Public Safety Groups Express Support for Numbering Waiver

January 24 2017–Several public safety entities have expressed support for a petition filed by Onvoy Spectrum LLC asking the FCC to waive rules that impose requirements on applicants for initial numbering services (TRDaily, Dec. 20, 2016). “This request serves the public interest because Onvoy has exhausted all other reasonable means to comply with the rules, and most importantly, grant of the waiver will improve public safety by allowing an innovative solution to be offered that will enable over-the-top (OTT) mobile providers for the first time to offer consumers vitally important 9-1-1 services,” according to the company. In a petition filed in WC dockets 13-97, 04-36, and 07-243, CC docket 99-200, and PS docket 10-255, Onvoy said that its solution would enable 911 to be delivered to data-only devices using over-the-top voice-over-Internet-protocol services.

The Association of Public-Safety Communications Officials-International said it “is encouraged by Onvoy’s efforts, because there is presently no 9-1-1 solution for such OTT mobile applications, and Onvoy appears to be addressing a number of important 9-1-1-related considerations. Accordingly, APCO believes it is in the public interest for the Commission to grant appropriate waiver relief to enable Onvoy to continue to pursue further testing of its OTT VoIP 9-1-1 solution.”

“As we read Onvoy’s petition, it does not seek a waiver of the authorization requirement contained in § 52.15(g)(2) of the Commission’s rules. Rather, we read the petition to seek a determination that the North American Numbering Plan Administrator’s (i.e., Neustar’s) criteria for determining whether an applicant is, in fact, authorized [to] extend beyond the requirements of the rule,” the National Emergency Number Association said. “To the extent that our reading is consistent with Onvoy’s intent, we support the petition, and urge the Commission to grant the requested relief.”

In joint comments, the Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communications Districts Association said that Onvoy should be granted the relief it seeks if it provides self-certification of approval by a 911 authority and “commits to work cooperatively to deliver all 9-1-1 calls with the appropriate Class(es) of Service and appropriate p-ANI [pseudo-automatic number identification] type as may be directed by the applicable 9-1-1 Authority …” – Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily