No, but if you are providing voice and telephony services that connect to the public switching network, as CenturyLink does, you absolutely have certain reliability requirements for 911 calls being relayed to local answering points.
I await the results of all the inquiries into this to find out what took place here.
Edit: Oh and "But $ISP doesn't offer traditional phone service, they sell VoIP", is as of 2005 no longer a valid excuse for non-compliance: https://www.fcc.gov/document/commission-requires-interconnec...