FCC-22-88 Is Now in Force. What CLECs and ILECs Need to Know.

The FCC's Third Report and Order on 911 Reliability — formally FCC Order 22-88 — went into effect April 15, 2025. A year later, enforcement is real, and a surprising number of carriers I talk to are still operating against the old expectation that "we'll deal with it if something happens."

Here's the short version of what the rule actually requires, and the three things I'd check on your own ops before the next major outage finds you.

What the rule says, in plain language

Originating, terminating, and intermediate service providers must notify affected Public Safety Answering Points (PSAPs) of qualifying 911 outages within 30 minutes of detection. The threshold for "qualifying" is when an outage causes a loss of communications impacting at least 900,000 user-minutes, lasting 30 minutes or more.

The notification must follow a standardized format the FCC defined in the order, must include affected areas, service types, 911 impact, and an estimated restoration timeline. And — this is the part people miss — providers must maintain "special diligence" in keeping PSAP contact data current. Stale contact info isn't a defense.

Three places carriers are still exposed

1. Manual notification workflows. If your runbook says "call the PSAP coordinator," you will miss the 30-minute window at scale. Automation isn't optional under this rule — it's the only way to comply when an outage hits multiple PSAPs simultaneously.

2. Stale PSAP contact data. The FCC's master PSAP registry is a starting point, not a finish line. PSAP staff changes, jurisdiction boundary shifts, after-hours contact rotations — most carriers haven't verified theirs in 18 months. Pick one PSAP in your territory at random and call the after-hours number on your own list. Tell me what happens.

3. Intermediate-provider exposure. If you're a CLEC routing traffic that touches 911-bound calls, the rule applies to you even if you're not the originating carrier. A lot of CLECs read this rule as "the BIG carriers' problem." It's not.

What "compliance" actually looks like operationally

You need three things wired up: real-time 911 call-path monitoring that can detect a qualifying event, an automated alerting system that prepares and dispatches PSAP notifications in the required format inside the 30-minute window, and an ongoing maintenance regime for PSAP contact data. You also need an audit trail — when an enforcement action comes, "we tried" isn't evidence; logs are.

You can build that yourself if you have the engineering team and the patience. Most operators don't, which is why Greenway runs it as a service — see DRaaS. But whether you outsource it or build it, the deadline has passed. The next move is yours.

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Greenway is not a law firm and this post isn't legal advice. Consult your own regulatory counsel for your specific compliance posture.