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The Association of Public Safety Communications Officials (APCO) made recommendations to FCC Chairwoman Rosenworcel’s office to issue proposed rulemaking on additional interoperability requirements for 9-1-1 providers. Specifically, APCO suggested that the emergency communication centers (ECC) which each provider serves should be able to certify their ability to transfer traffic to other ECCs located in at least three other states. This certification will demonstrate the ECCs’ capabilities to provide mutual aid to neighboring ECCs as well as troubleshoot misdirected IP-based traffic. APCO also suggested the FCC expand upon technical requirements for providers, such as record management and upgrading existing technology.