FCC to VoIP carriers: zero tolerance for vague E911 language

Colleague Ben Charny points to an Federal Communications Commission E911 VoIP provider compliance directive that upon reading, is more strict and specific than has generally been reported.

I've just read the 91-page document, and it appears that the FCC order expects all VoIP providers to adhere to very specific E911 customer notification practices.

Very strict. No exceptions. No excuses. Zero tolerance. Not hidden away in fine print, or irretrievable because of clumsy VoIP-provider site navigation or language.

Here's the notification language that quite literally jumped out at me when I read it this morning:

Although many VoIP providers include explanations of the limitations of their 911-like service (or lack thereof) in the Frequently Asked Questions sections on their Web sites or in their terms of service,153 recent incidents make clear that consumers in many cases may not understand tat the reasonable expectations they have developed with respect to the availability of 911/E911 service via wireless and traditional wireline telephones may not be met when they utilize interconnected VoIP services.

In order to ensure that consumers of interconnected VoIP services are aware of their interconnected VoIP service's actual E911 capabilities,by the effective date of this Order, we (the FCC) require that all providers of interconnected VoIP service specifically advise every subscriber, both new and existing, prominently and in plain language, the circumstances under which E911 service may not be available through the interconnected VoIP service or may be in some way limited by comparison to traditional E911 service."

VoIP providers shall obtain and keep a record of affirmative acknowledgement by every subscriber, both new and existing, of having received and understood this advisory. In addition, in order to ensure to the extent possible that the advisory is available to all potential users of an interconnected VoIP service,interconnected VoIP service providers shall distribute to all subscribers, both new and existing,warning stickers or other appropriate labels warning subscribers if E911 service may be limited or not available and instructing the subscriber to place them on and/or near the CPE (Consumer Premises Equipment) used in conjunction with the interconnected VoIP service.