For years, APCO has urged the Federal Communications Commission to take steps to make providers’ outage reports more useful to the emergency communications centers that rely on them to assess the impact of network outages and implement mitigation strategies. APCO has also emphasized the importance of holding covered service providers responsible for the actions of their contractors. We were heartened to see the FCC recently remind service providers of their obligations to provide timely and actionable notification of outages that potentially affect 9-1-1 service.
In a September 25 public notice, the FCC said that “[p]ublic safety organizations have made us aware of many examples of providers sending vague, inaccurate, or unnecessary notifications,” and accordingly warned that failure to comply with its requirements may result in enforcement action. The public notice provided examples of notifications that would likely not be considered compliant with the rules, including one that states that a provider “is experiencing a network impairment that MAY potentially impact … your PSAP.” Additionally, “[a] notification that a provider ‘is experiencing a network outage that may potentially affect your 911 special facility’ and does not specify how a 911 special facility is affected by the outage is not a compliant notification when the provider knows the outage is intermittently causing calls to drop and, when the calls do not drop, are not completed with ALI/ANI.”
The FCC also reminded providers that obligations apply not only to facilities-based providers but also to resellers to the extent they lease or otherwise utilize facilities to provide communications services to their customers; that they remain responsible for compliance with notification requirements even if they contract with third parties to analyze outages and send notifications; and that overly vague notifications are unlikely to satisfy the requirement that providers “undertake reasonable efforts to investigate outages and assess their impact before transmitting a notification.”
