A variety of parties have weighed in on the resiliency of communications infrastructure, the effectiveness of emergency communications, and the responses of the government and industry during the 2017 hurricane season. While some cited actions that helped response to the massive storms, they also suggested improvements, including changes to the FCC’s Disaster Information Reporting System (DIRS) and closer coordination between industry and government stakeholders.
Comments were filed in PS docket 17-344 by yesterday’s deadline in response to a public notice released last month by the FCC’s Public Safety and Homeland Security Bureau soliciting views in the wake of the destruction inflicted by four hurricanes last year, including three Category 4 hurricanes – Harvey, Irma, and Maria – the first time in history that three Category 4 storms have hit the U.S. in the same season (TR Daily, Dec. 7, 2017).
Wireless services were hit hard, especially by Hurricane Maria. After Harvey, nearly 5% of cell sites were out service across the impacted area in Texas and elsewhere at the peak, and after Irma more than 27% of cell sites were knocked out in Florida and nearly 56% in Puerto Rico. Maria wreaked the worst destruction, with more than 95% of cell sites out in Puerto Rico and more than 76% offline in the U.S. Virgin Islands.
But in its comments, CTIA said that Americans were able to rely on wireless services during the hurricanes. “The availability of mobile wireless networks was due, in large part, to the wireless industry’s application of lessons learned from past storms – most notably Hurricane Katrina and Superstorm Sandy. Wireless providers have invested to strengthen networks, and with the storms approaching, they pre-positioned resources and put into operation the key elements of the 2016 Wireless Network Resiliency Cooperative Framework (‘Cooperative Framework’ or ‘Framework’),” CTIA said. “It proved effective in enhancing service continuity and information sharing during and immediately after these historic storms. And when cell sites went down, the Cooperative Framework helped wireless providers and their representatives on the ground restore service as quickly as possible and support the greater rebuilding efforts in impacted communities. In Puerto Rico and the U.S. Virgin Islands, where extreme weather conditions and the near total destruction of the electric grid posed significant challenges across the board, the coordination and flexibility provided for in the Cooperative Framework helped wireless providers collaborate and develop innovative solutions to maintain and restore service.”
“To further promote service continuity and enhance the information made available on the status of communications networks, CTIA encourages the Commission to: continue to facilitate investment in wireless networks through modernizing infrastructure deployment processes and making more flexible use spectrum available for mobile broadband; and provide flexibility in the content of its Disaster Information Reporting System (‘DIRS’) reports,” the trade group’s filing said. “Reducing regulatory barriers to infrastructure deployment and making additional spectrum available for mobile wireless use will allow for continued network densification and increased capacity, which will in turn improve network resiliency and ensure networks are able to carry the increased volume of critical communications during and after emergencies and disasters. And maintaining flexibility in the DIRS reporting process will allow the Commission to tailor the information available to the public based on the particular circumstances of each emergency or disaster, providing greater clarity to the public about the availability of communications services in their areas.”
“While DIRS reports throughout Hurricanes Harvey and Irma generally served their intended purpose, it became evident following Hurricane Maria that including additional information could provide a more accurate picture of the status of communications networks,” CTIA said. “As previously noted, the Commission offered wireless carriers the ability to provide additional information and context in DIRS reports regarding carrier roaming arrangements, deployment of COLTs [cells on light trucks] and COWs, [cells of wheels] and included information regarding the availability of wireline and broadcast services – all of which was relevant in the context of Hurricane Maria. Including this information helped consumers understand that even though cell sites were down in their area, wireless service may still have been available.”
CTIA said that it “supports including other relevant information, such as the status and availability of commercial power, to the extent such information is publicly available from federal agencies. CTIA and its members welcome further discussions with Commission staff on potential improvements to DIRS reporting.”
“The 2017 hurricane season’s widespread impact on communications networks in the Southeastern United States and the Caribbean provides an important snapshot into the industry’s progress in making networks and services more resilient and reliable in the years since Hurricane Katrina and Superstorm Sandy. It also highlights the importance of disaster coordination and planning across different industry sectors and between industry and government stakeholders,” Verizon Communications, Inc., said. “Verizon’s performance during and after Hurricanes Harvey and Irma illustrates the benefits of upfront investment in – and applying best practices to – reliable network infrastructure, personnel training, and other preparedness measures. Due to our substantial investment in network architecture and backup power resources, more than 98 percent of Verizon’s network facilities in the hardest hit areas in Texas remained in service during and after Harvey. In Florida more than 90 percent of our facilities remained operational over the first days after Irma, and within five days after the storm our network performance was back its normal high level. In nearly all the counties for which the Commission activated its Disaster Information Reporting System (‘DIRS’) for cell site outages, Verizon’s performance exceeded the industry’s aggregated average.”
“The voluntary efforts of the commercial mobile radio services (‘CMRS’) industry, coupled with the competitive nature of the market, generally worked well to ensure resilient wireless networks and the rapid recovery of those portions of wireless networks damaged during the 2017 hurricane season,” T-Mobile US, Inc., said. “The Commission, through its Disaster Information Reporting System (‘DIRS’), collected extensive information regarding the performance of wireless networks in the wake of these hurricanes. This information confirms that overall wireless networks performed remarkably well during the 2017 hurricane season considering the varying circumstances. It is also worth noting that, while reporting includes information on the number of sites that are not operational or ‘down,’ this does not mean that a tower has been damaged or destroyed, but generally means loss of power or backhaul.
“Although wireless networks suffered outages immediately after the 2017 hurricanes, wireless carriers responded quickly to restore service,” T-Mobile added. “Lengthy delays in service restoration during the past hurricane season were generally not due to a failure of wireless infrastructure, but could be ascribed to the limited availability of commercial power and/or failures in third-party backhaul networks (coupled with the inability of the power and backhaul providers to restore these networks quickly). In particular, the complete and extended failure of the power grid and most of the fiber backhaul facilities in Puerto Rico, combined with the fact that Puerto Rico is an island, presented challenges to disaster response that would not necessarily be present in the continental U.S.”
“Experience gained as a result of the 2017 hurricane season suggests that the FCC should revisit DIRS and modify the tool to collect information that is more reflective of restoration efforts for the entire communications networking ecosystem,” T-Mobile said. “Wireless carriers generally focus service restoration efforts in the wake of natural disasters on restoring a ‘coverage layer’ of service to geographic areas quickly, which can be accomplished without restoration to every cell site within a carrier’s network. This focus is driven by wireless carriers’ determination to reconnect as much of the population as possible back to the network. Current DIRS reports do not truly reflect this service restoration progress as the reports focus on the number of cell sites that are operational, rather than the scope of geographic coverage. Thus, the Commission should modify DIRS to reflect the population without any service in a geographic area. The Commission also should explore opportunities to gather and disseminate information regarding backhaul outages and restoration efforts given the importance of these networks for the provision of wireless services.”
“While these events caused service outages in some instances, the underlying support structures, like towers and rooftop facilities, largely weathered the storm making restoration of service that much faster,” said the Wireless Infrastructure Association. “Most tower-supported networks feature inherent redundancies based on the distributed nature of modern wireless networks. And while a not insignificant number of people were impacted by the loss of wireless service during and immediately following the hurricanes, the redundancy of the network means that while there may be loss of service at one site, the outage is isolated. As was shown during the 2017 hurricane season, the wireless infrastructure industry quickly restored service in the affected areas shortly after the storms. According to the FCC’s outage data, during Hurricane Harvey and Hurricane Irma, virtually all wireless service was restored to the affected disaster areas within one week.”
Virgin Islands Telephone Corp. (d/b/a Viya) cited the challenges of recovering from the destruction that occurred as a result of hurricanes Irma and Maria and recommended several FCC actions.
“Specifically, Viya requests the Commission to consider providing additional funding to smaller island markets for the hardening of network infrastructure against future storms and to consider the unique operational challenges of serving smaller island markets in its policymaking generally,” it said. “In addition, Viya encourages the Commission to maintain a flexible approach to the implementation of the Disaster Information Reporting System (‘DIRS’). Further, Viya believes that communications restoration should be provided a higher priority when allotting governmental disaster recovery resources. Finally, Viya encourages the Commission to continue to play a leading role in coordinating the interactions between and among carriers and federal and Territorial governmental agencies regarding communications issues arising during disaster recovery efforts.”
Puerto Rico Telephone Company, Inc., (PRTC) (d/b/a Claro) said, “Unfortunately, the resiliency of the communications infrastructure in Puerto Rico, as well as the industry’s ability to respond to natural disasters such as storms and hurricanes, is severely handicapped by the massive problems with the island’s outdated and fragile electric power grid that are beyond any single entity’s control.”
Comcast Corp. said it “was able to keep many consumers connected, even those consumers displaced from their homes, during and in the immediate aftermath of both storms [Harvey and Irma]. In the Houston area, all 29 of our affected hub facilities remained operational despite massive flooding from the equivalent of a year’s worth of rain in four days. And in Florida, despite significant winds that knocked down support structures and cables across the state, we were able to restore service to more than 92% of our impacted customers within the first week after Hurricane Irma passed, and to over 99% of our customers a few days later.”
“Comcast’s experiences with Harvey and Irma reinforce the need for close coordination and open communications between service providers and federal, state, and local officials,” the company added. “As each hurricane was approaching landfall, Comcast’s local teams established contacts with federal, state, and local government authorities to ensure open communications channels, and obtained letters and other authorizations identifying its vehicles and repair crews as critical infrastructure providers eligible to access restricted areas. This coordination with local governments also expedited recovery efforts by facilitating both formal and informal waivers and other authorizations to deploy new cables and fiber, sometimes on a temporary basis, outside the usual permitting process.”
However, it said such coordination was sometimes lacking. “In Miami, for example, despite the best efforts of all parties to coordinate during the disaster, communications providers such as Comcast were not automatically placed on the ‘priority list’ to obtain emergency fuel or have commercial power restored to hub facilities by the local power company,” Comcast said. “This miscommunication made it more difficult for Comcast to refuel the generators needed to keep its facilities running until commercial power was restored. More broadly, Comcast’s efforts to bring contractors and other resources from outside the affected areas to help with preparation and recovery encountered numerous transportation-related administrative hurdles, because many of the inspections and registrations for certain vehicles are done on a state-by-state level.”
Charter Communications, Inc., said that Florida “customers suffered over 14,000 outages due to Hurricane Irma. And in Texas, Hurricane Harvey resulted in a total of 669 reported outages at the node level, impacting tens of thousands of accounts. However, due to preparation, coordination, and communication, Charter was able to restore service to most affected customers in a relatively short period of time. For example, in Florida where Charter was most significantly impacted, within 10 days after Hurricane Irma hit the region, service had been restored to 90% of customers originally impacted by the storm. For the remaining ten percent of customers, the vast majority of outages [were] caused by loss of power to homes or businesses or to Charter’s network.”
For its part, the satellite industry emphasized the value of its networks when terrestrial-based systems are out.
“Satellite communications (SATCOM) networks are indispensable in the event of a hurricane disaster,” the Satellite Industry Association said. “SATCOM networks are best positioned to inform decision-makers about the path and strength of an impending storm so that appropriate evacuation orders can be issued in advance of a hurricane. Additionally, SATCOM networks are more resilient after a hurricane compared to terrestrial communications, which can be easily destroyed in the event of a natural or man-made disaster. In Florida, Puerto Rico, and Texas, SIA members helped restore communications for disaster relief and emergency response organizations at the local, state, and federal levels, through the provision of satellite internet and phone services, as well as support for television broadcasts. These services also allowed for the reopening of critical infrastructure, including pharmacies, banks, grocery stores, and retailers, as well as the restoration of cellular communication for the local populations.”
Hughes Network Systems LLC cited damage to terrestrial networks from the storms and said the Commission “must work to include technological path diversity in its best practices, and explore the adoption of such requirements in its infrastructure funding criteria, such as a contingency for receipt of 9-1-1 network upgrade funding. The government must ensure that adequate funding resources are available to ensure that critical infrastructure and facilities have access to the tools they need to keep communications up and operational during even the worst disasters. With the deployment of the latest satellite technologies, there is no reason for the United States [to] be unprepared again.”
In joint comments, SES S.A. and its O3b Limited subsidiary also cited efforts to provide connectivity during the hurricane season. “As the first satellite operator to deliver a scalable GEO-MEO service offering, SES was able to provide immediate support to help restore service in the aftermath of the 2017 hurricane season,” their filing said. “SES Network’s FastConnect Solution supported Alphabet’s Project Loon and local telecommunications operations to restore 4G/LTE mobile connectivity after Hurricane Maria damaged or destroyed about 95 percent of the Puerto Rico’s cellphone towers.”
“Once the hurricane season began, Ligado responded by placing hundreds of new satellite phone units in the hands of federal and state officials,” said Ligado Networks Subsidiary LLC. “In the immediate aftermath of Hurricane Maria, for example, Ligado quickly responded to a request for satellite telephones from the Puerto Rican government by contacting MISSION UNITED, a United Way of Broward County program that assists veterans in transition from military service. MISSION UNITED was already sending volunteers and supplies to Puerto Rico through a partnership with federal first responders that included the US Army and the Department of Homeland Security. Working with MISSION UNITED, Ligado arranged for the delivery of satellite telephone units to Puerto Rico for distribution to relief workers, community centers and church groups serving as recovery hubs.”
“In light of the devastation left by Hurricanes Maria, Irma and Harvey in 2017, it is imperative that the Commission evaluate how to improve its natural disaster recovery efforts, particularly in speedily recovering damages communications networks,” Public Knowledge said. “Public Knowledge agrees with the Government Accountability Office’s (GAO) recent study on wireless network [resiliency] during and after a natural disaster. The Commission should seriously consider the recommendations given by the GAO and improve wireless network accountability in the light of devastating events of force majeure. In order to improve disaster recovery practices and provide adequate support to disaster victims, Public Knowledge recommends that the Commission hold further proceedings to address the policy concerns outlined in these comments. Finally, the Commission should use its Section 214 authority to ensure that Carriers repair vital copper wireline network or otherwise provide consumers with adequate replacement service.”
Public safety entities weighed in as well.
“Effective pre-planning by officials and local responders, which should be common practice for emergency communications agencies, made a significant difference in managing the hurricanes’ impacts,” said the Association of Public-Safety Communications Officials-International. “For example, agencies in Texas and Florida were able to restore 9-1-1 service after PSAPs were destroyed or lost power by rolling calls to secondary and even tertiary sites, and in at least one instance bringing in a mobile PSAP. Compliance with industry best practices on redundancy and resiliency improved the likelihood that communications networks would remain online, both for telecommunications and radio services. Cross-industry participation involving multiple providers is essential for effective redundancy and resiliency planning. Agencies and service providers fared better where they had ensured proper tower loading and maintenance and followed best practices for the location of equipment at the site, back-up requirements (battery, generator, or both), re-fueling considerations, etc. Where best practices were not followed, design and redundancy issues prolonged the outages.”
APCO also singled out for praise the FCC’s efforts to deploy radio frequency equipment to determine where outages had occurred as well as the work of amateur radio operators. But it said that more federal agency coordination and information sharing were necessary.
For example, while “DIRS serves as a helpful resource for providing situational awareness of outages,” APCO said that the FCC “could build upon the information at its disposal by augmenting DIRS data with local, ground-based reports. For example, a cell site might have no backhaul, no capacity, and no ability to provide actual service, but not be reported in DIRS as out of service. This can lead to a fundamental disconnect between outage reports and reality.”
It added, “Improving public safety awareness regarding service and restoration status through a carrier-PSAP contact database was a key commitment of the Wireless Resiliency Framework. Carriers and PSAPs could both benefit from such a resource, particularly for response to major outages during disasters. APCO looks forward to the carriers establishing the database and stands ready to assist the carriers with populating it.”
The city of Houston cited massive flooding from Hurricane Harvey. “Wireless networks in the immediate area of Houston stayed up and operational with only limited, localized interruptions,” it said. “Therefore, first responders were able to use cellular voice and data when network demands allowed. There was still some network congestion but based on the continued availability of the network, it had little impact. LMR was heavily used and stayed operational throughout the incident. The LMR networks in Houston rely on microwave as transport medium. There were some very limited link failures during the extreme portions of the storm but due to the redundant design were not service impacting.”
“The Houston Emergency Center (HEC) experienced a ten-fold increase in 911 call volume during the peak of Hurricane Harvey. An average of about 6000, 911 calls are received each day normally; during the peak day of the hurricane (Sunday, August 27, 2017), HEC received 60,000, 911 calls and answered 40,000 of those calls,” the city added. “The increase in 911 calls made it difficult for individuals to get through to emergency responders. Many power-dependent people with disabilities were on hold for extended periods of time waiting to get through to 911, and few were successful.”
The American Radio Relay League cited the work of its members during the hurricane and reiterated its call for (1) FCC action on a pending ARRL petition for rulemaking that asked the agency “to eliminate the symbol rate limit … relative to data emissions in the Amateur allocations below 29.7 MHz; and to establish a 2.8 kilohertz maximum occupied bandwidth for data emissions in those bands”; (2) congressional passage of the Amateur Radio Parity Act or, if Congress does not pass the bill, FCC action consistent with the legislation; and (3) FCC action on a pending petition for rulemaking to implement domestically a portion of the Final Acts of the 2015 World Radiocommunication Conference providing for the allocation of the 5351.5-5366.5 kHz band to the amateur radio service on a secondary basis.
The Puerto Rico Telecommunications Regulatory Board (PRTRB) said, “The telecommunications towers in Puerto Rico withstood the hurricane well; only less than two percent were damaged. However, cell site antennas fell or became out of alignment.” It also said that “a regional office of the FCC is needed in Puerto Rico for more efficient support and coordination of all response efforts in an emergency.”
The PRTRB also called “helpful” “information provided by the Commission before and after hurricanes Irma and Maria. “Nonetheless, the PRTRB had to issue an Administrative Order on October 10, 2017, ordering the companies certified and registered by the PRTRB to provide more detailed information on the recovery of critical telecommunications infrastructure,” it said. “The Board ordered this detailed information be provided daily until otherwise ordered, and indicated that said information would be handled in a confidential manner. In addition, the Administrative Order requested the plans of lifting of the individual telecommunications of each provider (healing plans), with the purpose of daily mapping the telecommunications service and infrastructure reconstruction progress.”
The U.S. Department of Homeland Security’s Office of Emergency Communications provided statistics on the use of the Government Emergency Telecommunications Service (GETS), Wireless Priority Service (WPS), and Telecommunications Service Priority (TSP) programs before, during, and after the hurricanes. OET recommended that the FCC update its WPS rules for priority voice, video, data, and information services being offered by wireless carriers.- Paul Kirby, firstname.lastname@example.org