California telephone number dials 711, the call may go to a California relay center, not a Virginia relay center. Therefore, in such a case the interconnected VoIP provider is not routing the 711 call to an appropriate relay center, as defined above. 11. In light of the foregoing, we grant a limited waiver of the 711 call handling requirement for interconnected VoIP providers. Although interconnected VoIP providers are required to transmit 711 calls to a relay center, we waive the requirement insofar as it requires them to transmit the 711 call to an appropriate relay center, as defined above. We deny, however, the VON Coalition and USTelecom requests to the extent they seek such relief for an extended period of time. As noted above, the VON Coalition proposes an open-ended waiver, whereas USTelecom requests an additional two years to comply with our rules. We agree with the Coalition of Organizations for Accessible Technology (COAT) that “a brief extension of time for each of these requests may be merited,”29 but that “a two year extension of the FCC’s deadline on this matter, one which can affect the life, safety and health of people who rely on TRS for emergency access . . . is not in the public interest.”30 As COAT observes, many individuals are switching to VoIP service.31 It is of critical importance that all Americans, including those who place emergency 711 calls using interconnected VoIP service, have access to emergency services. For this reason, we grant a limited waiver of the requirement that interconnected VoIP providers route 711 calls to an appropriate relay center for a period of six months, so that interconnected VoIP service providers can implement a means of routing 711 calls, in all cases, to an appropriate relay center. 26 VoIP TRS Order at para. 42. 27 As a practical matter, the call typically should be routed to a relay center in the state where the caller is physically located, except where a single relay provider serves more than one state, in which case, the call should be routed to the relay provider that serves the state in which the caller is located. 28 We recognize that clarifying the VoIP TRS Order in this way effectively requires that all 711 calls (both emergency and non-emergency calls) carried by an interconnected VoIP provider be routed in this manner inasmuch as the interconnected VoIP provider has no way of knowing when its customer places a 711 call if it is an emergency call or not. 29 See Opposition by the Coalition of Organizations for Accessible Technology (COAT) to Motion for Stay or Waiver by the VON Coalition and USTelecom Petition for Waiver, WC Docket 04-36 et al., at 5 (filed Sept. 27, 2007). 30 Id. at 5. 31 Id. Federal Communications Commission DA 07-4178 6 B. Limited Waiver of Section 64.604(a)(4) for State TRS Providers 12. With respect to the obligation of TRS providers to handle emergency calls in accordance with our rules, we also find good cause exists to waive section 64.604(a)(4) of the Commission’s rules,32 as applied to TRS providers’ handling and routing of emergency 711 calls placed via TTY by interconnected VoIP customers, for a limited period of six months. As noted above, section 64.604(a)(4) of the Commission’s rules 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.33 Although the VoIP TRS Order did not 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 TRS providers under a duty to handle and route these calls as prescribed by the Commission’s pre-existing emergency call handling rules. 13. In order to route an emergency 711 call placed by an interconnected VoIP customer in the manner prescribed by section 64.604(a)(4), the TRS provider (the CA) must have a means of determining: (1) the geographic location of the caller; and (2) the appropriate PSAP that corresponds to that geographic location, so the CA can make the outbound call to the PSAP. As Hamilton notes, we understand that problems may arise when an interconnected VoIP user whose VoIP telephone number does not correlate with his physical location attempts to place an emergency 711 call. In particular, when an interconnected VoIP user dials 711 to reach a TRS provider to place a call for emergency services, the VoIP provider may route the call to a TRS provider in a state other than where the calling party is located if the calling party is using a telephone number that does not correlate to the caller’s geographic location or is using a VoIP service “nomadically.” In these circumstances, the relay provider may contact a PSAP that corresponds to the caller’s telephone number, but not the caller’s actual location. Further, even if the caller self-identifies his or her location to the CA, the CA may be unable to determine the correct PSAP to call unless the relay provider has access to a national database of PSAPs and can connect to the database. 14. Therefore, based on the record before us, it appears that, under certain circumstances, TRS providers receiving a call via an interconnected VoIP service may be unable to call an appropriate PSAP to respond to an emergency call.34 Moreover, it appears that certain TRS providers may be unable to access and/or connect to a national database of PSAPs in the event that a TRS provider receives an emergency 711 call from an out-of-state caller, making impossible the automatic routing of such a call to an appropriate PSAP. For these reasons, we grant TRS providers in this situation a limited waiver of the emergency call handling requirement insofar that, despite their best efforts, they may not be able to make the outbound call to an appropriate PSAP that corresponds to the caller’s actual location. 15. During the pendency of this waiver, we require a TRS provider that cannot automatically and immediately route to an appropriate PSAP the outbound leg of an emergency 711 call placed via TTY by an interconnected VoIP user, as required by section 64.604(a)(4), to implement a manual system for doing so, to the extent feasible, that accomplishes the proper routing of emergency 711 calls as efficiently as possible. Further, during this waiver period we require interconnected VoIP providers and traditional TRS providers 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. Finally, for the 32 47 C.F.R. § 64.604(a)(4). 33 47 C.F.R. § 64.604(a)(4). 34 In fact, the relay provider may not even know that the call is being routed via an interconnected VoIP provider, rather than the PSTN. Federal Communications Commission DA 07-4178 7 reasons discussed above in limiting the duration of the waiver of our 711 call handling requirements for interconnected VoIP providers, we believe that the public interest dictates that we limit this waiver relief for TRS providers to a period of six months. IV. PUBLIC NOTICE SEEKING COMMENT 16. As set forth above, we grant in part and deny in part the petitions for a stay or waiver filed by the VON Coalition, USTelecom, and Hamilton.35 We now seek comment on these petitions. In particular, we seek comment on technical solutions to the ability of interconnected VoIP providers to route all 711 calls to an appropriate relay center, as defined above, and to the ability of a relay center to identify the appropriate PSAP to call when receiving an emergency call via 711 and an interconnected VoIP service. 17. We also expect that interconnected VoIP providers, relay service providers, and members of the industry and community work closely together to achieve a solution as expeditiously as possible that will enable emergency 711 calls placed through interconnected VoIP to be handled in accordance with our emergency call handling procedures. In comments supporting a limited extension of time to comply with our rules, Wireless Communications Association International, Inc., states that “a meaningful solution requires cooperation and dialogue among a variety of interested parties, including service providers, vendors, the disabled community, TRS providers and . . . the public safety community.”36 We agree, and to this end, we seek comment on the waiver requests submitted by the VON Coalition, USTelecom, and Hamilton Relay, and the technological issues raised therein. V. PROCEDURAL MATTERS 18. 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 30 days after publication in Federal Register and reply comments may be filed 45 days after publication in 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. 19. 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 35 See note 1, supra. 36 See Letter from Andrew Kreig, President, WCA, to Marlene H. Dortch, Secretary, Federal Communications Commission, WC Docket No. 04-36 et al., at 2 (filed October 1, 2007). Federal Communications Commission DA 07-4178 8 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 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. 20. 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. 21. 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. 22. 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 . 23. 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. 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 24. 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. 25. IT IS FURTHER ORDERED that the VON Coalition Petition, USTelecom Petition, and Hamilton Petition are granted in part, and denied in part, as set forth herein. 26. IT IS FURTHER ORDERED comments shall be filed within 30 days after publication of Federal Communications Commission DA 07-4178 9 this item in the Federal Register, and reply comments shall be filed 45 after publication on this item in the Federal Register. 27. IT IS FURTHER ORDERED that this Order SHALL BE effective upon release. 28. To request materials in accessible formats (such as Braille, large print, electronic files, or 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 document can also be downloaded in Word and Portable Document Formats (PDF) at http://www.fcc.gov/cgb.dro. FEDERAL COMMUNICATIONS COMMISSION Cathy Seidel, Chief Consumer & Governmental Affairs Bureau