Federal Communications Commission DA 09-1461 
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
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WC Docket No. 04-36
WT Docket No. 96-198
CG Docket No. 03-123
CC Docket No. 92-105
ORDER
Adopted:  June 26, 2009 Released:  June 26, 2009
By the Acting Deputy Chief, Consumer & Governmental Affairs Bureau:
I. INTRODUCTION
1. In this Order, the Consumer & Governmental Affairs Bureau (Bureau) finds good cause 
to extend for one year (until June 29, 2010), the current limited waiver of section 64.604(a)(4) of the 
Commission’s rules,1 to the extent that the rule requires traditional telecommunications relay service 
(TRS) providers to “automatically and immediately” call an appropriate Public Safety Answering Point 
(PSAP) when receiving an emergency, 711-dialed call placed over an interconnected Voice over Internet 
Protocol (VoIP) service.2
2. The rule at issue has been waived previously, and on April 1, 2009, the Bureau extended 
that limited waiver until June 29, 2009.3 In doing so, the Bureau recognized that “technical and 
  
1 47 C.F.R. § 64.604(a)(4).
2 See 47 C.F.R. § 9.3 (defining “interconnected VoIP service”).
3 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-
(continued….)
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operational challenges” continue to prevent traditional TRS providers from developing a system to 
consistently identify an appropriate PSAP to which to route an emergency, 711-dialed interconnected 
VoIP call in the manner prescribed by section 64.604(a)(4).4 At the same time, the Bureau issued a Public 
Notice (Notice) seeking comment on the specific challenges preventing traditional TRS providers from 
complying with this rule and on the continuing need, from the consumer’s perspective, to be able to dial 
711 via TRS in an emergency, rather than dialing 911 directly.5  
3. The record reflects that traditional TRS providers continue to encounter significant 
challenges in reliably identifying the physical location of (and therefore an appropriate PSAP for) an 
interconnected VoIP caller who dials 711, rather than 911, to reach emergency personnel.6 Based on this 
information, and for the reasons set forth below, we find good cause to waive section 64.604(a)(4) for one 
year, to the extent that the rule requires traditional TRS providers to “automatically and immediately” 
route the outbound leg of an interconnected VoIP-originated emergency 711 call to an appropriate PSAP.7
We emphasize that grant of this waiver will not prevent traditional TRS users from reaching emergency 
services.  During the pendency of the waiver, traditional TRS providers will be required to maintain a 
manual system for routing 711-dialed emergency calls as quickly and efficiently as possible, and to renew 
their efforts to educate consumers of traditional TRS to dial 911 directly, rather than placing a 711-dialed 
TRS call, in an emergency.  
II. BACKGROUND 
4. TRS, mandated 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.8  
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., by using a TTY with a traditional wireline telephone 
service), 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).
(Continued from previous page)    
198, CG Docket No. 03-123 & CC Docket No. 92-105, Order, 24 FCC Rcd 5707 (CGB April 1, 2009) (April 2009
TRS 711 Waiver Order).  
4 Id., 24 FCC Rcd at 3936, para. 11.  
5 Id., 24 FCC Rcd at 3937, paras. 13-14.  
6 Comments of Sprint Nextel Corporation (filed May 28, 2009); Comments of AT&T, Inc. (filed May 28, 2009).  
See also 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, Petition for Extension of Waiver (filed June 11, 2009) 
(Petition for Extension of Waiver).
7 47 C.F.R. § 64.604(a)(4) (emphasis added).
8 See 47 U.S.C. § 225; 47 C.F.R. § 64.601 et seq. (implementing regulations).
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5. 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.9 711 
abbreviated dialing allows TRS users (both persons with hearing or speech disabilities and voice 
telephone users) 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 toll free 
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.10 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].”11 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.”12  
6. 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.13 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.”14 Following release of the VoIP TRS Order, several 
parties filed petitions for waiver raising two distinct issues:  (1) the ability of interconnected VoIP 
providers to route the inbound leg of 711-dialed calls 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, 711-dialed calls concerning an 
emergency to automatically and immediately route the outbound leg of the call to an appropriate PSAP.15
  
9 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).  
10 47 C.F.R. § 64.604 (the TRS mandatory minimum standards).
11 47 C.F.R. § 64.604(a)(4).
12 Id.
13 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).
14 Id., 22 FCC Rcd at 11296, para. 42.  
15 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 non-geographic telephone numbers, 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 reliably 
determine the geographic location of 711 TRS callers using interconnected VoIP service).
Federal Communications Commission DA 09-1461
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7. In response to these and subsequently filed petitions for waiver, the Bureau issued a 
series of orders clarifying and/or waiving the respective obligations of interconnected VoIP providers and 
TRS providers with regard to 711-dialed calls under the applicable TRS rules.16 On April 1, 2009, in 
view of the continued technical and operational challenges presented by this requirement, the Bureau 
issued an order extending for 90 days (until June 29, 2009), the limited waiver previously granted to 
traditional TRS providers of section 64.604(a)(4),17 The Bureau allowed the waiver relief previously 
granted to interconnected VoIP providers to expire, however, noting that progress had been made toward 
resolving technical difficulties previously associated with the routing of 711-dialed calls by 
interconnected VoIP providers.18  
8. In the Notice accompanying the April 2009 TRS 711 Waiver Order, the Bureau sought 
comment on any remaining compliance issues that currently prevent traditional TRS providers from 
reliably identifying the appropriate PSAP to call when receiving an emergency call via 711 and an 
interconnected VoIP service.19 In addition, the Bureau sought comment on:  (1) the total number of 
interconnected VoIP-originated 711 TRS calls that are processed annually by interconnected VoIP and 
traditional TRS providers, and the proportion of those calls that are of an emergency nature; (2) the 
continuing need, from the consumer’s perspective, to be able to dial 711 via TRS in an emergency, rather 
than dialing 911 directly; (3) any impediments consumers have encountered in attempting to dial 911 
directly; (4) the effectiveness of providers’ outreach efforts in educating consumers about the importance 
of dialing 911 directly in an emergency when using a TTY and an interconnected VoIP service; and (5) 
the continuing use of TTYs by individuals with hearing or speech disabilities and, in particular, the use of 
TTYs with an interconnected VoIP service.20
9. In response to the Notice, interested parties filed three comments and one reply 
comment.21 In its comments, AT&T, a traditional TRS provider, explains that handling an interconnected 
VoIP-originated, 711-dialed, emergency call in compliance with section 64.604(a)(4) requires that 
traditional TRS providers:  (1) identify a 711-dialed call as an interconnected VoIP call; (2) determine the 
  
16 See April 2009 TRS 711 Waiver Order, 24 FCC Rcd at 3935-36, paras. 9-11; 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, 23 FCC Rcd 5707, 5712-15, paras. 9-14 (CGB April 4, 2008) (2008 TRS 711 Waiver Order); 
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, 22 FCC Rcd 18319, 18322-24, paras. 8-14 (CGB 
Oct. 9, 2007) (2007 TRS 711 Waiver Order).
17 April 2009 TRS 711 Waiver Order, 24 FCC Rcd at 3936, para. 11.
18 Id., 24 FCC Rcd at  3935, para. 9 n.27. 
19 Id., 24 FCC Rcd at 3937, para. 13.
20 Id., 24 FCC Rcd at 3937, para. 14.
21 See Comments of AT&T, Inc. (AT&T) (filed May 28, 2009); Comments of Sprint Nextel Corporation (Sprint) 
(filed May 28, 2009); Comments of TDI et al. (Consumer Groups) (filed May 28, 2009); and Reply Comments of 
Verizon (filed June 8, 2009).
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location of the interconnected VoIP caller; and (3) identify an appropriate PSAP to call.22 Because it 
reportedly has implemented a system to accomplish step three (identifying the appropriate PSAP to call), 
AT&T’s comments focus on the obstacles to accomplishing steps one and two – i.e., identifying the call 
as an interconnected VoIP call and determining the geographic location of the caller.23 AT&T explains 
that although it has taken steps to institute a process for determining when a 711-dialed call originates 
from an interconnected VoIP customer, the process requires that AT&T (and other traditional TRS 
providers instituting this process) assign a dedicated toll free number to every interconnected VoIP 
provider and, in turn, that every interconnected VoIP provider agree to route all 711-dialed calls through 
that dedicated toll free number.24 According to AT&T, the sizable and ever changing number of
interconnected VoIP providers, among other things, makes this approach problematic.  In addition, even if 
a call is successfully identified as an interconnected VoIP call (because the interconnected VoIP provider 
routes it over an agreed upon, dedicated toll free number), AT&T states that traditional TRS providers 
“remain unable to reliably identify the geographic location of the caller via an automated process” when 
the caller is using a “non-geographically relevant” telephone number or a “nomadic” interconnected VoIP 
service.25 AT&T estimates that it could incur $600,000 over one to two years adopting a system that 
reliably determines the location of some (but not all) interconnected VoIP callers.26 AT&T’s comments 
indicate that few, if any, 711-dialed emergency calls are placed by interconnected VoIP users, and AT&T 
thus asserts that “the disproportionate impact of section 64.604(a)(4) as it applies to VoIP originated 711 
calls” justifies granting traditional TRS providers an indefinite waiver of the rule.27
10. Sprint, also a traditional TRS provider, seeks a “permanent waiver” of the requirement 
that traditional TRS providers must automatically and immediately call an appropriate PSAP when 
receiving an emergency 711-dialed call placed by an interconnected VoIP user.28 Sprint contends that 
traditional TRS providers’ compliance with section 64.604(a)(4) hinges on the ability of interconnected 
VoIP providers to provide sufficient information to enable traditional TRS providers to determine that a 
call is VoIP-originated and to accurately determine the caller’s location.29 According to Sprint, 
interconnected VoIP providers “have yet to expend the necessary resources to enable them to provide 
location information of their subscribers who seek to place emergency calls through relay” to the 
traditional TRS providers.30 In reply comments, Verizon, an interconnected VoIP provider, explains that 
it does not object to extending indefinitely the limited waivers previously granted to traditional TRS 
providers.31 Verizon disagrees with Sprint’s claim, however, that interconnected VoIP providers alone 
are responsible for resolving these issues and asserts that the Commission’s rules specifically assign 
  
22 Comments of AT&T at 4.
23 Id. at 5.
24 Id. at 6.
25 Id. at 6-7.
26 Id. at 9.  AT&T explains that, using this system, it could reliably determine the location only of interconnected 
VoIP users who obtain service from VoIP providers that contract with third party registered location database 
administrators.  Id.
27 Id. at 11. 
28 Comments of Sprint at 1-2.
29 Id. at 1-3.
30 Id. at 2.
31 Reply Comments of Verizon at 1.
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responsibility to the TRS providers for routing emergency interconnected VoIP 711 calls to the 
appropriate PSAP.32 Verizon further asserts that, in any event, the successful resolution of these issues 
will require the collaboration of many industry participants including, but not limited to, traditional TRS 
providers and interconnected VoIP providers. 
11. The Consumer Groups emphasize the importance of ensuring that emergency 711 calls 
placed from a TTY via an interconnected VoIP service will be rapidly connected to an appropriate 
PSAP.33 At the same time, the Consumer Groups assert that if the Commission determines not to require 
the automatic routing of such calls to an appropriate PSAP, the Commission should take steps to ensure 
that such calls will be manually connected as efficiently as possible.34 While recognizing that “there 
appears to be a relatively small number of TTY users who also utilize interconnected VoIP service[,]” 
insofar as consumers with a broadband Internet connection are more likely to use Internet-based relay 
services, the Consumer Groups express the concern that there may still be TTY users who will attempt to 
connect to emergency services through 711 and relay for various reasons, including lack of awareness that 
direct 911 is the preferred method of accessing emergency services.35 Accordingly, the Consumer Groups 
ask the Commission to ensure “continued efforts to educate TTY users of interconnected VoIP services 
about the availability of 9-1-1 direct dialing.”36 In addition, they ask that the Commission take 
“significant and comprehensive steps” in a rulemaking proceeding to develop a “real-time text standard” 
for use in the IP environment for emergency communications.37 They explain that such technology would 
be capable of transporting conversational text “natively as data” rather than as “tones” over IP networks, 
and would allow text communications to be sent directly to PSAPs “as part of the next generation 9-1-1 
system.”38  
12. Most recently, on June 11, 2009, AT&T filed a petition seeking an indefinite extension of 
the current waiver of section 64.604(a)(4), asserting that traditional TRS providers “still cannot determine 
the appropriate PSAP to route a VoIP-originated 711 emergency call due to the inaccessibility of 
registered location information.”39  
III. DISCUSSION
13. The Commission may waive a provision of its rules for “good cause shown.”40 For the 
reasons set forth below, we find good cause to extend until June 29, 2010, the current limited waiver of 
  
32 Id. at 1, 3.
33 Comments of Consumer Groups at 4, 6.
34 Id.
35 Id. at 3-4.
36 Id. at 4, 6.
37 Id. at 5, 6.
38 Id. at 5.
39 See Petition for Extension of Waiver at 2 (filed June 11, 2009) (Petition).  
40 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).
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section 64.604(a)(4) of the Commission’s rules,41 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.42  
14. As noted above, section 64.604(a)(4) requires that TRS providers use a system for 
incoming emergency calls that “automatically and immediately” routes the outbound leg of a TRS call to 
an appropriate PSAP.43 The Bureau has previously noted that, 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 traditional TRS providers under a duty to handle and route these 
calls as prescribed by the Commission’s pre-existing emergency call handling rules.44  
15. The record reflects that the remaining technical and operational challenges of compliance 
with this requirement are formidable and that a comprehensive resolution of these issues will require 
significant, ongoing collaboration among a variety of industry stakeholders.45 At the same time, the 
comments suggest that the increasing popularity and availability of Internet-based forms of TRS have 
significantly reduced the number of consumers with broadband Internet access who communicate via a 
TTY and an interconnected VoIP service, rather than via an Internet-based form of TRS.46 Moreover, the 
introduction of more forward-looking solutions, such as the “real-time text” solution described by the 
Consumer Groups, is likely to diminish further the incidence of TTY use with an interconnected VoIP 
  
41 47 C.F.R. § 64.604(a)(4).
42 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.  
43 47 C.F.R. § 64.604(a)(4).
44 October 2007 Order and Notice, 22 FCC Rcd at 18324, para. 14.
45 See, e.g., Comments of AT&T at 7-9 (describing the estimated costs and the “substantial” level of cooperation 
among various stakeholders that would be needed to enable traditional TRS providers to automatically access 
interconnected VoIP customers’ Registered Location information); Reply Comments of Verizon at 1 (any solution 
to these issues requires cooperative effort from “many industry participants”).
46 See, e.g., Comments of Consumer Groups at 3 (noting that although the increasing affordability and availability of 
interconnected VoIP may make this service more attractive to TTY users, deaf or hard of hearing individuals with 
broadband Internet connections “may be more likely to use Internet-based relay services,” particularly in an 
emergency situation); Comments of AT&T at 10 (asserting that VoIP users tend to be more “technologically savvy” 
than typical TTY users and, as such, are more likely to use Internet-based TRS rather than TTY); Comments of 
Sprint at 2-3 (stating that “deaf and hard of hearing users with broadband connections to their homes and offices are 
virtually certain to use [Internet-based TRS] to meet their communications needs”).  Although the Consumer Groups 
state that “deaf, deaf-blind and hard of hearing consumers who wish to contact 9-1-1 directly currently have no 
direct 9-1-1 access through an Internet-based communications system other than through the use of a TTY operating 
through a VoIP system[,]” see Comments of Consumer Groups at 3, this statement is no longer true in light of the 
Commission’s recent adoption of a ten-digit numbering system and emergency call handling requirements for 
Internet-based TRS providers.  See generally Telecommunications Relay Services and Speech-to-Speech Services for 
Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123; E911 Requirements for IP-Enabled 
Service Providers, WC Docket No. 05-196, Report and Order and Further Notice of Proposed Rulemaking, 23 FCC 
Rcd 11591 (June 24, 2008) (adopting numbering and emergency call handling requirements for VRS and IP Relay 
providers).
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service.47 Taken together, these findings lead us to conclude that, while TTY use by interconnected VoIP 
consumers may be on the decline, there remain deaf and hard of hearing consumers who continue to rely 
on TTYs.  Therefore, while we find good cause to extend for an additional year the limited waiver 
previously granted to traditional TRS providers, in light of the continuing technical and operational 
challenges described in the record, we decline to extend the waiver indefinitely, as requested by AT&T.  
As noted above, the Consumer Groups urge the Commission to initiate a proceeding to develop “real-time 
text” technology to “enhance communication during emergency situations by people who are deaf and 
hard of hearing or who have a speech disability.”48 Although the action we take today is not intended to 
prejudge any future course of action by the Commission with respect to these issues, granting the waiver 
request before us will have the added benefit of affording the Commission sufficient opportunity to fully 
explore those issues.                    
16. Finally, we agree with the Consumer Groups that, during the period of this waiver, any 
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), must maintain a manual system for doing so, to the extent feasible, that accomplishes the 
proper routing of emergency 711 calls as quickly and efficiently as possible.49 This waiver is, therefore, 
conditioned on continued compliance with that requirement.  Further, during this period, TRS providers 
and interconnected VoIP providers must continue to undertake consumer education and outreach designed 
to remind individuals with hearing or speech disabilities to dial 911 directly (as a text-to-text, TTY-to-
TTY call) in an emergency, when using an interconnected VoIP service, rather than making a TRS call 
via 711 in an emergency.50 We also expect TRS providers to continue their collaboration with 
interconnected VoIP providers and other industry stakeholders in order to resolve any remaining 
compliance issues associated with the processing and routing of interconnected VoIP-originated 711 
emergency calls.51
IV. PROCEDURAL MATTERS
17. 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 Petition for Extension of Waiver may also be found by 
searching ECFS at http://www.fcc.gov/cbg.ecfs. 
18. 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 
  
47 Comments of Consumer Groups at 5, 6.
48 Id. at 5.
49 Id. at 4.  See also October 2007 Order and Notice, 22 FCC Rcd at 15324-25, para. 15.
50 October 2007 Order and Notice, 22 FCC Rcd at 15324-25, para. 15. 
51 In this regard, we agree with Verizon that it is not the responsibility of interconnected VoIP providers alone to 
resolve the technical issues associated with TRS providers’ obligation to route a 711-dialed, TTY call via an 
interconnected VoIP service to the an appropriate PSAP.  See Reply Comments of Verizon at 3. 
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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.   
V. ORDERING CLAUSES
19. 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.
20. IT IS FURTHER ORDERED that section 64.604(a)(4) of the Commission’s rules, 47 
C.F.R. § 64.604(a)(4), to the extent that it requires traditional TRS Providers to implement a system to 
automatically and immediately call an appropriate PSAP when receiving an emergency 711-dialed call 
via an interconnected VoIP service, IS WAIVED until June 29, 2010.
21. IT IS FURTHER ORDERED that this Order SHALL BE effective upon release.   
FEDERAL COMMUNICATIONS COMMISSION
Suzanne M. Tetreault
Acting Deputy Chief                                                                                        
Consumer & Governmental Affairs Bureau