What Can We Expect from Number Order?
6 01 2009Happy New Year, Folks!
Here are two links to the Number Order by the FCC. First one is the “advisory comments” of the Number Order, and the second one is the Number Order in itself in its all complication splendor.
FCC Consumer Advisory (same one as the last post)
Full blown Order on Number - if you want gritty details, click to this one.
I may need to follow up with a few Vlogs or blog or comments on the recent Number Order by the FCC. I will decide on which particular issues to cover with based on comments and video calls I will receive from some of you. At any rate, I will try to pull out information that is important to consumers, and leave out the techo-babble and cost reimbursement stuff.
One thing is clear from the Number Order, though, is that all of us can get Local Telephone Number (abbreviated to LTN) from VRS and IP Relay Providers. That’s GREAT news and Exciting!
Here are the basic items:
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Once deaf/HOH gets LTN, the LTN can be shared with other deaf who have VP; but it cannot be just any VP, it has to be a VP that deaf/HOH got from a VRS provider.
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Meaning if a deaf person has a PolyCom Video Phone or pretty much any video phones that were not distributed by VRS providers, he/she would need to use an Internet Protocol Address to call other VRS users. If you did not get your video phone from a VRS Provider, you will not be able to use that video phone to call 9-1-1. Please use your TTY instead.
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Your LTN can be shared with any hearing person. Hearing persons do not need two sets of phone numbers to contact a VRS user. Your telephone number will automatically connect to hearing through the default VRS provider that YOU chose.
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Most VRS Providers, who gave you the equipment, may contact you to ask you to register to get a telephone number. This telephone number will be what 9-1-1 identifies when you dial 9-1-1 during times of an emergency.
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Only VRS and IP Relay Providers can give you a new telephone number. You cannot get a telephone number from a phone company that is not associated with VRS or IP relay service (not now, maybe in the future).
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Once you get the LNP, you can use it immediately (nice).
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Only deaf/HOH can get telephone number for Video Phones; hearing person at this time cannot get LNP for video phone. (The following is my comment: I was disappointed to see that, and sincerely hope that will change in the near future as many of us have hearing relatives, friends and business associates who can sign.)
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Deaf/HOH MUST register with VRS Providers, no exceptions; this means giving your name, address, where you live, and any important information that E911 may need to know.
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VRS providers are allowed to verify by whatever means to ensure that deaf/HOH live at that address; not unlike credit card, bank accounts, etc.
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In addition, VRS providers MUST verify that registrants are deaf/HOH, and allowed to employ procedures to determine that.
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§ So if they ask you questions, these are the reasons why.
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The FCC allows for you to use the current “fake telephone number” (alias and proxy numbers) you have been using up to 6 months. After 6 months, these numbers will not be allowed; 800/866 will be permitted only if “geographical telephone numbers” are assigned to 800/866 numbers.
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In other words, deaf/HOH must have registered and received your telephone number first, before you can use 800/866.
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First 3 months are for “eligibility period”, and the last 3 months is a “permissive calling period”. Meaning that VRS users must register within the first three months.
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After 3 months, VRS providers are required to notify any VRS calls they receive that VRS users will need to register for LNP. After the cut-off time (June 30, 2009), VRS providers will not process any VRS calls if the Video Phone user is not registered with any one of VRS providers.
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Deaf/HOH persons are allowed more than one LNP; for example, one LNP for Video Phone, and one LNP for pager/laptop.
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Right now, due to technical reasons, you will not be able to use the same telephone number for multiple devices in your home. Meaning, if you have an Ojo downstairs, and a Sorenson VP200 upstairs, you will need to get a separate telephone number for each.
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Hopefully in the near future, when all the equipments are compatible with new standards in place, you will be able to have same telephone number for each device in your home even if different from each other.
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However, if you have, for example, two VPADs in your home, i.e., downstairs and upstairs; you can use the same telephone number for both of VPADs.
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You will need to check with your provider first to make sure the devices they gave you can do this type of set up.
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To have the same telephone number for VP and Cell Phone/Pager is not possible; each must be assigned a LNP separately.
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However, VRS providers can if they have the feature of “forward call” where a VRS call can be forwarded to IP, or vice versa. That is up to VRS providers to offer that, the FCC does not disallow that.
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All 911 calls processed by VRS providers must have the capacity to:
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Carry a call back number; for example if the video call got disconnected, then Video Interpreter will need to be able to call back to VRS user immediately.
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Name of relay provider
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Video Interpreter or IP Relay Agent identification number
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The Caller (deaf/HOH) Registered Location (data needed for the emergency dispatcher to know where/who/what)
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Video Interpreters during an emergency call are allowed to record everything in case the call to emergency dispatcher gets disconnected, and Video Interpreter will be able to relate to emergency dispatcher what happened.
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VRS providers are required to put any 911 VRS call to top of its queue waiting list.
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VRS providers CANNOT break into any VRS calls they are processing and close the regular VRS call then accept an emergency call.
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When connecting to a 9-1-1 through VRS the Video Interpreters are allowed to identify pertinent information from viewing VP (see fire, gun waving around, etc.) that may help emergency dispatcher assess the situation realistically.
The following issue is bit complicated; try to read this carefully.
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Portability Issue: what this means is if you are not happy with the VRS service you signed up with in the beginning and want to make a switch to a new VRS provider, all it requires is that you, the deaf/HOH person, can simply go to the new Provider and tell them you want to use their service and keep the telephone number you have. The new Provider will contact the old Provider to work it out. You do not have to talk to the old Provider at all.
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Important for you to know that at this time; if you switch to new VRS provider, you may not get the same features that you had with previous VRS provider. The new Provider may not have the technical standards to continue the VP’s look on your screen. So it is very important that you ask if they can do this before you make the switch. Not all Providers are up to par yet. If the new Provider cannot manage your existing videophone from their end, then you may be given a new video phone from the new Provider and you should still be able to keep your telephone number.
If you have problems with above, please feel free to share with me so I can inquire with the E911 Stakeholder Council of which I am member of and working on these issues.
Well, that is about it. Do let us know what you think of this and do feel free to ask questions; I will either respond via comment or vlog.
eyes open & thumbs up,
Ed B

This is wonderful news. Would not have hapened w/o your prodding.
can you get into the issue about the vp calls made in between 2 different brands of vps such as ojo to vpad or vp200 to Z devices? unless I am overlooked from previous statements, should it work with LTN rather than IP or is it just limited to the same brand of device?
I sure am looking forward to get same access as hearing people have!
thanks!
Ricky,
Yes, LTN is supposed to make it possible to make vp calls between two different brands of VP, however, VPs need to come from VRS provider. If any one is not able to call simply by using TN to another VP of different brand, then need to let VRS providers know of this and if they do not resolve that, let the FCC know of this.
I’m excited about this, too.
eyes open & thumbs up,
Ed
Wonderful discussions!! Keep up the great work! Curious if there’s many others who are fighting for our rights with FCC your collaborating with?
thumbs up too! =)
So…for deaf people using Internet relay services/providers, if they still hasn’t registered for LNP after 3 months of “eligibility period”, and also after the last 3 months of a “permissive calling period”, they are not allowed to register at any provider because they waited too long and therefore are too late to receive LNP?
I know that some of my deaf friends still HAVEN’T heard about the FCC rulings or the ten-digit numbering system yet. (And what about those who are unable to afford high speed internet? That is worrisome!)
Ed
I want to make clarification on the last part about Probability Issue. If I want to use CSDVRS on my VP-200 then I need to contact CSDVRS and they will deal this with Sorenson. Correct?
Thanks for the valuable information.
David
Hi Ed…
In reference to the following exerpt…
The FCC allows for you to use the current “fake telephone number” (alias and proxy numbers) you have been using up to 6 months. After 6 months, these numbers will not be allowed; 800/866 will be permitted only if “geographical telephone numbers” are assigned to 800/866 numbers.
Two questions:
1) What will ensue if the VP user does not register past June 30, 2009? Will the VP still be functional as before, but without any VRS or 911 service?
2) Will the proxy number still work for VP to VP calls after June 30, 2009?
Thanks and regards…
Ken
Just curious – wonder if I can keep one vrs provider and use other vrs provider to make calls?? If not, that means “hassling and pain in the …….” to change the whole thing..
U see lately I keep one vrs provider who gave me the ph nbr and I then use other vrs to make calls does that clear to u and others?????
I admit I dont like to make call from a certain vrs provider for it makes me wait toooooooooooo long which doesnt meet FCC’s rulings – that’s why I switch to other vrs provider to make calls …
Thanks for keeping us updating post from FCC which we all really appreciate it very much…
GO HOGS TUSK HORNS! (AR NOW PLAY BASKETBALL GAME AGAINST HORNS SMILE!)
Outlawery,
TDI, NAD, and few other national and state organizations are fighting for consumer rights. There are also quite a few individuals who sends ex parte comments to the FCC on a regular basis.
Frankly, we could use more of the latter as the FCC does read comments from consumers.
Cheers…
Ed
Jane,
No, the first three months means any deaf/hoh can call any VRS providers without TN, and the last three months means VRS providers will need to “alert” VRS users the need to get a TN, but will still provess VRS calls. Then end of 6 months means that any deaf/hoh who do not have TN will not be able to make a VRS calls. Any deaf/hoh can get TN anytime after 6 months. So once deaf/hoh gets a TN after 6 months, they can make a VRS calls.
On your last comment about those folks who cannot afford Internet Service. Yeah, that is an issue, but hopefully this is a small percentage of the entire deaf/hoh population.
Ed B
David B,
You got that right. Be sure to ask CSDVRS, though, that will you as VRS user be able to use VP-200 with CSDVRS? If the answer is yes, great. If the answer is no, then you may need to give up VP-200 and use one of the CSDVRS’s video phone instead.
Ed
Ken,
What it looks like is that if a person does not register past 6 months, he/she will not be able to make VRS calls or 911. He/she may be limited to making calls to same VP brand; in other words, Ojo to Ojo. However, according to the FCC rule, it does appear that proxy numbers are to be discouraged after 6 month period. So if I read order right, it is possible that fake numbers will be discontinued entirely.
Your question whether VP itself will still be functional if still not registered after 6 month? Yes, but with Internet Protocol address, not TN.
Ed
May,
Most certainly you can call any other VRS providers. Keep in mind that if you get a TN from your chosen VRs provider means any incoming VRS calls will go thru the VRS provider that you chose as your default VRS provider. However, you can call any other VRS providers even if you have one default VRS provider.
Cheers…
Ed B
Happy New Year, Ed!
As usual, great job explaining in depth about LTN. One quick guestion… If a person did register for LTN from VRS provider and/or IP provider, does s/he keep its toll free number from a VRS provider for good as well as free to us, VRS users?
Jack,
Happy New Year to you, too…
Yes people can keep 800/866, but people need to understand that to keep 800/866, they must get Local Telephone Number because after June 30, 2009, the 800/866 – if people did not register by then – may no longer work.
As for “free” toll free number. The FCC has said that the Interstate TRS Fund will NOT reimburse VRS providers for the free toll number, so it is up to VRS provider to decide if they want to give them away free or start charging VRS users.
eyes open & thumbs up,
Ed
Ed, thank you for the latest info you wrote in your blog regarding the Number Order by the FCC. However for me, it raised many questions I really need answers. Perhaps you can. Here are several questions as follows:
1. What does LNP stand for? Does this indicate that is the land line phone
which I have had for years? I have heard stories that many deaf
people are giving up their own phone because they want to save
money and everything can be communicated with “Free VP services.”
Is it essential to keep one landphone number on hand so one can dial simply the 911 number on a phone?
2. Of all the 800 numbers given to me by various VRS companies,
does it mean that these numbers would not last more than 6 months?
It sounds like I must make use of it perhaps once or twice within six
months. If I lost one 800 number from a VRS company, will I be able
to get it back or do I have to register again?
3. How can I decide which VRS service is the best for me if I dont
try them out all? I cannot decide this till after several months of comparison
then I can select one for E911 service. I wish there is a time limit
for one to compare each different type of services before picking one
for emergency service.
4. Because I lost my Sidekick pager a few weeks ago and I am in the
process of purchasing iPhone as my new pager. Will I be able to make use
it for E9111 services?
5 If a deaf or HOH person wants to use telecaption phone communication, is it necessary to register for ten digit numbers? Do they get it from Ultratec or Sprint? Will it work for E911 service using the ten digit numbers?
6. I know some people do not use vrs at all because they use exculsively the IP relay set up on there computer. How does this work out with the E911 if they dont use the VRS relay services much? Hope you get the gist of what I am saying.
Hope you or your readers can help me with all the things I need to understand above.
Happy New Year to all of you.
Steve Brenner, Potomac, MD
Steve,
Good questions. I do not know all the answers, but for those I don’t know the answer, I can give you best educated answer.
Q#1: LNP stands for Local Number Portability which is same as Local Telephone Number – landline phone number. With LTN or LNP from VRS and IP Relay providers, one can call E911. Question is should deaf/hoh give up regular phone network and use VRS or IP Relay instead since they now can access E911? That will be up to them to decide that. Remember regular telephone network does not depend on electricity to make 911 calls while VRS does, IP Relay with pager use battery.
Q#2: the 800 numbers. vlog explained that you need to first get LTN from VRS providers to make the 800 work. At least that is how I understood it to be.
Q#3: Welcome to the competition. Just like hearing folks, they cannot try out all the services, they go by advertising.
Q#4: if IPhone can do IP Relay, then should be able to get LTN for the pager and then one can make e911 calls.
Q#5: telecaption phone communication? I do not think it is part of VRS or IP Relay services, if so then no can’t get LTN for that.
Q#6: The Number Order REQUIRED that IP Relay can access E911 including laptops, pagers and computers. I do not know if the technical issues have been FULLY resolved or not. You will need to ask the IP Relay provider if they can or not.
eyes open & thumbs up,
Ed
Ed, Thanks for explaining…I understand better now.
Muchos Gracias, Ed… Until the next tete-tete…
Great topic! One of my deaf friends who I met on a popular deaf dating site deafloving dot com told me aobut your blog. So am here now. Thanks for the valuable information. good job!
FAQs about E-911, 10-Digit Numbers and Local Number Portability, from Purple Communications Inc. http://www.purple.us/advisories/faqs.html (text format)
More about E-911, 10-Digit Numbers and Local Number Portability. http://www.purple.us/advisories/index.html (text and vlog format)
10-digit Number: Myths and Truths http://www.hovrs.com/purplenumber/Default.aspx (vlog format)
Purplelicious,
John R.
I came across this blog looking for help with the new FCC 10-digit number rule. I’m an I.T. support contractor at a large US Gov facility. Unless I’m missing something, this ruling is BAD NEWS for our deaf/HOH users. It means they will LOSE access to phone relay service from the office. Why? Because the FCC now insists on tying your identity on relay to a public IP address. As I understand it (mostly based on info from nextalk.net), if your public IP address changes, you have to re-register the address. Won’t work. Big facilities use network address translation (NAT), DHCP with private IP addresses, proxy servers, multiple firewall levels… By the time you get out to the Internet your IP address could be anything and could change often. Daily? At least. So your registration ‘breaks’ and you get no relay service.
The irony is that this ‘feature’ seems to exist just to support E911, and E911 doesn’t WORK at our facility. We have on-site security/fire/medical service that takes all emergency calls instead.
I really hope I’m misunderstanding this, because I don’t know what we are going to do.
Larry,
Let me do a little digging and will get back to you or if I can persuade a geek from VRS industry to comment directly. Hold ur horse, but not ur breath for the time being ;-]
Another issue that was recently raised was outfitting deaf schools with video phones; many of the locations are really public, so how to deal with that?
I’m sure that the FCC will allow that, but I think will require someone to submit a request of clarification to the FCC on this.
Finally, I think a few – not all VRS providers, can handle dynamic IP Address in one location so you may want to check out other VRS providers whether they can or not.
eyes open & thumbs up,
Ed
Larry,
I got two responses from acknowledged experts. Basically they said dynamic ip address should not be a problem.
First response:
“Ed:
The system is designed to work with dynamic addresses and updating of those addresses is automatic rather than something that the user must do. It certainly works with DHCP etc. A public IP address was always required to communicate with a VP, simply because that’s all the public Internet can route on and I know that service providers were previously able to adapt to reach users behind corporate networks. The design arguments in developing iTRS involved how to take the information that relay providers already used to set up calls (but held privately) available to other relay providers. My question is whether a problem has actually been encountered or someone is speculating about a problem based on a reading of second hand information.
If folks are encountering problems these need to be reported to the chosen relay provider in sufficient detail for them to be worked. I expect that all parties, including corporate and government location IT support, will work together to resolve these.”
Second response:
“Video Phones used for VRS are designed to announce their public IP address, which could be NATed from an internal private address, to their default video relay provider. The VP usually gets its IP address via DHCP and it can change often and still work. The database is dynamically updated with the current (public) IP address. What is required is a way to contact the device when an incoming call is received. This is usually accomplished by establishing some kind of port forwarding to the device, which does take some firewall configuration. The 10 digit number scheme does not change the way VPs handle addressing from what it was before the 10 digit plan was put into effect. As with any other public service, private proxies have to be completely transparent to the VP signaling, which is standard H.323.
There would be some level of concern on E9-1-1, but it is the same level of concern if 9-1-1 was called from a cell phone. Effectively, you get the same result. If calling 9-1-1 from a cell phone next to the device gets you the internal response agencies, then it is very likely a 9-1-1 call from the VP will get the same response.”
Hope that answers your question.
eyes open & thumbs up,
Ed
Thank you, Ed. My issue is with Telecommunications Relay Service (TRS), specifically IP-Relay (TTY to Voice using PC and Internet connection), not Video Relay Service (VRS or VP). I think this is the users’ preference; at least, AFAIK, they have not requested cameras for their PCs. Sorry for any confusion. The answers above seem specific to VRS.
I’ve read some more, looked at information from other providers, and even tried to read through the FCC order. The information seems to differ between VRS and TRS/IP-Relay.
In the FCC order, it says that a LTN for VRS will be mapped to a URI with IP address and protocol, and a LTN for IP Relay is mapped to a URI with domain name and user name. Which makes me think maybe they don’t need a fixed IP address for IP-Relay. But the relay provider we have used does not distinguish. Here is the part of the “consumer advisor” on one relay provider’s registration site:
IMPORTANT information about your dynamic IP address:
In order to keep your E911 information current and ensure delivery of all
your voice-inbound calls, your relay service provider must know the IP
address of your registered device AT ALL TIMES. Your IP Address is what
‘links’ your device to your ten-digit number. Many individuals have a
‘dynamic IP address’, which means the IP address assigned to your device
periodically changes. How often your IP address changes depends on your
local Internet Service Provider.
NOTICE:If and when your dynamic IP address changes, the ‘link’ between your
IP Address and ten-digit number becomes broken.
To adress this problem and to keep our records current, each night our
system will send a signal to every registered IP Address. This action will
tell us if your dynamic IP address is the same or has changed. If we
determine your IP Address has changed, you will be notified via email. In
the email, you will be directed to a webpage to update your IP Address
information. It is crucial you update your IP Address information
immediately to avoid interruption of your voice-inbound calls. You will
continue to receive daily email reminders until you update your IP address
registration information.
From first response:
> The system is designed to work with dynamic addresses and updating of
> those addresses is automatic rather than something that the user must do.
Not automatic, according to the relay provider’s signup information above.
From second response:
> What is required is a way to contact the device when an incoming call is
> received. This is usually accomplished by establishing some kind of port
> forwarding to the device, which does take some firewall configuration.
Straight-forward with a typical home DSL or cable broadband setup.
Pretty much impossible in a medium-to-large business.
I will continue my research, probably check other providers.
Thanks again for the information.