When service-impacting issues arise for 911, it’s critical to communicate that information to public safety answering points. Stakeholders must receive timely and actionable updates when outages occur and know which originating service provider is impacted.
What Does the FCC Require?
The FCC’s decision on outage notifications, Report and Order FCC22-88, requires that affected 911 special facilities, including and especially public safety answering points (PSAPs), receive timely and actionable information about service issues that potentially impact them. Under the Report and Order, originating service providers (OSPs) must send this information as soon as possible but within 30 minutes of a 911 outage that potentially affects a PSAP. Further, the OSP must follow up in two-hour intervals of the original notification to provide additional material information through the time of resolution.
The rules also require OSPs, which include cable, satellite, wireless, wireline and VoIP providers, to use special diligence to create and maintain an accurate, up to date contact list for purposes of notifying PSAPs of service outages.
But what is special diligence, and how can OSPs ensure they are compliant?
Understanding the Special Diligence Requirement
911 special facilities, such as PSAPs, play an instrumental role in notifying the public of alternative ways to reach emergency services when 911 outages occur. These public notifications can save lives.
But if PSAPs are not informed of service impacting issues by service providers, the public may be unaware of how to reach help when they need it. This underscores the significant need for timely and actionable information to be shared with PSAPs.
The FCC described special diligence as “the diligence expected from a person practicing in a particular field of specialty under circumstances like those at issue.” Unfortunately, that doesn’t provide much clarity on what constitutes special diligence for purposes of complying with the rule. But the order did state that OSPs must update their PSAP outage contact list at least annually and must make several attempts to ensure they get a response from each of the PSAPs in their service area.
Because 911 is critical to ensuring the safety of the public, the FCC imposed this higher level of care requiring OSPs to actively seek and confirm accurate contact information – and not rely on the absence of a response. For example, if an OSP is unable to verify information after multiple documented attempts, special diligence can include escalation to local or state 911 authorities to track down the proper contact information.
Intrado PSAP Outage Notification List
We know from experience that maintaining accurate PSAP contact information is a major undertaking. It’s not easy for OSPs to ensure their database is reliable and comprehensive, especially for those that have not been required to do this before. But as a longtime leader in public safety, Intrado has been actively curating and maintaining a highly accurate list of contacts within PSAPs across the US and its territories for many years.
Using a biannual, multistage process, we maintain a thorough and accurate PSAP contact list that we are confident achieves the special diligence required by the Commission’s rules. This information is available to OSPs via various methods with a standardized set of data – allowing all OSPs to have equal opportunity to adhere to FCC regulatory requirements.
What’s Next?
The rules are likely to become effective later this year. With that in mind, it’s important for OSPs to start planning now. The FCC doesn’t hesitate to enforce its outage rules against OSPs, and recent enforcement action has resulted in OSPs being assessed fines of up to several thousand dollars per PSAP for non-compliant outage notifications.
Intrado has a vetted solution already in place for over 20 years, removing the burden of collecting, maintaining, and frequently updating this information in-house. Begin planning today by reaching out for more information about Intrado’s PSAP Outage Notification List.
