Webinar: Reviewing Critical Federal 911 and Outage Reporting Requirements, Jan. 25

2022-01-11T14:03:28-05:00January 11, 2022|Webinars|

Don’t chance an FCC fine (or worse) due to a 911 outage

No service you provide to your customers is more vital than making sure they can reach 911 quickly and easily in an emergency. And the FCC feels the same, hitting several companies recently with multi-million-dollar fines for not delivering emergency calls and fully complying with federal 911 outage reporting rules.

These recent enforcement actions, along with the latest enhanced 911 location accuracy rules, make this a critical time for providers to review their current procedures. Join us for a webinar on Tuesday, January 25, 2022, at 2 p.m. Eastern when our 911 experts will cover:

  • Details and best practices for network outage reporting, especially outages caused by natural disasters;
  • Complying with the annual 911 Reliability Certification requirement;
  • Future rule changes the FCC is considering;
  • Additional information about the FCC’s 911 location accuracy rules; and
  • Best practices for network resiliency and public safety that are not required, but highly encouraged.

All service providers that connect calls to a 911 system need to be aware of and fully meet these obligations. Those companies that provide 911, E911, or NG911 capabilities directly to Public Safety Answering Points or that operate one or more central offices that directly serves a PSAP are especially important to the emergency response system and absolutely must be sure they’re complying with all of the FCC’s 911 rules. Dropping the ball on these services not only can bring the FCC’s Enforcement Bureau to your door, but also can result in a public relations nightmare for your company. Don’t take that chance.

Registration for this webinar is $249 per company. (Can’t make it on the 25th? We offer recordings of our webinars as well.)


Contact Jessica Wick or Brenda Cordwell in the Maryland office at 301-459-7590 for more information about this webinar or questions about registration.

JSI Webinar: 911 Round Up – Implementing Location Accuracy & Next Gen Requirements

2021-12-07T17:05:14-05:00August 30, 2021|Webinar Recordings|

The nation’s 911 system continues to evolve in an effort to improve emergency service responses. In January 2022, all voice calls delivered to 911 PSAPs must include the caller’s detailed location information, including for those callers on mobile and nomadic networks. As well, states have begun implementing Next Generation 911 (NG911) which would allow callers to send even more detailed data—such as videos, images and texts—to 911 call centers.

Voice service providers must stay abreast of these changes and comply with any related requirements in their switches and networks. JSI invites you to a webinar on Thursday, September 9, 2021, at 2 p.m. EDT where our experts will go over requirements, including a review of fixed location rules, and what you can expect in the coming months, including:

  • Your responsibilities as a voice provider to help with these 911 improvements;
  • Location information that must be shared and how to get the additional location information from the customer;
  • Steps you can take if you’ve run into problems delivering location information;
  • What to expect as NG911 is implemented and what additional costs you might incur;
  • Technical requirements for NG911 and what will be asked of you; and
  • How to respond to AT&T Wireless’ request for interconnection agreements related to ESInet.

As you’re aware, not complying and implementing these 911 enhancements can be a matter of life and death for someone in need of emergency services. Don’t risk a tragic outcome or even an enforcement action and PR nightmare. Stay informed and take the necessary actions to make your local 911 service the best it can be.

Purchase Recording

Sorry, you missed this webinar! But, a recording of this webinar is available for $249. If you would like to purchase the recording, please contact Jessica Wick or Brenda Cordwell in the Maryland office at 301-459-7590.

Webinar: Implementing 911 Location Accuracy Requirements in the RAY BAUM’S Act

2020-12-10T14:57:20-05:00December 10, 2020|Webinar Recordings|

On January 6, 2021, your telecom switches must not only relay 911 calls to the local PSAP, but also include detailed location information for callers on fixed voice lines (nomadic voice services such as VoIP systems have an additional year to prepare). Dispatchable location information includes the caller’s verified street address, as well as the room, floor number and other information necessary to locate the caller in a multistory business or on a large campus. These new requirements are part of RAY BAUM’S Act, which, in coordination with Kari’s Law, was passed to strengthen the effectiveness of emergency calling.

Are your systems updated and ready to meet the January 2021 deadline? Are your switches passing along the required location information needed to direct emergency responders to the right location?

On a recent webinar, JSI’s experts broke down the rules, provided best practices and implementation tips, and addressed the lingering questions about multiline telephone systems (MLTS) and 911 location implementation requirements, such as:

  • What type of location information needs to be shared?
  • To what underlying technologies do location information requirements apply?
  • What are your responsibilities as an MLTS provider?
  • How do you get the additional location information from the customer?
  • What do you do if your PSAP cannot receive the location information required?

A recording of the webinar is available for $249. Contact Brenda Cordwell in the Maryland office at 240-556-1295 if you’d like to purchase the recording of this webinar.

Waivers Necessary if Local 911 PSAPs Can’t Receive Enhanced Location Info

2020-11-11T12:08:52-05:00November 11, 2020|e-Lerts|

Service providers are working to comply with the FCC’s adopted rules under Section 506 of RAY BAUM’S Act to convey “dispatchable location” information with 911 calls, but not all public safety answering points (PSAPs) can receive this information as the rules require. Discussions with FCC staff determined that the requirements will not be met even if carriers provide dispatchable location information to a PSAP that is not capable of receiving such information. In instances where a local PSAP is not capable of receiving the dispatchable location information, the FCC has said that service providers may need to file a waiver with the Commission.

You will need to check with all the PSAPs that serve your customers and if any of them cannot receive the dispatchable location information or other location information required, JSI encourages you to file a waiver with the FCC.

For full compliance, the PSAP must be able to receive the dispatchable location information conveyed with 911 calls so that first responders can more quickly locate the caller. Dispatchable location information includes the verified street address of the caller and additional information, such as room or floor number, necessary to adequately locate the caller. This additional information is required where the address alone is not enough to locate the 911 caller, for example when calls are made from multistory businesses or large campuses.

These rules apply to the following 911-capable services: fixed telephony, interconnected VoIP services, Internet-based TRS, and mobile text service. As a reminder, the implementation deadlines and corresponding 911 information delivery requirements are as follows:

  • Fixed Telephony Compliance Date
    • January 6, 2021 – Providers of fixed telephony service must provide automated dispatchable location information with 911 calls.
  • Mobile Text Compliance Date
    • January 6, 2022 – Covered text providers must provide automated dispatchable location information with all 911 text messages routed to a PSAP if technically feasible; otherwise they must either provide (i) end-user manual provision of location information or (ii) enhanced location information that is coordinate-based and consists of the best available location that can be obtained.
  • Interconnected VoIP Compliance Date
    • January 6, 2021 – Providers of fixed interconnected VoIP services must provide automated dispatchable location information with each 911 call.
    • January 6, 2022 – Providers of non-fixed interconnected VoIP services and providers of all outbound interconnected VoIP services must provide automated dispatchable location information with each 911 call if technically feasible. Otherwise, they must provide either (i) registered location information, which includes the location the service provider obtained from the customer prior to the initiation of service at which the service is first to be used; or (ii) alternative location information that may be coordinate-based and must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings. Finally, as a last resort, providers may route the caller to the national emergency call center, so long as the provider has made a good faith effort to obtain location data from all available alternative location sources.
  • TRS Compliance Dates
    • January 6, 2021 – Providers of fixed VRS, IP Relay and IP CTS must provide automated dispatchable location information with each 911 call.
    • January 6, 2022 – Providers of non-fixed VRS, IP Relay and IP CTS must provide automated dispatchable location information with each 911 call if technically feasible. Otherwise, they must provide either (i) registered location information, including the location that the service provider obtained from the customer, prior to the initiation of service, or (ii) alternative location information that may be coordinate-based and must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings. Finally, as a last resort, providers may route the caller to the national emergency call center, so long as the provider has made a good faith effort to obtain location data from all available alternative location sources.

When and where possible JSI will file group waivers for providers that have similar circumstances as a means to minimize individual companies’ costs.

Please contact Amanda Molina at 321-985-5709 or Chresanthe Staurulakis at 301-459-7590 if you would like more information, would like to participate in a group waiver filing, or would like JSI to file a waiver specific to your company.

FCC Proposes Changes to 911 Reporting Requirements

2020-05-04T10:54:30-04:00May 4, 2020|e-Lerts|

The FCC released a Public Notice seeking comment on proposed modifications to certifications and outage reporting of Covered 911 Providers (comment date is pending). The rules would affect both the Network Outage Reporting System (NORS) reports and the 911 Reliability annual certifications. The FCC believes that the proposed changes would help identify when there is an outage that impacts 911, clarify each entity’s obligation, and track progress towards improved reliability.

You are a Covered 911 Service Provider if you provide 911, E911 or NG911 capabilities, such as call routing, automatic location information, automatic number identification, or the functional equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency authority and/or operate one or more central offices that directly serve a PSAP.

NORS Reporting
Proposed changes to NORS would increase the details Covered 911 Providers must report, to include 1) identification as a Covered 911 Provider via a drop-down menu, and 2) if the reported outage affected any 911 service, and if yes, which 911 special facilities were affected by the outage, whether they were notified and, if so, how they were notified.

JSI reminds clients it is important to be sure you have current contact information for any 911 facility served. Current outage reporting rules require that within 30 minutes of discovering an outage that potentially affects a 911 special facility, you must notify any official who has been designated as your contact(s) for communications outages at that 911 facility and convey all available information that may be useful in mitigating the effects of the outage, as well as a name, telephone number, and email address at which you can be reached for follow-up. This initial notice to the 911 facility contact must be followed with additional information no later than two hours after the initial contact. Note this requirement to directly contact the 911 facility is in addition to the NORS notifications and reports.

Annual 911 Reliability Certifications
Modifications are also proposed to the annual certifications required of Covered 911 Service Providers. First, to determine if a covered carrier has responsibility for providing diverse facilities, the Covered 911 Provider will need to select if they perform the following functions:

  1. 911, E911 or NG911 call routing through a selective router or its functional equivalent;
  2. Aautomatic location information or automatic number information database lookup capability or its functional equivalent; and
  3. Direct service to a PSAP by one or more central offices it operates, including administrative lines to a PSAP, statewide default answering point, or appropriate local emergency authority.

The functions your company provides will determine if you are responsible for providing diverse facilities to the PSAP.

Second, a new text field is proposed for the Covered 911 Service Provider to provide a summary of improvements they have made to the 911 system in the past year. This added field will be optional.

For questions about either current 911 reporting rules or these proposed rules, please contact Valerie Wimer or Marty Kluh at 301-459-7590.

Webinar: Meeting the FCC’s Enhanced 911 Requirements

2020-01-23T14:39:20-05:00January 23, 2020|Webinar Recordings|

Changes are a result of Kari’s Law and the RAY BAUM’S Act

Telephone service providers have only a few weeks to comply with the enhanced 911 rules as a result of Kari’s Law and the RAY BAUM’S Act. Companies will need to make changes to both their networks and any multi-line telephone systems (MLTS), including hosted services, that they sell, lease, install, or manage. The requirements and deadlines vary by the type of technology and whether the equipment is fixed or not.

JSI recently held a webinar to help clients sort through the requirements, deadlines and details. The webinar covered:

  • Who is considered a network provider and a MLTS provider
  • Requirements for MLTS installed after February 16, 2020
  • New rules for sending a notice to the MLTS’ centralized location when 911 is called
  • Liabilities for companies that do not meet the requirements
  • Details on requiring greater location accuracy and how to judge your company’s current capabilities
  • Best Practices and education programs

A recording of the webinar is available for $249. Contact Brenda Cordwell in the Maryland office at 301-459-7590 if you’d like to purchase the recording of this webinar.

FCC Enhances its 911 Caller Location Accuracy Rules

2019-10-14T15:55:36-04:00October 14, 2019|e-Lerts|

Over the summer, the FCC updated its 911 rules to increase the location accuracy for 911 calls made using wireline, VoIP, Telecommunications Relay Service, and text-to-911 networks. This order also consolidates 911 rules, which were in 47 CFR 1.9,20, 25 and 64, into Section 9. Section 9 will include the new rules required in this order and eliminate sections that are specific to obsolete technologies.

This order provides significant additional requirements for multi-line telephone systems (MLTS) to implement the Kari’s Law Act of 2017 and requires all systems to provide functionality to improve 911 dialing and location accuracy to implement the Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018 (RAY BAUM’S Act). The requirements apply differently to various entities.

  • Voice service providers are required to transmit 911 calls, including the station number, to the Public Safety Answering Points (PSAPs). Voice providers that rely on customers to determine the routing of the 911 calls have no further responsibility.
  • MLTS manufacturers, sellers, installers, managers, lessors, and importers must ensure systems installed after February 16, 2020, meet the following:
    • Default equipment routing is pre-configured to allow 911 calling;
    • Does not require the customer to dial additional digits to reach a 911 PSAP, such as “9”;
    • Sends a notification to a centralized MLTS location at the same time the 911 call is initiated.
  • In addition, the installer or MLTS system manager must configure the system to convey the dispatchable locations of the caller to the PSAP:
    • No later than one year after the effective date of the order for on-premises fixed locations;
    • No later than two years after the effective date for non-fixed devices and off-premises devices associated with the MLTS system.

Note, companies that provide hosted PBX, Centrex, or IP PBX would be considered installers or managers of the systems they sell or lease and could be liable for errors in routing of the calls or provision of call location information.

Enhanced Location Accuracy Rules
In 2014, the FCC enhanced the location accuracy rules for Commercial Mobile Radio Service (CMRS) providers to include the building floor where the caller is located. The FCC is striving to have automatic real-time dispatchable locations be generated for all 911 calls. However, this is not yet feasible in all cases, so carriers can generally fall back to Registered Locations and manual updates. In this latest order, the FCC enhances the location accuracy for other technologies:

VoIP Providers
FCC reaffirmed that VoIP service providers continue to have obligations to educate customers on the limitations of VoIP 911 and must provide stickers for phones or include an on-screen notice to notify customers. The rules apply to all VoIP services, including outbound-only VoIP. The dispatchable location rules depend on the type of VoIP being provided:

  • Fixed VoIP service providers must automatically transmit dispatchable locations with every 911 call unless it is not technically feasible or is cost prohibitive, in which case they can fall back to using the registered location option. The compliance date for fixed VoIP automatic dispatchable location data is one year after the effective date of the order.
  • Non-fixed/nomadic VoIP providers have additional challenges on implementing automatic dispatchable location information. However, some nomadic VoIP services can provide additional information on the dispatchable location. The FCC allows non-fixed VoIP to provide automatic dispatchable location or a registered location when feasible and can accept alternative location information consisting of coordinate-based locations sufficient to identify the caller’s civic address and approximate in-building location including floor level. Non-fixed VoIP service providers will have two years from the date this order is approved by OMB to meet the same requirement as fixed VoIP.

TRS Providers
IP Relay and Video Relay Service providers currently must transmit location information to the PSAP in the form of a registered location. The FCC’s new rules have enhanced this requirement:

  • Internet-based TRS providers will have the flexibility to implement automatic dispatchable location and fall back to the registered location option when real-time dispatchable locations are not feasible. Internet-based TRS providers also have the option to provide alternative location information received from other sources.
  • The FCC also recognized that TRS providers do not have the obligation to automatically detect when their customer premises equipment (CPE) has been moved.
  • TRS providers will have two years from the order’s effective date to comply with the new rules.

Mobile Providers with Text to 911 Service
Currently, text to 911 services are required to obtain the location information needed to properly route the text to the proper 911 PSAP, but are not required to convey call back information. With this order, text providers are required within two years to provide either:

  • The dispatchable location if technically feasible;
  • Manually-updated dispatchable location; or
  • Enhanced location information, which may be coordinate based, consisting of the best available locations that can be obtained, including the floor level.

In summary, TDM services must be able to transmit the station location and provide automatic location information to the 911 PSAP. New MLTS installed or manufactured after February 2020 must be configured to allow 911 calls in the initial default settings and to notify the organization when a 911 call is made. Automatic location accuracy is required for both wireline and wireless, VoIP, and TRS providers. Location accuracy requirements are designed to be applied to all technologies. Generally, fixed technologies have one year to comply; nomadic technologies have two years to comply.

JSI will send another e-Lert when the order is final and specific compliance dates are available. If you have questions about any of these new 911 requirements, please contact Valerie Wimer at 301-459-7590.

E911 Indoor Location Accuracy Certifications Due June 2 for All CMRS Providers

2017-12-14T11:11:09-05:00May 12, 2017|e-Lerts|

JSI reminds clients that are Commercial Mobile Radio Service (CMRS) providers that they must certify with the FCC by June 2 that they can provide, as of April 3, 2017, dispatchable locations or x/y locations (latitude and longitude) within 50 meters for 40% of all wireless 911 calls. The FCC’s Public Safety and Homeland Security Bureau provided guidance in its March 30 Public Notice on filing the certifications of compliance with E911 location accuracy benchmarks as required by Section 20.18(i)(2)(iii) of the Commission’s rules.

The certification must be signed by an officer or director of the CMRS provider who is familiar with and has responsibility for the provider’s indoor location accuracy compliance. Providers may file their certifications using the FCC’s Electronic Comment Filing System (ECFS), https://www.fcc.gov/ecfs/. All certifications must reference PS Docket No. 17-78.

Any company that is unable to meet this initial two-year benchmark should request a waiver of the relevant rule on or before the June 2 certification deadline. Waiver requests should reference PS Docket No. 07-114.

If you have any questions or issues with compliance with this certification, please contact John Kuykendall in JSI’s Maryland office at 301-459-7590.

Source: JSI e-Lert

Power Backup Consumer Disclosures Effective February 1, 2017

2017-05-19T10:09:41-04:00April 11, 2016|e-Lerts|

As JSI alerted clients in its October 20, 2015 e-Lert, facilities-based carriers of fixed residential voice service that is not line-powered (covered providers) with fewer than 100,000 retail subscriber lines must offer a minimum eight-hour power backup option for customers by August 11, 2016. (For companies with 100,000+ retail residential lines the compliance date was February 16, 2016.) This obligation stems from the 911 reliability concerns and requires the power backup to power all equipment required to make a 911 call.

The compliance dates for consumer disclosures, which were pending Office of Management and Budget (OMB) approvals, were announced in the April 7th Federal Register.

By February 1, 2017, covered providers with fewer than 100,000 non-line powered lines, i.e., fiber to the home, must disclose at the point of sale to new subscribers and to all customers annually the following:

  • Service’s capability to accept backup power and the availability of at least one backup power solution from either the provider or a third party;
  • Service limitations with and without backup power during a power outage;
  • Purchase and replacement options;
  • Expected backup power duration;
  • Proper usage and storage conditions for the backup power source;
  • Subscriber backup power self-testing and monitoring instructions; and
  • Backup power warranty details, if any.

Note: The FCC corrected the disclosure compliance date for providers with fewer than 100,000 lines on June 2, 2016. The corrected deadline is February 1, 2017. (This disclosure compliance date is August 5, 2016, for covered providers with 100,000+ lines.)

In February 2019 when a 24-hour backup option is required, companies also will have to provide the same information on customer disclosures for the 24-hour power backup option.

Companies should be working now to determine what power backup options they will offer and if they are going to charge the customer. In addition, companies should be able to answer questions concerning the issues required in the consumer disclosures in August 2016 even though they are not required to provide a formal notification until February 1, 2017.

If you have any questions about the rules or would like JSI’s assistance developing your customer notifications, please contact Valerie Wimer at 301-459-7590.

Source: JSI e-Lert

JSI Webinar: On the Road to All IP: New Rules & New Requirements

2017-05-19T10:09:45-04:00October 7, 2015|Webinar Recordings|

The transition from copper to fiber and TDM to IP comes not only with technical hurdles, but also a host of new rules and requirements. Chief among these are new customer notifications regarding copper retirement and back-up power.

JSI recently hosted a webinar to break down each of these new requirements, who they apply to, what companies will be required to do, and when they’ll need to act. Specifically, JSI VP Valerie Wimer will discuss:

  • New customer notifications before copper can be retired
  • The FCC’s limits on pricing terms to competitors for IP services
  • Filing Section 214 notices with the FCC when services are discontinued
  • New requirements for backup power for fiber customers to ensure access to 911 services

A recording of the “On the Road to All IP: New Rules & New Requirements” webinar is available for $249.

If you are interested in purchasing the webinar recording, please contact Brenda Cordwell in JSI’s Maryland office at 301-459-7590.

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