VoIP Providers Closer to Getting E-911 Signoffs From All Customers

AT&T told the agency it had a 93% response rate by Sept. 1, but probably will lack signoffs from 4-5% of customers by Sept. 28. Vonage reported 97% of subscribers have responded but said “given the size of Vonage’s subscriber base, it still must obtain acknowledgments from thousands of customers” so it can’t say for certain it will meet the deadline. EarthLink said the vendor providing its VoIP service has acknowledgments from 85.4% of customers, estimating about 12% will be lacking by the deadline. McLeod, which said its service didn’t come under the FCC process, still agreed to follow the educational process, reporting it had responses from 81% of subscribers and estimating it would be 10% short of full compliance by Sept. 28.

XO Communications reported 75.5% of subscribers submitted acknowledgments, and 0%-20% probably will remain outstanding as of Sept. 28. “It is impossible to give a reliable estimate of the percentage of subscribers” who won’t acknowledge, XO told the Commission. The company said it sent 3 e-mail messages seeking acknowledgment, enclosed a reminder in bills and finally “XO personnel began contacting subscribers that had not responded to the series of e-mails in mid-August.” All future communications will seek acknowledgments and warn that “the FCC expects us to discontinue your VoIP service by September 29th unless we obtain acknowledgment,” XO said.

The FCC ordered VoIP providers to disconnect customers who don’t acknowledge providers’ educational materials by Sept. 28. The agency recently opened the door to so-called “soft” disconnects for such customers but some VoIP providers said that option would be hard to accomplish. With a soft disconnect, customers could make only 911 calls, with other calls blocked or routed to customer representatives who would ask for the acknowledgments. Vonage said it’s in the process of implementing a soft disconnect. Once a customer submits an acknowledgment, service would be restored, it said. EarthLink said its vendor would use a soft disconnect procedure. “The account will remain active, but in order to have regular service reinstated, the subscriber will need to go to their web account and accept the 911 Dialing Notice,” EarthLink said.

However, AT&T said it will disconnect non-responding customers “with the result that they will not be able to place any outbound calls whatsoever (including 911) and will not be able to receive any incoming calls.” The company said it can’t do a soft disconnect by Sept. 28. It does plan to use an “intercept message” starting today (Thurs.) to tell customers they must give a E-911 acknowledgment or face disconnection Sept. 28. Once the intercept message process begins, AT&T will block non- responders’ outgoing calls, though they still can get incoming calls and make 911 calls, the company told the FCC. It said it could continue that process beyond Sept. 28 but couldn’t do the type of soft disconnect the FCC envisions. Besides, AT&T said: “AT&T believes that if a customer has ignored repeated warnings from AT&T for 10 weeks and has been prohibited from making outbound calls for two weeks absent acknowledgment, that such a customer has no intention of providing the level of acknowledgment required by the Commission to maintain his or her service,” the company said in its report.

Covad said more than 88% of customers have acknowledged the warning and it thinks “most” will do so by the deadline. It “continues to examine the feasibility of implementing a ’soft’ or ‘warm’ disconnection” for remaining customers, it said. XO said it too isn’t sure if it will use soft disconnects. It said it’s still “determining the technical, operational and financial feasibility” of such disconnects.

Verizon said it has gained acknowledgments from all its VoiceWing customers because it has been alerting them to the E-911 limitations since the service began last year. SBC reported it gained acknowledgments from “all but one” of the business customers subscribing to its PremierSERV Hosted IP Communications Service (HIPCS). SBC said it would disconnect the customer Sept. 28 if no acknowledgment is given because it would be too difficult and costly to design a soft disconnect for one customer.

Cox, which operates as a regulated carrier, warned that some state regulators may not let carriers disconnect customers: “Many states have disconnection rules that require a specific basis for disconnecting customers. In light of such rules, one state commission has informed Cox that it will sanction Cox if it implements even a soft disconnect for VoIP customers. In another state, the state commission requires that a company seeking to disconnect any customer under any circumstances must formally seek prior approval, which is a lengthy process.” Cox said its tariffs also “constrain Cox’s ability to disconnect customers.” Its tariffs list specific reasons for disconnecting customers and “failure to provide an acknowledgment of receipt of the E911 notice is not a ground for disconnection under Cox’s tariffs.” Cox said it expects to get 100% customer return on acknowledgments but if some customers don’t sign off, Cox isn’t sure it would opt for a soft disconnect. It said the soft disconnect process involves several steps. For example, “for each soft disconnect, Cox must create a work order to put a service code on the customer’s account, must program its switch to limit the customer’s service… and must have a process for reconnecting the customer.”