T-Mobile asked for clarification of certain operational aspects o...

and pass to the PSAP the customer’s registered location includes information that the interconnected VoIP provider derives automatically from its provision of service or operation of the network, and the “provider may select and transmit the registered location that it deems most likely to accurately reflect the customer’s location at the time the customer places the 911 call.” (2) The requirement to obtain a customer- provided registered location can be satisfied without end user participation if the provider can derive the location automatically. “This will be particularly important for mobile VoIP offerings, for which an end user provided registered location may not be the appropriate location for emergency response,” T-Mobile said. (3) The provider may obtain customer-provided registered location information after the service is initiated in case it’s “not practicable” to obtain such information in advance. (4) For mobile and nomadic VoIP applications, the PSAP won’t be considered capable of “receiving and utilizing” E911 data until it can use “non-call associated signaling” and retrieve location from real-time databases. The FCC has set a timetable for CMRS carriers and PSAPs to implement necessary upgrades, and T-Mobile said “the Commission should rely on that process here.” (5) Mobile and nomadic VoIP providers, particularly CMRS carriers, that offer interconnected VoIP services may deliver location information to the PSAP for interconnected VoIP services using latitude and longitude coordinates, as is being done for CMRS E911 calls. “These clarifications are necessary to ensure that CMRS providers can provide the best possible emergency location information if providing interconnected VoIP services, and to allow CMRS providers to leverage their existing E911 infrastructure to provide such emergency services,” T-Mobile said.