The FCC’s Public Safety and Homeland Security Bureau released a public notice today to launch a review of the adequacy of the voluntary Wireless Network Resiliency Cooperative Framework. The public notice also seeks comments for a study on providing the public access to 911 services via Wi-Fi and other technologies.
“The devastating 2017 hurricane season provided insight into how wireless providers react to varying levels of damage to their wireless networks and how they cooperate after disasters. The Public Safety and Homeland Security Bureau (Bureau) is currently working with providers, public safety officials, and others to determine what lessons may be learned from the past season to better prepare for future emergencies. By this Public Notice, the Commission further complements its ongoing analysis of network resilience during and after the 2017 hurricanes and lays the groundwork for improved wireless network resiliency in the future,” the bureau said.
“We believe this is an opportune time to review the overall efficacy of the Wireless Network Resiliency Cooperative Framework (Framework). Since its initiation in 2016, the Framework has provided a systematic approach to enhancing coordination during disasters to protect the reliability of wireless networks. Our goal is to ensure that this voluntary industry commitment to promote resilient wireless communications and situational awareness during disasters is robust and effective. Therefore, the Bureau seeks public comment on potential methods of measuring the effectiveness of the Framework, determining the extent of the Framework’s use, and further promoting awareness of the Framework,” the public notice added. “We also seek comment on ways to further facilitate improvements to the Framework, including by soliciting voluntary commitments from backhaul providers to address processes and best practices for information sharing for network restoration and coordination during disasters.”
The public notice also said that “pursuant to Title III, Section 301 of RAY BAUM’S ACT, we seek comment on a future Commission study that will address the public safety benefits, technical feasibility, and cost of providing the public with access to 911 services during times of emergency via Wi-Fi access points and other technologies, when mobile service is unavailable.”
The bureau said it seeks “public comment, including from Framework signatories, wireless service providers, public safety entities, and other stakeholders, on how best to measure the extent of the Framework’s use and its effectiveness. Should we seek input on a recurring or an ad hoc basis from signatories? How can we measure the extent and effectiveness of roaming under disaster arrangements? Should we evaluate the effectiveness of the Framework based on metrics such as the percentage of customers covered by roaming agreements on a per-wireless provider basis? Is there another useful metric, such as the percentage of calls completed during an emergency due to roaming agreements? How can we best measure the extent that carriers provided, sought, or received mutual aid during emergencies and the effectiveness of such mutual aid? Is measuring the efficacy of mutual aid during emergencies too context-specific to measure in a standardized way? Would a narrative form of reporting by signatories provide the Commission with sufficient information?
“We also seek comment on measuring enhancements to municipal preparedness and restoration, including a PSAP database, once it has been established,” according to the bureau. “How can we measure the extent to which industry best practices, including those recommended by CTIA as part of its commitment to the Framework, are followed? Is there evidence of how communities are leveraging these best practices, and can that evidence be used to measure enhancements to municipal preparedness and restoration? What metrics are available to measure the usefulness and effectiveness of the Consumer Readiness Checklist? Should the Bureau attempt to establish benchmarks for measuring awareness of the Checklist and if so, what should those benchmarks be? Would a narrative form of reporting by signatories provide the Bureau with sufficient information on the effectiveness of the Checklist? Are certain prongs of the Framework presenting challenges to signatories that are preventing their abilities to enhance wireless resiliency?”
The bureau also wants views “on how it can most effectively promote awareness of the elements of and any outcomes from the Framework among federal, state, and local public safety partners and other industry stakeholders. What are the best methods for measuring the effectiveness of such promotion? What metrics are available to measure the extent to which posting aggregated data on cell site outages through DIRS [Disaster Information Reporting System] reports has improved public awareness and stakeholder communications on service and restoration status?”
The bureau said “that particular challenges during Hurricane Maria included the ability of wireless carriers to obtain real time information from backhaul providers about the status of network restoration efforts, as well as the relative lack of meaningful coordination on those efforts among backhaul providers, wireless providers, local government partners, and power companies. The Bureau thus seeks comment on whether soliciting voluntary, tailored commitments from backhaul providers within the existing Framework would be an effective method for addressing these challenges. Specifically, should backhaul providers be encouraged to participate in the Framework and work cooperatively with wireless providers and other relevant stakeholders to develop a process for sharing restoration information during disasters, including a timeline of expected restoration efforts, based on either the prioritized list of circuits or those circuits designated for high traffic during emergencies? If so, what would that process be? Should participating backhaul providers work with wireless providers and other stakeholders to incorporate best practices for information sharing and network restoration prioritization efforts, including coordination with federal, state, and local emergency response agencies and power companies similar to the CTIA Best Practices?
“Do backhaul providers have access to contact information from emergency response agencies and power companies for emergency response, network restoration, and continuity of operations, and could they share such contact information with other Framework signatories, affected carriers, and the Commission? Are there other challenges that could be addressed by extending the Framework to include backhaul providers?” the public notice asked. “Should any such extension be applicable to all providers of backhaul service, including cable providers? Would extending the voluntary Framework to include backhaul providers raise any significant challenges for participating providers that could hinder their own restoration efforts, including restoring service to corporate and/or residential end users? Are there particular incentives or disincentives for backhaul providers’ voluntary participation in the Framework that we should consider? To what extent are existing federal and state restoration and resiliency frameworks, such as the Telecommunications Service Priority, sufficient in addressing the concerns expressed following last year’s hurricane season, particularly after Hurricane Maria?”
Regarding the report it must prepare on 911 services, the bureau noted that “the study must consider (1) making telecommunications service provider-owned WiFi access points, and other communications technologies operating on unlicensed spectrum, available to the general public for access to 911 services, without requiring any login credentials, during times of emergency when mobile service is unavailable; (2) the provision by non-telecommunications service provider-owned WiFi access points of public access to 911 services during times of emergency when mobile service is unavailable; and (3) other alternative means of providing the public with access to 911 services during times of emergency when mobile service is unavailable.
“We seek comment on several issues and assumptions arising out of these statutory provisions to aid in developing the required report,” it said. “What current or near-future capabilities would be required for WiFi hotspots to implement the contemplated emergency access? What technical or operating specifications would be necessary to restrict access and secure communications for the purpose of emergency services? Are there differences in the capabilities that would be required for voice versus text access to 911? What corresponding capabilities would be required for consumer handsets to support such access? Are there some types of consumer handsets for which this capability would be difficult or impractical to provide? Could over-the-top software applications play a role in facilitating emergency access to WiFi hotspots? Are there means to facilitate emergency access to hotspots in a transparent manner that would not require action on the part of the end user? What technical, operational, or administrative barriers might impede emergency access to 911 over WiFi? What other avenues of inquiry should the Commission pursue to fully inform the contemplated report?”
Comments are due July 16 and replies July 31 in PS docket 11-60. —Paul Kirby, firstname.lastname@example.org