Navigating the FCC’s 911 Reliability Requirements
The FCC’s 911 Reliability Requirements establish important guidelines to guarantee the dependability of emergency services across the country. These regulations mandate that 911 Service Providers undertake measures to safeguard against service disruptions. Compliance with these requirements is vital for maintaining access to emergency assistance and upholding public safety standards nationwide.
In 2013, the FCC adopted its 911 Reliability Order to ensure reliable 911 service and implemented requirements for 911 Service Providers. These requirements apply to any entities that Provide 911, E911, or NG911 capabilities such as call routing, automatic location information (ALI), automatic number identification (ANI), or the equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency authority; or operate one or more central offices that directly serve a PSAP.
Under the FCC Rule, all 911 Service Providers must:
- Take reasonable steps to ensure diverse 911 circuits, backup power for central offices, and diverse network monitoring.
- Annually certify that they’ve met these requirements or provide alternative measures that adequately reduce the risk of failure.
- Notify PSAPs of any outages that might affect them.
Providers must prove compliance through yearly certifications of their efforts in three areas:
- Circuit Diversity Audits: Providers must audit critical 911 circuits, tag them to prevent loss, and remove single points of failure.
- Backup Power: They must ensure backup power for central offices serving PSAPs, test and maintain equipment, and ensure easy operation.
- Network Monitoring: Providers must audit network monitoring points, links, and centers for diversity and implement diverse monitoring points and links.
Non-compliance with these requirements can result in significant penalties for service providers which may include fines, enforcement actions, and potential revocation of licenses or authorizations to operate. Additionally, failure to meet these requirements could lead to disruptions in emergency services, compromising public safety and potentially exposing service providers to legal liabilities. Driving this point home, just yesterday the FCC announced it will investigate to determine what caused multi-state 911 outages in Nevada, Texas, South Dakota, and Nebraska that occurred on April 17.
If you are unsure about your organization’s status as a 911 Service Provider or require assistance with certification efforts, Marashlian & Donahue, PLLC is here to help. Our knowledgeable attorneys can provide guidance and support for all of your 911 Reliability Requirement questions. If you would like additional information about the FCC’s 911 Reliability Requirements, including suggestions for best practices, please contact Jonathan Marashlian at 703-714-1313 or jsm@commlawgroup.com. Further information about Marashlian & Donahue’s Emergency Services 911 practice is available here.
