Recently, the FCC clarified rules for 911 reliability certifications (TMI Regulatory Bulletin Service subscribers see Bulletin dated 8/3/15). Remember, in 2013, the FCC adopted rules requiring entities that route 911 calls and number or location information to PSAPs to implement either industry best practices or alternative measures that are reasonably sufficient to ensure 911 reliability? Covered providers must make annual compliance certifications to the FCC. Your company is a “Covered” provider if:
- You provide 911, E911, NC911 capabilities such as call routing, ALI, ANI, or the functional equivalent of those capabilities, directly to a PSAP, statewide default answering point or appropriate local emergency authority and/or
- You operate one or more central offices that directly serve a PSAP. This includes entities that provide capabilities to route 911 calls and associated data such as ALI and ANI to the appropriate PSAP
The first certification filings are due October 15, 2015. You may have more questions than answers as you develop best practices and rush to meet this rapidly approaching deadline. We thought it would be beneficial to share some of our findings with our subscribers.
Examples of questions you may have are:
- What records are required to prove the appropriate maintenance/testing is performed on back-up power supporting critical 911 circuits?
Your maintenance/test routines should refer to the manufacturer’s guidelines specific to the backup power deployed at your individual locations and results should be electronically stored and easily accessible.
- How do you ensure your vendors, involved with the provision of 911 services, cooperate with you to certify compliance?
Amending your vendor contracts to identify the related services and defining specific performance criteria brings an awareness to the surface allowing a joint effort to comply with the 911 requirements.
Other questions to consider as you develop a 911 Reliability Certification compliance strategy include:
- Do you make it a general practice to test route diversity within your network and if so how frequently is it tested?
- Will your circuit inventory be sufficient to protect the integrity of your critical 911 circuits?
- When you perform routine network maintenance, do you preserve the 911 call flow and alert the PSAPs?
- Do you have the necessary alarm triggers to respond to service outages that impact the delivery of 911 calls and are you capturing enough details adequate to defend compliance if challenged by the FCC?
The FCC also clarified that the certification framework it has adopted was intended to allow flexibility for all covered providers to rely on reasonable alternative measures in lieu of any given element of the certification set forth in its rules. As you can see from the examples provided in this article, there are significant questions that should be answered and criteria that must be met in order to meet the October 15th deadline for the FCC’s 911 Reliability Certification.
