PSHSB Announces Comment Dates for 911 Reliability PFR
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
Released: March 14, 2014
PUBLIC SAFETY AND HOMELAND SECURITY BUREAU ANNOUNCES
COMMENT DATES FOR PETITION FOR RECONSIDERATION
IN 911 RELIABILITY PROCEEDING
PS Docket Nos. 13-75, 11-60
Comments Due: March 27, 2014
Reply Comments Due: April 7, 2014
comment dates for a petition for reconsideration in a rulemaking to improve the reliability and resiliency
of 911 communications networks.
On December 12, 2013, the Federal Communications Commission (Commission) adopted a
Report and Order (911 Reliability Order) requiring certain 911 communications providers to take
reasonable measures to provide reliable service, as evidenced by an annual certification of compliance
with specified best practices or reasonable alternative measures.1
On February 18, 2014, Intrado, Inc., filed a “Motion for Clarification or, in the Alternative,
Petition for Partial Reconsideration” (Petition)2 seeking clarification or reconsideration of the 911
Reliability Order’s requirements regarding diversity audits of critical 911 circuits and network monitoring
links. Specifically, Intrado requests guidance “that Providers may take reasonable alternative measures to
meet the Commission’s standards in lieu of implementing any of the best practices adopted by the Order.
This would include confirming that Providers may take reasonable alternative measures instead of
conducting Diversity Audits, Tagging Critical 911 Circuits, or auditing Monitoring Links.”3
The Commission published notice of the Petition in the Federal Register on March 12, 2014.
Accordingly, pursuant to section 1.429 of the Commission’s rules,4 oppositions to the Petition are due on
or before March 27, 2014, and replies are due on or before April 7, 2014.5
1 In the Matter of Improving 911 Reliability; Reliability and Continuity of Communications Networks, Including
Broadband Technologies, PS Docket Nos. 13-75, 11-60, Report and Order, 28 FCC Rcd 17476 (Dec. 12, 2013),
available at http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db1212/FCC-13-158A1.pdf (911
2 Intrado, Inc., Motion for Clarification or, in the Alternative, Petition for Partial Reconsideration, PS Docket Nos.
13-75, 11-60 (Feb. 18, 2014), available at http://apps.fcc.gov/ecfs/document/view?id=7521073778 (Petition).
3 Id. at 3 (emphasis in original).
4 See 47 C.F.R. § 1.429(f)-(g).
Procedural MattersPursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419,
interested parties may file comments on or before the dates indicated on the first page of this document.
Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS).6
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing.
If more than one docket or rulemaking number appears in the caption of this proceeding, filers
must submit two additional copies for each additional docket or rulemaking number. Filings can
be sent by hand or messenger delivery, by commercial overnight courier, or by first class or
overnight U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary,
Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary must be
delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325, Washington, DC 20554.
The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber
bands or fasteners. Any envelopes and boxes must be disposed of before entering the building.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must
be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street,
SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to email@example.com or call the
Consumer and Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).
Parties wishing to file materials with a claim of confidentiality should follow the procedures set
forth in section 0.459 of the Commission's rules. Casual claims of confidentiality are not accepted.
Confidential submissions may not be filed via ECFS but rather should be filed with the Secretary’s Office
following the procedures set forth in 47 C.F.R. § 0.459. Redacted versions of confidential submissions
may be filed via ECFS. Parties are advised that the Commission looks with disfavor on claims of
confidentiality for entire documents. When a claim of confidentiality is made, a public, redacted version
of the document should also be filed.
The proceeding of which this Public Notice is a part is a “permit-but-disclose” proceeding
conducted in accordance with the Commission’s ex parte rules. Persons making ex parte presentations
must file a copy of any written presentation or a memorandum summarizing any oral presentation within
two business days after the presentation (unless a different deadline applicable to the Sunshine period
applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex
parte presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
5 See Petition for Reconsideration of Action in a Rulemaking Proceeding, 79 Fed. Reg. 13,975 (March 12, 2014),
available at https://federalregister.gov/a/2014-05261.
6 See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24,121 (1998).
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has
made available a method of electronic filing, written ex parte presentations and memoranda summarizing
oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment
filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex
Paperwork Reduction Act of 1995. This Public Notice does not contain new or modified
information collection requirements subject to the Paperwork Reduction Act of 1995, Public Law 104-13.
Therefore it does not contain any new or modified “information burden for small business concerns with
fewer than 25 employees” pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-
For further information, please contact Eric Schmidt in the Cybersecurity and Communications
Reliability Division of the Public Safety and Homeland Security Bureau at (202) 418-1214 or