Under rules enacted last year, all covered 911 service providers that provide 911, E911, or NG911 capabilities must submit information to the FCC about their networks and their efforts to make them more reliable by October 15, 2015. Collecting the required information on circuit diversity, power backup, and diversity of network monitoring is part of the FCC’s 911 network reliability rules (see JSI’s October 17, 2014 e-Lert).

“Covered” 911 service providers are defined as all carriers that provide 911, E911, or NG911 capabilities, such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency and/or operate one or more central offices that directly serve a PSAP. Carriers that simply route 911 calls from their customers to the 911 system are not affected and do not need to file this information with the FCC.

The electronic system required for filing these reports is now available at https://apps2.fcc.gov/rcs911/.  Companies can start submitting information at any time.

In this first annual filing, companies must demonstrate that they have made significant progress toward meeting the circuit diversity, power backup, and diverse network monitoring criteria. Significant progress is defined as 50% of the circuits meeting the criteria. The FCC clarified in its July Order on Reconsideration that companies may certify to alternative measures to insure reliability for circuits that do not meet the criteria. But those companies must explain how alternative measures will mitigate the risk of failure of the 911 system and are comparable to the criteria in the rules.

If you have any questions, please contact Valerie Wimer in JSI’s Maryland office at 301-459-7590.

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