Reminder: FCC Annual 911 Reliability Certification Due October 16, 2017

Kelley Drye Client Advisory

Please be reminded of the upcoming due date for the FCC filing requirement listed below:

911 Provider Annual Reliability Certification

Pursuant to FCC rule 12.4, providers of 911, E911, or NG911 capabilities in the United States must file with the Federal Communications Commission (FCC), by October 16, 2017,* an annual certification of compliance with the FCC’s 911 reliability requirements.  The annual certification must be submitted via an online portal through the FCC’s website available at https://​app​s2​.fcc​.gov/​r​c​s911/.

*Note that this certification is typically due on October 15th annually.  However, because that date falls on a weekend in 2017, Commission rules dictate that the certification will be due on the following business day.

Who Must File:

The rule 12.4 annual recertification requirement applies to any ​“covered 911 service provider,” which is defined as any entity that:

(A) Provides 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 authority as defined in §§64.3000(b) and 20.3 of [the FCC’s rules]; and/or

(B) Operates one or more central offices that directly serve a PSAP.  For purposes of this section, a central office directly serves a PSAP if it hosts a selective router or ALI/ANI database, provides equivalent NG911 capabilities, or is the last service-provider facility through which a 911 trunk or administrative line passes before connecting to a PSAP.

The term ​“covered service provider” does not include PSAPs or other governmental authorities that provide 911 capabilities, or entities that offer the capability to originate 911 calls where another service provider delivers those calls and associated number or location information to the appropriate PSAP.

Overview of Report Contents:

Rule 12.4 requires Covered 911 Service Providers to certify compliance with three substantive requirements:

  1. 911 Circuit Diversity.  Filers must certify that they have: (i) conducted diversity audits of critical 911 circuits or equivalent data paths to any PSAP served; (ii) tagged such critical 911 circuits to reduce the probability of inadvertent loss of diversity in the period between audits; and (iii) eliminated all single points of failure in critical 911 circuits or equivalent data paths serving each PSAP.
  2. Central Office Backup Power.  Filers must certify whether they (i) provision backup power through fixed generators, portable generators, batteries, fuel cells, or a combination of these or other such sources to maintain full-service functionality, including network monitoring capabilities, for at least 24 hours at full office load or, if the central office hosts a selective router, at least 72 hours at full office load; (ii) test and maintain all backup power equipment in such central offices in accordance with the manufacturer’s specifications; (iii) design backup generators in such central offices for fully automatic operation and for ease of manual operation, when required; and (iv) design, install, and maintain each generator in any central office that is served by more than one backup generator as a stand-alone unit that does not depend on the operation of another generator for proper functioning.
  3. Diverse Network Monitoring.  Filers must certify whether, in the last year, they have: (i) conducted diversity audits of the aggregation points that they use to gather network monitoring data in each 911 service area; (ii) conducted diversity audits of monitoring links between aggregation points and network operation centers (NOCs) for each 911 service area in which they operate; and (iii) implemented physically diverse aggregation points for network monitoring data in each 911 service area and physically diverse monitoring links from such aggregation points to at least one NOC. 

The FCC has clarified that, under section 12.4, Covered 911 Service Providers may implement and certify an alternative measure for any of the specific certification elements, as long as they ​“provide an explanation of how such alternative measures are reasonably sufficient to mitigate the risk of failure,” and ​“how the alternative will mitigate such risk at least to a comparable extent as the measures specified in [the FCC’s] rules.”

Companies that serve numerous PSAPs or service areas may choose to enter their responses in an Excel spreadsheet, which is available for download through the online portal.  Once users enter all certification information into the 911 Reliability Certification System, the portal provides a link to upload a signed attestation from a company’s Certifying Official that such information is true and correct.


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For more information regarding this client advisory, please contact your usual Kelley Drye attorney.