Carrier Association Requests Reconsideration of FCC Decision on 911 Outage Notification

WASHINGTON, March 21, 2023 – The Competitive Carriers Association is asking the Federal Communications Commission to reconsider a November decision requiring carriers to provide certain network outage notifications within 30 minutes.

The FCC order mandates that originating call providers notify 911 special facilities – such as emergency call centers called public safety answering points – of outages “no later than within 30 minutes of when the outage that potentially affects 911 service is discovered.” The order also required those providers to keep up-to-date contact information for those special facilities in areas they serve.

In a petition on Friday, the CCA is asking for the FCC to review and implement flexibility in that timing. “The significant new requirements that the Commission has imposed on carriers…are likely to be burdensome and counter-productive not only for carriers, but also 911 special facilities,” the CCA said in its application, though it continues to encourage the commission to retain the “as soon as possible” requirement.

“At a minimum, however, the Commission should start the 30-minute timer (and subsequent timers) when actual originating service provider…notification occurs from its vendor or other underlying provider,” the CCA said, adding even then carriers “would face significant difficulty assessing the outage, identifying the appropriate” public safety answering points to notify, and making the required notifications within 30 minutes.

“Therefore, it would be appropriate to deem [originating call providers] compliant if they begin notifying affected PSAPs that an outage exists within the 30- minute timeframe, and continue to notify any PSAPs that the OSPs could not reach before the expiration of the 30-minutes,” the industry association added.

The association said the problem with the decision is it doesn’t account for the “practical difficulty (if not impossibility)” of getting a vendor notification, determining which of the thousands of answering points may be affected by the outage, and making the required notification in that timeframe. It said carriers frequently don’t get outage notifications from 911 solution vendors within 30 minutes.

“The unnecessarily rigid approach in the [order] will often make compliance an impossibility, and otherwise will require carriers to spend critical time and resources on notifications to PSAPs that are not affected by outages, and will subject PSAPs to frequent notifications regarding outages that do not affect them, with limited actionable information given the short deadline,” the CCA added.

The CCA is also requesting that the commission create and maintain a centralized database with information provided by the 911 special facilities. It notes that the FCC order fails to fully take into consideration the burden its approach will place on carriers, especially smaller ones with limited resources, and PSAPs, who are “likely to experience a recurring deluge of requests for updated contact information from numerous carriers subject to this amorphous standard.”