STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY
Re: Improving 911 Reliability, PS Docket No. 13-75; Reliability and Continuity of
Communications Networks, Including Broadband Technologies, PS Docket No. 11-60
Matters regarding reliable emergency communications are too important to be taken lightly or be
handled in haste. Throughout this proceeding, I have been asking the Commission to think things through
and do our best to get it right the first time. Unfortunately, we have not shown such necessary restraint.  
The philosophy seems to be act now, fix later.
Since releasing the initial 911 reliability order a little over a year and a half ago,
1
we have already
issued a notice of proposed rulemaking (“2014 Notice”) seeking to build upon and expand the needlessly-
burdensome requirements.
2
  I dissented to both of these items and specifically expressed concern that, in
adopting these reliability rules, we should not have “rushed forward without greater thought and effort.”
3
And now we have today’s Order on Reconsideration clarifying aspects of the certification requirements
adopted in the original order.  Since the comment cycle for the 2014 Notice closed in the end of April,
4
it
will not be long before we are presented with yet another item to modify these rules.
Although the Commission should act as swiftly as possible, we cannot do so at the expense of
quality and clarity.  We must keep in mind that providers do not have infinite resources, they only have so
many experts working on these issues, and they need time to meet the requirements under our rules.  And,
for industry to comply, these rules must be relatively stable, not stuck in a continuous cycle of being
reconsidered or altered.  Putting in place rules that are not fully cooked burdens providers, results in costs
that are passed on to consumers, and hurts the Commission’s credibility.
Regardless, I can support today’s order, because the clarification provides necessary flexibility
when it comes to certifying compliance with the 911 reliability requirements. By permitting entities to
show that they have implemented “alternative measures” for any of the prescriptive certification elements
(e.g., circuit diversity auditing and network monitoring), entities will be able to implement reliability
measures tailored to their individual networks.  This should promote innovation, adoption of NG911
capabilities and, most importantly, resilient emergency communications systems that will ensure that
Americans can reach first responders in times of need.   
                                                
1
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 (2013).
2
911 Governance and Accountability, Improving 911 Reliability, PS Docket Nos. 14-193, 13-75, Policy Statement
and Notice of Proposed Rulemaking, 29 FCC Rcd 14208 (2014).
3
Id. at 14265.
4
911 Governance and Accountability, Improving 911 Reliability, PS Docket Nos. 14-193, 13-75, Order, 30 FCC
Rcd 2085 (2015) (extending the comment filing date to March 23, 2015 and the reply filing date to April 21, 2015).