FCC Seeks Comment on Revising 911 Network Reliability Rules

Updated: Jun 22, 2018

On June 13, 2018, the FCC’s Public Safety and Homeland Security Bureau (the “Bureau”) released a Public Notice (“Notice”) seeking comment on the Commission’s rules regarding the reliability of 911 networks, including notifications to Public Safety Answering Points (“PSAPs”) of network outages affecting 911 service (DA 18-612, PS Docket No. 13-75).

Under current FCC rules, “covered 911 service providers” are required to: 1) take “reasonable measures” to ensure 911 circuit diversity, availability of central office backup power, and diverse network monitoring; 2) certify annually to their performance of these measures, or to alternative measures demonstrated to be reasonably sufficient to mitigate the risk of failure; and 3) notify PSAPs of outages that potentially affect them. When the Commission adopted these rules in 2013, it committed to review them in five years to determine if they remain appropriate. Therefore, the Bureau is now seeking comment regarding the following aspects of the 911 reliability rules:

Current 911 Reliability Rules

  • Effectiveness of Current 911 Reliability Rules. The Bureau seeks comment on the effectiveness of the existing reliability requirements in preventing Next Generation 911 (“NG911”) outages, any examples of specific measures or most effective measures to prevent outages, and any suggestions for other or alternative modifications to the current requirements to improve reliability.
  • Alternatives to Current 911 Reliability Rules. The Bureau seeks comment on whether the existing 911 reliability rules should be replaced with an alternative framework, suggesting either a general reasonableness requirement to ensure network reliability rather than specific mandated measures or a certification of implemented best practices, and how new requirement frameworks could be measured and implemented to ensure reliability.
  • Utility of the Certification Process. Where covered providers are required to take reasonable measures to ensure reliability, the Bureau seeks comment on whether the annual certifications of those measures should still be required and if so, whether the frequency of certification filings should be revised. Additionally, the Bureau seeks comment on whether certifications have provided value, and if not, whether this requirement should be eliminated.
  • Costs of Reliability Rules. The Bureau seeks comment to refresh the record on the annual costs of reliability measures and performance certifications since last assessed in 2013, and seeks comment on the potential costs of any proposed alternative measures.

Scope of Covered Entities Subject to 911 Reliability Rules

  • Definition of a Covered 911 Service Provider. In 2013, the 911 reliability requirements were limited to covered 911 service providers’ 911 networks. The Bureau seeks comment regarding whether the term “covered 911 service provider” still adequately encompasses industry participants and on any instances where it may be unclear where a service provider fits within this category. The Bureau further asks whether the Commission should revise the definition of “covered 911 service provider,” and how to broaden the definition to include other examples of service providers that are not currently included in the definition but are integral to 911 reliability.

PSAP Notification Requirements

  • Effectiveness of the Current PSAP Notification Requirements. In the 911 Reliability Order, the Commission required covered 911 service providers to: 1) notify affected PSAPs within 30 minutes of discovering a 911 outage by telephone and in writing; and 2) update PSAPs within two hours of their initial contact. The Bureau seeks comment on the effectiveness of these rules in helping PSAPs gain timely information about outages.
  • Standardization. The Bureau seeks comment on whether outage notifications should be standardized, and if so, whether existing templates or recommendations provide a reasonable model on which to base a PSAP notification template.
  • Streamlining. The Bureau seeks comment on whether it is feasible to reduce the number of multiple notifications that PSAPs receive for the same outage event, and if so, what measures could be taken to streamline notifications.

Comments are due July 16, 2018.

Reply comments are due August 13, 2018.

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