The FCC’s Public Safety and Homeland Security Bureau released a public notice today seeking comments on the agency’s network reliability rules, including outage notifications to public safety answering points (PSAPs). Among the questions the bureau asked is whether the agency should weaken the current regulations.
“Under current Commission rules, ‘covered 911 service providers’ are required to: 1) take ‘reasonable measures’ to ensure 911 circuit diversity, availability of central office backup power, and diverse network monitoring; 2) certify annually to their performance of these measures, or to alternative measures demonstrated to be reasonably sufficient to mitigate the risk of failure; and 3) notify PSAPs of outages that potentially affect them,” the bureau noted in the public notice in PS docket 13-75. “When the Commission adopted these rules [TR Daily, Dec. 12, 2013], it committed to review them in five years to determine whether they remain technologically appropriate, and both adequate and necessary to ensure the reliability and resiliency of 911 networks. The Bureau invites interested parties to provide comments and other information regarding how effective these provisions have been in practice, and whether these provisions should be modified to adapt to advancements in technology or other changes. The Bureau will use the record from this Public Notice to recommend next steps, if any, for the Commission’s consideration.”
“As a threshold matter, the Bureau seeks comment on the effectiveness of the existing 911 reliability rules. Have the Commission’s 911 reliability requirements for covered 911 service providers been effective in safeguarding the nation’s legacy, transitional, and Next Generation 911 (NG911) networks from preventable outages?” the bureau asked. “Are there examples of specific circuit diversity, central office backup power, and network monitoring measures that have been taken because of the Commission’s 911 reliability rules? Do the Commission’s current 911 reliability requirements adequately encompass transitional and NG911 networks? What are the most effective measures that covered 911 service providers have implemented to prevent and mitigate outages in networks that include transitional or NG911 elements? Commenters are also invited to submit any information or materials that demonstrate improvements in 911 network reliability since the 911 reliability rules’ effective date, including any contribution by the rules to those improvements. If the rules have not resulted in measurable improvements to 911 reliability, how should the Commission change these requirements?”
The bureau also asked “whether the Commission should replace the existing 911 reliability rules with an alternative framework. For example, would it serve the public interest to require covered 911 service providers to take reasonable measures to ensure the reliability of their 911 networks, but without mandating specific measures to achieve that outcome (i.e., eliminate specific requirements with respect to 911 circuit diversity, availability of central office backup power, and diverse network monitoring)? How would such a general reasonableness requirement be measured and implemented? Should such a general reasonableness requirement apply only to transitional or NG911 networks, with the existing 911 reliability rules continuing to apply to legacy 911 networks? Would such a general reasonableness requirement provide covered 911 service providers with greater flexibility in network administration, while also ensuring sufficient care in 911 networks operation? As another alternative, should the Commission require covered 911 service providers to certify to implementation of certain best practices? If so, what best practices would be appropriate for this purpose, and are they specific enough to ensure a reasonable degree of reliability?”
The public noticed added that “in the event the Commission continues to require covered 911 service providers to take reasonable measures to ensure 911 circuit diversity, availability of central office backup power, and diverse network monitoring, should the Commission continue to require annual certification to the satisfaction of these measures? If so, should the Commission revise the frequency of certification filings? What frequency of filings (e.g., biannual or triannual filing rather than annual filing) would be sufficient to ensure that networks remain reliable through the course of reconfigurations and other network changes, based on relevant data and experience? If certifications have not provided significant additional value, should the Commission eliminate the certification requirement from the 911 reliability rules?”
The public notice also asked parties to update the record on how much it costs to comply with the current rules and whether it should modify the scope of covered entities that are subject to them. “Does the growing diversity of industry participants in the transitional and NG911 environment continue to be adequately encompassed by the term ‘covered 911 service provider’? Are there instances where it may be unclear whether a service provider fits within this category, as it is currently defined?” it asked. “Should the Commission revise its definition of a ‘covered 911 service provider,’ and if so, how? Are there other examples of service providers that are not considered ‘covered 911 service providers,’ but that may nevertheless be integral to supporting 911 reliability?”
The bureau also wants views on the effectiveness of the existing PSAP notification requirements and whether it should standardize how PSAPs are notified about outages. And it asked whether it is possible to reduce the number of notifications about a single event so PSAPs don’t think there are multiple outages.
Comments are due July 16 and replies Aug. 13 in PS docket 13-75. —Paul Kirby, firstname.lastname@example.org