FCC Acts to Preserve Reliable 911 Service as Technology Evolves

The Federal Communications Commission proposed rules to preserve reliable 911 service as technology evolves. The proposals address the increasingly complex nature of the nation’s 911 infrastructure and respond to a recent trend of large-scale “sunny day” 911 outages – that is, outages not due to storms or disasters but instead caused by software and database errors. Technology transitions, including the move to IP-based networks, can vastly improve 911 calling and help first responders during emergencies. However these transitions also present potential new vulnerabilities to 911 service. The process of routing and completing a 911 call now often involves multiple companies, sometimes geographically remote from where the call is placed. Outsourcing and consolidation of critical 911 network infrastructure means that a single 911 outage can affect more people in more places than before, and can also complicate restoration efforts.

In the Policy Statement and Notice of Proposed Rulemaking (NPRM), the FCC affirmed the core principles that have guided and will continue to guide the FCC’s approach to 911 oversight – particularly its policy of working with state and local partners to ensure reliable 911 service. The FCC also cited recent large-scale “sunny day” 911 outages, most notably an April 2014 outage caused by a software coding error in a 911 routing facility. That outage resulted in a loss of 911 service for more than 11 million people in seven states for up to six hours, with over 6,600 failed calls to 911. The FCC’s Public Safety and Homeland Security Bureau issued a report on the outage, citing the importance of network reliability and clear accountability throughout the 911 call completion process.

Accordingly, the NPRM seeks comment on specific proposals in four key areas to set the nation on a path towards reversing the trend of large-scale 911 outages:

1. Requiring 911 providers to make public notification of major changes to 911 service, so that 911 call centers and other stakeholders are aware of potential impacts, and to seek approval if they intend to discontinue critical 911 services.
2. Requiring entities seeking to offer new 911 capabilities and services to certify that they have the technical and operational capability to do so reliably.
3. Clarifying roles to promote situational awareness, information sharing, and coordination among multiple service providers during 911 outages.
4. Updating the FCC’s 911 reliability certification requirements to account for new technologies and network architectures.