Frequently Asked Questions: FCC 911 Reliability Certification

Updated October 2015

* These FAQs are provided as interpretive guidance by FCC staff to assist filers in understanding their certification obligations and do not reflect a binding action of the Commission.

Please send additional questions to Ryan Hedgpeth and David Ahn, and this page will be updated periodically.

Who is required to certify?

Certification requirements apply to Covered 911 Service Providers, defined as entities that:

Are PSAPs or state/local 911 authorities required to certify?

No. The rules do not apply to PSAPs or governmental authorities that provide 911 capabilities.

Are companies that only originate 911 calls required to certify?

No. A company that offers the capability for its customers to originate 911 calls is not a Covered 911 Service provider if another entity operates the selective router and/or ANI/ALI database that delivers those calls and associated number or location information to the appropriate PSAP.

Are companies that provide 10-digit administrative lines to a PSAP required to certify if they don't provide the 911 trunks?

Yes, but only with respect to backup power. A central office "directly serve[s] a PSAP" and must comply with backup power requirements if it is the last service-provider facility through which a 911 trunk or administrative line passes before connecting to a PSAP. Unlike 911 trunks, however, administrative lines are not "critical 911 circuits" and are not subject to auditing or diversification requirements. The network monitoring section of the certification is not applicable unless a company has a "911 service area," defined as the geographic region in which a covered 911 service provider operates a selective router or the functional equivalent. Therefore, companies that provide administrative lines to a PSAP but do not operate the selective router, ANI/ALI database, or the functional equivalent should complete the backup power portion of the certification but may respond that the other sections are not applicable.

Which circuits are subject to diversity audits?

Diversity audits apply to 911 circuits or transport facilities between the selective router or the functional equivalent and the central office that serves each PSAP, as well as to links between ANI/ALI databases and the central office that serves each PSAP. Portions of the network between originating callers and the selective router are not subject to auditing requirements, nor are 10-digit administrative lines or the "local loop" between each PSAP and its serving central office.

Are companies required to certify with respect to 911 circuits leased from third parties?

Yes. Where a Covered 911 Service Provider provides 911 services directly to a PSAP (pursuant to contract or tariff) over leased facilities, the circuit auditing obligation applies to the Covered 911 Service Provider, and not to the facilities lessor. Companies that directly serve PSAPs over leased facilities may contract with the lessor to audit those circuits or to provide some other assurance that they are physically diverse, but only the company with a direct relationship to the PSAP is responsible for certification. The free-text description of alternative measures for circuit diversity provides an opportunity for the Covered 911 Service Providers to explain such arrangements and list any other companies that may be involved in providing critical 911 circuits. Covered 911 Service Providers should also indicate whether a lease or service level agreement obligates a third party to audit and/or tag critical 911 circuits, or whether a third-party network is available for backup routing if the primary network fails.

Which companies are required to certify with respect to network monitoring?

Companies must certify with respect to network monitoring if they serve, one or more "911 service areas," defined as "the metropolitan area or geographic region in which a covered 911 service provider operates a selective router or the functional equivalent to route 911 calls to the geographically appropriate PSAP." Such companies should indicate the location of each selective router or the functional equivalent in the form field for each 911 service area. If a company does not operate a selective router or the functional equivalent, it may respond that the network monitoring portion of the certification is not applicable.

What if a company has a "911 service area" but does not use aggregation points for network monitoring data?

The certification is based on a network monitoring architecture that collects telemetry data from end points in the network through one or more aggregation points in each service area en route to a network operations center (NOC). Companies that operate a selective router or the functional equivalent but use a different network monitoring method (e.g., a modem network or an IP-based monitoring network that connects directly to the NOC) may indicate such methods in the drop-down and text field for alternative measures.

What is the difference between "inputters" and "coordinators"?

As with the Commission's Network Outage Reporting System (NORS), the certification system has two types of users: inputters and coordinators. Inputters only have access to information that they have submitted, while coordinators have access to all information submitted by their company. Users responsible for limited portions of a company's certification (e.g., particular service areas or topics such as circuit diversity, backup power, or network monitoring) should register as inputters, while users responsible for overseeing each company's certification as a whole should send a request to David Ahn or to Ryan Hedgpeth to be upgraded to coordinator status. For security purposes, these upgrades are done on a case-by-case basis.

How does the spreadsheet work?

Companies that serve numerous PSAPs or service areas may choose to enter certification information in an Excel spreadsheet, which is available on the main menu page of the certification system, rather than entering individual records in the system itself. Users must be registered as coordinators to have access to the Excel upload and download capability. For further information about accessing and completing the spreadsheet, please contact Ryan Hedgpeth at (202) 418-7095 or

Who is required to sign the attestation form?

After completing the certification, each Covered 911 Service Provider must upload an attestation by a "Certifying Official," defined as a corporate officer with supervisory and budgetary authority over network operations in all relevant service areas. Record of the attestation from the Certifying Official that such information is true and correct must be filed under signature with the FCC by uploading the attestation in PDF form via the link provided in the system.

Where can I find the rule text?

This page summarizes FCC rules codified at 47 C.F.R. § 12.4. If in doubt about specific certification requirements, please consult the actual rule text, or refer to the Report and Order adopting the rules, FCC 13-158.

What happens to testing accounts once the actual filing period opens?

Data entered in the test system will be deleted when the actual filing period opens, and users will have to create a new user identity on the production system.

What counts as "substantial progress" for purposes of the first certification due October 15, 2015?

FCC rules require an Initial Reliability Certification of "substantial progress" toward meeting the standards of the Annual Reliability Certification, defined as "compliance with standards of the full certification in at least 50 percent of the Covered 911 Service Provider's Critical 911 Circuits, central offices that directly serve PSAPs, and independently monitored 911 Service Areas." See 47 C.F.R. § 12.4(d)(1). The Initial Reliability Certification should reflect at least 50-percent compliance with each of the three substantive certification requirements (i.e., circuit diversity, backup power, and network monitoring). For example, Covered 911 Service Providers should certify they have conducted at least 50 percent of the circuit audits required across their network footprint, or that they meet backup power requirements in at least 50 percent of their central offices that directly serve PSAPs. The Commission delegated to PSHSB authority to implement the Initial Reliability Certification consistent with the principles of substantial progress described in the rule, and the Bureau intends to offer Covered 911 Services Providers as much flexibility as is reasonably practicable in phasing in these certification requirements. If, however, it is not clear from a company's certification responses whether its efforts to comply with the Initial Reliability Certification constitute substantial progress, we may request additional information to ensure that the company is on track for full compliance with Annual Reliability Certifications beginning October 15, 2016.

How do I provide supplemental information not included in responses on the certification form?

The certification system provides free-text fields for companies to describe alternative measures, as well as a free-text field for additional remarks, and we encourage companies to use these fields as much as possible when information pertains to a specific PSAP, central office, or service area. If companies wish to provide more general explanations or narrative about their 911 reliability efforts or progress in meeting the requirements of the Initial Reliability Certification, they may upload that information with their attestation form. Please append any supplemental information to the attestation as one .PDF document so that it may be uploaded as a single file.

How do I submit certifications for multiple companies?

If you are a consultant or other representative submitting certifications on behalf of multiple Covered 911 Service Providers, please e-mail Ryan Hedgpeth or David Ahn for instructions on how to file information for each company.

How do I know when my certification is complete? Will I receive a confirmation e-mail?

A certification is complete once a company completes all applicable form fields in the certification system (or Excel spreadsheet, if applicable) and uploads a signed attestation from its Certifying Official. You will not receive a separate confirmation message or e-mail. You may, however, review the information that you have submitted by clicking the “View Report” link from the Main Menu page. If you still have questions or would like to verify that we have received your certification, please e-mail Ryan Hedgpeth or David Ahn.

Why am I getting a system error?

The certification system cannot accept certain characters such as <, >, ~, `, #, @, %, ^, =, :, [, ], {, } and \. If you are receiving an error message such as “invalid value,” please try submitting your filing without using these characters.

Can I amend a previously submitted certification?

Yes. To amend a previously submitted certification, log back in to the certification system and resubmit any information that you would like to change.

How do I request confidential treatment for information submitted with a certification?

Certain information provided with 911 reliability certifications is presumed confidential and exempt from routine public disclosure under the Freedom of Information Act (FOIA) as provided in section 0.457(d)(vii) of the FCC rules. Therefore, no additional filing is required to the extent that certification information “consists of descriptions and documentation of alternative measures to mitigate the risks of nonconformance with certification elements, information detailing specific corrective actions taken with respect to certification elements, or supplemental information requested by the Commission with respect to such certification.” If you wish to request confidential treatment of additional information that may not clearly fall within the presumption of confidentiality, please include a request that materials or information submitted to the Commission be withheld from public inspection under FCC rule 0.459 when you upload the attestation from your Certifying Official. The request should contain a statement of the reasons for withholding the materials from inspection and of the facts upon which those records are based, as set forth in more detail in section 0.459(b). This can be added to the same .PDF file as the attestation and uploaded as one document when you complete your certification. Information submitted through this process will then be accorded confidential treatment unless and until the Commission receives, and acts upon, a request for public inspection, and all subsequent appeal and stay proceedings have been exhausted.