Dash Carrier Services - Top Five Considerations for Meeting TRS and Emergency e911 FCC Mandates

Top Five Considerations for Meeting TRS and Emergency e911 FCC Mandates

George Sutcliffe in Emergency Number Professional Magazine

Last year, the Federal Communications Commission (FCC) mandated that Internet-based Telecommunications Relay Services (TRS) users must offer 10-digit numbers to ensure, among other reasons, that emergency calls placed by Internet-based TRS users will be routed directly and automatically to the appropriate emergency services authorities by TRS providers. A deadline to meet the requirements was set for December 31, 2008.

As a result, the TRS industry is going through a radical change with issuance of 10 digit numbers and being able to process e9-1-1 calls. It has taken a lot of effort and a substantial shift in mindset to satisfy the FCC mandate and it has been satisfying to meet the requirements.

COMMUNICATION OPTIONS
The Deaf and Hard-of-Hearing Community have a number of communication options when communicating with their hearing counterparts. TRS services delivered via the "Internet IP-Relay" in text form or Video Relay Services (VRS) in video form are available; both services were required to have seamless mechanisms to connect a 9-1-1 call to the appropriate public safety access point (PSAP). Text relay has been around much longer and is a more mature product, so its growth rate has been pretty flat. Meanwhile, the video relay market is growing significantly year after year, with more than 20 percent growth. On a per-minutes basis, video has eclipsed text as the dominant TRS service; it is favored by the deaf community as an easier way to communicate by using their native American Sign Language (ASL) rather than having to communicate in "written" English or Spanish - a second language for many users of TRS.

THE HUMAN ELEMENT
Beyond technical nuts-and-bolts challenges to link Internet-based services to 10 digit numbers and routing emergency calls, human elements also had to be addressed. For some in the deaf community, using IP Relay to 'dial' 9-1-1 to obtain help in an emergency was new. Interpreters and CAs also had to be trained and supported to handle 9-1-1 calls. Today, TRS users have access to e9-1-1 services and many have obtained their own local phone number. Based upon experiences over the past year, five key factors for meeting the TRS and Emergency e911 FCC mandates have been identified: 1. User education 2. User registration 3. Training and support for Interpreters and Communications Assistants 4. Call routing/systems 5. 9-1-1 and local number partners

USER EDUCATION
The general public has been schooled in the proper and appropriate use of 9-1-1 for decades, most starting at kindergarten and elementary school. For many in the Deaf and Hard-of-Hearing Community, dialing 9-1-1 for emergency services is a new concept.

While the public may take 9-1-1 services for granted, nearly 31 million Deaf and Hard-of-Hearing people have been introduced to the concept of 9-1-1 almost overnight through the introduction of 10 digit numbers and e9-1-1 requirements for TRS services. The Deaf and Hard-of-Hearing community needs to understand 9-1-1 in detail: how to physically dial and reach 9-1-1 from their preferred communication device, why it is important, when to call, and when not to call (an issue that the general public has had its own issues with over the decades).

Finally, user education is an ongoing and continuous process, both to refresh and remind existing users about the proper use of 9-1-1 and to introduce new users to the concept.

USER REGISTRATION
Assignment of a real 10 phone number is simply and easy, but being able to have that number "map" to a physical address for enhanced 9-1-1 service delivery is at the essence of the FCC's mandate. The user has to provide a physical address which then has to be validated and matched to the provisioned 10 digit number, followed by updating the record with the appropriate PSAP. In addition, a mechanism needs to be in place to allow for the quick and easy update of the user's physical address should they move.

Training and Support for Video Interpreters (VIs) and CAs While a TRS 9-1-1 call is far from a common event, video interpreters and their text-based communication assistant counterparts need to be trained in the handling of emergency communications so they can keep a cool head and make sure the call goes through. The skill sets for being a good VI or CA are different and unique from those needed to be a good emergency services operator. VIs and CAs need to be trained on how to process the call and to first be a conduit to and for a 9-1-1 operator rather than acting on a natural instinct to interact with the caller.

Support after handling a 9-1-1 call is equally important. Counseling may be needed in the aftermath of a call since the VI/CA is not typically either used to or trained for handling stressful events at the same level of intensity and frequency as a PSAP operator handling such calls as a daily part of his job.

CALL/ROUTING SYSTEMS
Flexibility in call routing is vital on both sides and is much more of a challenge than a typical 9-1-1 voice call. Nearly all 9-1-1 calls made over VoIP are automatically processed to identify if a caller is a registered user; if not, the call goes to an emergency call center where the location data is collected and then the call is routed to the closest PSAP. Complicating matters for a provider, a 9-1-1 call made through a TRS service has to deal with not one, but two call paths, plus an interpreter translating between the Deaf/Hard-of-Hearing caller and the emergency operator at the PSAP. A TRS provider has to first be able to identify and prioritize a 9-1-1 call to the top of any queue for interpreters. Once the call is established between the caller and the TRS provider with the interpreter ready to assist, a second call path has to be initiated between the TRS provider and the appropriate PSAP for the caller, based upon the caller ID and user registration information. Only when both paths are established can the caller "talk" to the PSAP through the TRS provider.

9-1-1 AND LOCAL NUMBERS
TRS users live across the United States, so the ability to both originate and terminate 9-1-1 calls anywhere in the country to the appropriate PSAP is vital. The Deaf and Hard-of-Hearing community wants the same 10 digit phone numbers as their hearing neighbors, so a service provider needs to have the ability to obtain local numbers anywhere in the country, as well as the ability to route calls directly to the physically closest and most appropriate PSAP. Both capabilities - obtaining numbers and routing calls to the relevant PSAP - require the largest nationwide coverage footprint obtainable in order to ensure the widest possible service area for the community.

SUMMARY
Through a lot of effort, the TRS industry and the telecommunications service providers it partners with are now able to provide the Deaf and Hard-of-Hearing community access to the same 9-1-1 services as the rest of us take for granted. Now that the infrastructure and support procedures are in place for TRS providers to accept 9-1-1 calls, the ongoing challenge is to continue to educate the Deaf and Hard-of-Hearing community on the existence and appropriate use of 9-1-1 service and bring them up to the same level of awareness and comfort in using such services in case of emergency.

George Sutcliffe is Vice President of Product Strategy for Purple Communications (Novato, CA). He joined Purple Communications in May 2007, as Director of Product Development, and was promoted to his current role in 2008. Prior to joining Purple Communications, George spent six years with Pac-West Telecom in various roles. George has made a positive impact on such companies as DCI, DIGI-CELL, Inc., Logix Communications, Inc. and NetStream, Inc. He can be reached at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

Dash Carrier Services (Denver, CO) is a provider of wholesale carrier products and services for IP Telephony rollouts that provides a unique, all-inclusive set of offerings to both emerging VoIP providers and established voice carriers. Its comprehensive, integrated portfolio includes dash911, E9-1-1 for VoIP, dashconnect, U.S. and Canadian origination and termination and dashinfo, CNAM, 4-1-1 and nationwide directory listing services. Founded in 2002, Dash boasts a nationwide footprint, including extended coverage to Puerto Rico, Hawaii, Alaska and Canada, and maintains partnerships with several of the industry's foremost innovators. For more information, visit www.dashcs.com.

A PARTNERSHIP
More than 30 million people are part of the Deaf and Hard-of-Hearing community in the United States. To communicate with the larger hearing community via telephone, a variety of relay services are available, ranging from a text telephone (TTY) or other device to an Internet-connected PC for text and video.

As the nation's largest provider of text relay services and second largest provider of video relay services to the Deaf and Hard of Hearing community, Purple Communications of Novato, CA had a lot to consider as it worked to meet the FCC's new requirements. The use of a communication assistant (CA) to provide a bridge between Internet text-based communication and the PSTN is nothing like a traditional voice carrier, due to the interpreter-in-the-middle requirements to facilitate the communication between the Deaf and Hard-of-Hearing Community and their hearing counterparts.

At the beginning of 2008, Purple Communications began working with Denver, CO-based Dash Carrier Services (Dash) in a collective effort to help meet the new FCC mandates for TRS, with a more formal relationship announced in March 2009. Dash, a provider of wholesale carrier products and services for IP telephony, supplied Purple with the telephony solutions to quickly and easily order, provision and modify DIDs, and pass e9-1-1 emergency services information through a Web-based application provisioning 'dashboard.'

"SELLING THE JOB"
A number of telecommunications service providers offer the ability to obtain a 10 digit phone number, get it provisioned, and have the number mapped and then validated to a physical address, but Dash had clear advantages. In addition to a Web interface with a complete API and a branded end-user portal for address changes, Dash's address geo-coding has a 99 percent address acceptance rate on the first submission, translating to a lot less manual work during the registration process.

Call routing is much more complicated with a video interpreter in the middle. Purple has to be able to identify and prioritize a 9-1-1 call to the top of the queue for a VI or CA, regardless of the device and means of communication selected. At the same time, Purple has to make an outbound call into Dash's network. Using information based on caller's identification and registration information, the call has to be routed by Dash to the correct/closest PSAP to the caller. Once both sides of the call are established - caller to Purple, Purple to PSAP - the conversation between the deaf caller and emergency call center can take place.

Among the key capabilities that Dash offered was the largest footprint of coverage across the U.S. to terminate a 9-1-1 call and a superior ability to obtain numbers within that footprint. Dash has 92 percent enhanced PSAP coverage. With more than 31 million people in the Deaf and Hard-of-Hearing Community, Purple needed a service provider with the widest possible footprint.

All of these considerations play a role in successfully implementing e9-1-1 service for TRS customers. Dash was extremely helpful in helping meet their deadline and proved to be a reliable, effective partner through the process and they had flexibility to work in a unique environment.