On February 21, 2012, the FCC released an Order extending Part 4 outage-reporting requirements to facilities-based and non-facilities-based interconnected VoIP providers.  Reporting requirements are limited to situations where there is a complete loss of interconnected VoIP service on the provider’s network.  The FCC deferred on extending obligations to broadband Internet service providers.  

Under the new rules, interconnected VoIP providers must submit an electronic notification (through the NORS web-based filing system) to the FCC: 

• Within four hours of discovering an outage of at least 30 minutes duration that potentially affects a 911 special facility.  In addition, the VoIP provider also must notify by telephone or other electronic means the designated contact at the affected 911 facility and convey all relevant information. 
• Within 24 hours of discovering an outage of at least 30 minutes duration that (i) potentially affects at least 900,000 user minutes of interconnected VoIP service and results in complete loss of service; or (ii) potentially affects any special offices and facilities (includes major military installations, key government facilities, nuclear power plants or airports). 

In addition, VoIP providers must submit a Final Communications Outage Report to the Commission within 30 days after discovering the outage.  Unlike current outage rules, there is noobligation to submit an initial report. 

The new rules will become effective 90 days after Office of Management and Budget approval. 

For more information about outage reporting obligations, please contact Scott Friedman at (312) 372-3930 or sfriedman@cm-chi.com.