New 911 requirements coming for all providers of voice services

On November 17, 2022 the FCC issued a new report and order to improve 911 reliability by requiring service providers to notify the PSAPs in their service area of outages which might impact 911 service. This ruling will go in effect in 120 days after the final report is issued which most are expecting to happen real soon.

This means every VOIP reseller has to keep a database of all PSAP that their customers have 911 setup with and any outage that would affect a caller from reaching the PSAP you must notify the PSAP.

I am curious what all the resellers of voice services here plan to do to be compliant with this?

We’re still working that out. The only upside right now is our small our market footprint, in the grand scheme, so that reduces the amount of PSAPs I’ve got to track.

Does this mean that the ITSP has to consider every end-user who works remotely, or PSAP associated with the the billing address on the account?

No, this is for carriers and OSPs. So if my data center is dead in the water, I cannot complete 911 calls for my users. I must now inform the PSAPs I can’t deliver 911 calls in the areas of the outage. Now if my upstream 911 carrier is down, I could still route calls out another carrier even if they end up in a regional PSAP. As the OSP I can still deliver 911 calls but if I’m down but my 911 carrier is up, I am the one that has to inform the PSAPs of my outage.

Now what I thought about since reading this is that there have been a small amount of people who have asked for help/admitted that they don’t have their own infrastructure and are doing things like STIR/SHAKEN, etc directly on PBX systems (even on-prems). Because at that point the OSPs infrastructure is the PBX at a location that has no Internet so now the OSP can’t complete 911 calls at that location. So yeah, sounds like to me they would have to contact PSAPs in those cases.

More and more it is becoming clear that being someone that installs PBX systems and then uses someone like VoIP Innovations to trunk each PBX to is going to make dealing with these new regulations a PITA.

Even more clear is the fact the days of “Look ma, I’m a reseller of VoIP and I can just put all responsibilities on my upstream…” is over.

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Correct. So when you have to notify PSAPs of that outage, which PSAPs are you required to notify? All the PSAPs that your clients end-users may reach?

Meaning, let’s take ABCTrunkingProvider for an example, if they are down, do they have to query their e911 registered DID database, do a PSAP match (how?) to all street addresses and reach out to them? What about Dynamic e911 service which the address can be different literally every few minutes, do they have to constantly to query, match and update PSAPs?


You’re referring to non-fixed devices I take it? If ABCTrunking is down and can’t complete any calls why would it matter if the caller’s location changes every 2 minutes? The network they are connected to (ABCTrunking) is down. If ABCTrunking is nationwide and has a full nationwide outage, yeah they need to inform every PSAP.

As for how they do that or how they get that information, I’m not entirely sure just yet. Still trying to sort through how to deal with this.

BOLO for new “Outage Notification” fees from every vendor.

After reviewing the proposed rule and talking with our telecom compliance company we use it is pretty clear that anyone that offers SIP Trunking or even Hosted PBX with trunking built in will be required to notify all affected PSAPs of any outages that keep your customers from reaching the PSAP and the ruling even talks about if you use a 3rd party 911 provider you the Company charging the customer for phone service are liable and required to handle the notifications and you can not pass the buck to your upstream 3rd party provider of the 911 calling. This is going to be fun and a short deadline to put in place all of this.

This this ruling is for OSP (Original Service Provider) and Interconnect VOIP Reseller. Right from the Ruling itself

Reliance upon a third-party service provider to manage, route, or otherwise contribute to 911 call processing does not relieve a covered 911 service provider or an OSP, including an interconnected VoIP provider, of the obligation to provide notification to 911 special facilities under this rule. It is the duty of covered 911 service providers and OSPs, including interconnected VoIP service providers, to provide 911 service in accordance with the Commission’s rules.46

I am having a hard time envisioning different situations and who is responsible for notifying who.

If your upstream provider is having an outage and they are handling E911 for their customers (all their customers not just us as a reseller) presumably they would need to reach out to all PSAP’s that they could potentially interconnect with to notify them of an outage, correct?

If they are required to do this and have already done this, how does a PSAP handle me also calling them and notifying them of said outage?

Further, if a phone system that was deployed at a customer’s site goes out for whatever reason (let’s say their internet is out) we are supposed to reach out to the PSAP and notify them that an internet connection for a customer is out? How does a PSAP knowing the status of an internet connection for somebody that’s using VoIP that might reach out to them help the situation?

The rules are clear. You are to notify them even if your 3rd party provider has the outage. Your are liable if the notification is not made and can not rely on your 3rd party provider. They are crystal clear on this requirement.

They state “ Reliance upon a third-party service provider to manage, route, or otherwise contribute to 911 call processing does not relieve a covered 911 service provider or an OSP, including an interconnected VoIP provider, of the obligation to provide notification to 911 special facilities under this rule. It is the duty of covered 911 service providers and OSP”

We can all say we don’t like the rule and it’s stupid but if your selling voice services to a customer you are regulated and required to do the notices now.

So again, an individual client loses internet connectivity and we are supposed to reach out and notify the PSAP of that internet outage with an on premise phone system?

I am just trying to understand what this rule is trying to help with or mitigate.

Could somebody provide a link to the actual requirements and instructions of what to do in case of an outage?

The source of it is right here on the FCC website. FCC Updates Rules To Improve 911 Reliability | Federal Communications Commission

You will see it does not tell you how to reach the PSAP. That is something you have to figure out for each and every PSAP you have customers e911 setup for. Like most regulations it says you must do X but doesn’t detail how to do it.

No, they are an end user not an OSP, Interconnect VoIP, LEC or 911 carrier. You should already be providing your end users will the VoIP E9-1-1 rules that state them having an Internet outage will impacted their 9-1-1 calls.

If any of my customers have an Internet outage, how would I know? Their trunk being down doesn’t indicate an outage. It could but it doesn’t automatically mean that. A customer having an issue with their PBX that is not managed by me is a customer issue.

EDIT: I will amend this with, if you are someone that is reselling VoIP but installing individual PBX systems that are trunked directly to a upstream like VoIP Innovations or anyone that allows that then you are in a different boat. Because you are still the OSP/VoIP provider for the customer and as an OSP/VoIP provider you should have you own network between you and your upstreams.

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I wonder how exactly this would be enforced on any small service provider that is under the radar of news coverage. Yeah if Lumen has a major outage, that’s well known. If Bob’s VoIP & Stuff goes down, who’s going to see it? Are Bob’s customers going to report the outage to the FCC? I doubt the PSAP is looking around for outages to tell the FCC about. I guess the FCC will keep their eyes peeled for people suing their phone system providers for failure to connect 911, and then the FCC will also file suit to collect their fines.

Thank you, this was clarifying actually.

When it comes to the FCC and their hammer they have on fines and enforcement I use the mindset of

The more your F*** around the more you will find out graph.

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Much like everything with FCC rulings you have to read it a few times to catch everything. There are two things I caught the last time around. First, there are already existing rules for certain types of carriers and this order is to harmonize it for everyone. So this isn’t something new, per se, it is now being expanded to cover pretty much all OSPs of any type.

Second, more to @billsimon’s question. I found this little tidbit

The Commission requires covered 911 service providers and OSPs to notify both the Commission and 911 special facilities when they experience an outage that potentially affects 911

So it is sounding like, to me, we’ll have to report it to both entities and the FCC can then review the reporting.