The Federal Communications Commission has issued an Order on Reconsideration clarifying the certification requirements that will apply to certain “Covered 911 Service Providers.” The FCC clarified that under Section 12.4 of its rules, Covered 911 Service Providers may implement and certify an alternative measure for any of the specific certification elements, as long as they provide an explanation of how such alternative measures are reasonably sufficient to mitigate the risk of failure. It stated any provider advancing such an alternative measure will face a heavy burden in demonstrating why comparability cannot be achieved, how the risk of failure has been reduced, and why the measure should be regarded as reasonably sufficient to address the vulnerabilities at issue. The initial reliability certification is due to be filed by October 15, 2015.
