Reminder Regarding October 16 Deadline for Annual 911 Reliability Certification

Reminder Regarding October 16 Deadline for Annual 911 Reliability Certification
Carriers Urged to Re-assess Criteria for Determining Covered 911 Service Provider
Covered 911 Service Providers must file an Annual 911 Reliability Certification with the FCC by October 16, 2017.  In light of apparent confusion in the industry, we recommend that carriers revisit whether or not they fall within the definition of a “Covered 911 Service Provider” and re-assess whether the 911 reliability requirements apply to them, and therefore require them to file a certification.
Many small carriers do not consider themselves to be Covered 911 Service Providers because they do not provide 911 capabilities such as automatic location information (ALI) and automatic number identification (ANI), or functional equivalents of ALI and ANI, directly to a public safety answering point (PSAP).  A carrier, however, also is a Covered 911 Service Provider if it operates one or more central offices that directly serve a PSAP.  A carrier may directly serve a PSAP if it has a central office that hosts a selective router or ALI/ANI database, that provides 911 capabilities, or that is the last service-provider facility through which a 911 trunk or administrative line passes before connecting to a PSAP.  If a carrier falls within the definition of a Covered 911 Service Provider solely because it provides administrative lines to a PSAP, then the carrier is only required to certify compliance with the backup power requirements for the relevant central offices.
If you have any questions or need assistance with this matter, please contact Robin Tuttle at rtuttle@hermanwhiteaker.com.