Public Safety Groups, Industry at Odds on Need for New FCC 911 Reliability Rules
APCO and the National Emergency Numbering Association urged the FCC to impose new 911 reliability rules. Industry commenters said rules would do nothing to make emergency calling more reliable. The Public Safety Bureau sought comment in June on reliability of 911 networks and whether current rules should be “modified to adapt to advancements in technology or other changes, including notification to Public Safety Answering Points of network outages affecting 911 service." Initial comments were due Monday in docket 13-75.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
“While APCO does not want to deter innovation and competition from new participants, these benefits must be balanced with the need for reliability, which might only be achieved by expanding the scope of regulations,” the group said. Requirements to notify PSAPs of outages need to be strengthened, APCO said. “PSAPs should receive real-time outage information in an easily accessible format that provides situational awareness with regard to the timing, nature, and scope of any impacts to 9-1-1 services.”
Improved reliability rules are needed “to prevent avoidable service degradation and outages,” and current rules don’t take into account the databases and software that “underpin the infrastructure of the NG9-1-1 network,” NENA said. “Examine whether expanding the scope of its Rules to include these parts of the NG9-1-1 environment is necessary to ensure reliability and resilience as the nation transitions to NG9-1-1.”
NENA and APCO said the FCC should expand its definition of a covered 911 service provider to keep up with changing times. “In only a few short years the 9-1-1 industry has grown by leaps and bounds and in almost every conceivable direction, with vendors offering supplemental data services, 9-1-1 apps, advanced computer-aided dispatch (CAD) and responder situational awareness integrations,” NENA said. “These products and services are rapidly becoming integral to the workflow of the modern PSAP.”
USTelecom said the FCC should streamline rather than add to rules. Certifying results of a required 911 system diversity audit annually “is no longer necessary given that the results do not change substantially” and the FCC should require an audit every three years, the association said. “The initial effort to audit, reconsider diversity paths, and tag critical circuits for thousands of offices and aggregation points required an investment many-times over the Commission’s $9 million annual cost of compliance estimate (to say nothing of the Commission’s estimated compliance costs of $0 that it submitted to the Office of Management and Budget),” USTelecom said. The FCC should remove a requirement that compliance be certified at the corporate officer level, the group said: “Companies are responsible, with enforcement penalties for non-compliance, for compliance with the rules regardless of a corporate officer certification.”
West Safety, which provides 911 services, said the FCC is right to ask “whether the current rules maximize flexibility and account for differences in network architecture without sacrificing 9-1-1 service reliability.” The company urged the FCC to appoint a working group to examine “alternative frameworks for regulation.” West said the definition of service provider doesn’t need to change.
New rules would be duplicative and aren’t needed, ATIS said. Current 911 reliability requirements “adequately encompass transitional and NG9-1-1 networks,” ATIS said. It said rules should be changed to require 911 service providers “take reasonable measures to ensure the reliability of their 9-1-1 networks, but without specific mandates related to 9-1-1 circuit diversity, availability of central office backup power, diverse network monitoring, etc.”