APCO Says FCC Should Require Backup Power Testing in Aftermath of Derecho

Verizon last week detailed the problems that led to major problems at four public safety answering points (PSAPs) , including generator failures at two Verizon centers (CD Aug 15 p1). Verizon attached a copy of that report to its comments (http://xrl.us/bnmgzz). FCC Chairman Julius Genachowski has indicated the commission would at least consider backup power requirements in the wake of the 911 problems (CD July 20 p1). The FCC imposed requirements once before, later dropping the post-Hurricane Katrina mandate (CD Dec 2/08 p1).

"Interviews with PSAP managers whose centers were impacted by the June 29 storm indicate that Verizon’s network operations center (NOC) personnel did not appear to be fully aware of the status of the relevant central office equipment failures or the status of 911 call delivery in Northern Virginia,” APCO said (http://xrl.us/bnmhop). “A major issue for PSAPs on June 29 was the lack of outage reports and related communications from their local carriers. In critical times of outages when systems fail, it is imperative that there be direct contact with an on-call representative of the LEC [local exchange carrier]. However, managers from several of the impacted PSAPs reported to APCO that they did not receive timely, accurate or complete information regarding the network outages or restoration efforts."

APCO also called for various testing and reporting requirements for backup power facilities. “For years, LECs have known that they have had problems with their generators and uninterrupted power supplies (UPS),” the group said. “These items should be tested under load weekly, just as is done by most PSAPs.” Carriers should be required to report the results to the FCC’s Public Safety Bureau “within 3 business days, and complete a successful retest and report within 24 hours,” APCO said. “LECs should also provide semi-annual documentation of preventive maintenance inspections for UPS and batteries."

The National Emergency Number Association declined to make any recommendations, saying in a one-page letter it’s still reviewing the derecho-related problems (http://xrl.us/bnmhry).

Verizon and Verizon Wireless’s comments largely followed the post-storm report the company released last week. “Verizon has begun a reassessment and redesign of its telemetry system in light of its experiences in the storm,” the carrier said. “This redesign is intended to provide more diverse connections and alternate (backup) locations, in the event of a problem at a location where telemetry functions ordinarily occur. Verizon is also instituting automated controls to give higher priority to maintaining or restoring the telemetry functions when generator problems arise so that monitoring can continue in those circumstances.” Verizon said it also took “additional steps to further mitigate the potential impact of commercial power loss on its networks and services. These measures include audits of backup power systems for mission-critical facilities supporting 911 and taking necessary corrective actions to address issues identified in those audits."

"Back-up power and its associated challenges provide an example of how prescriptive regulation can create significant challenges for wireless licensees,” CTIA said (http://xrl.us/bnmhgo). “While wireless carriers have made substantial investments in back-up power solutions, they have in many cases encountered significant obstacles in installing back-up power equipment at particular sites. For example, some cell sites simply have too little available space to install back-up power equipment, while others may not be able to support the weight of back-up power sources."

Derechos are a rare event and all its operations performed well during the storm, AT&T said. “The Commission should not pursue new regulatory mandates, such as on-site back-up power requirements, which would divert and dilute carrier resources that could otherwise be used more effectively in a disaster,” (http://xrl.us/bnmheo). “In addition to being inefficient, an on-site back-up power mandate could conflict with other Federal, State, and local regulations. Finally, placing extended back-up power resources on-site could be unsafe or impractical for many facilities."

"The competitive nature of the CMRS marketplace incents wireless carriers to take appropriate measures necessary to maintain a reliable and resilient network,” T-Mobile said (http://xrl.us/bnmhtb). “Voluntary best practices is the preferred approach to supporting network reliability and resiliency as this methodology offers wireless carriers maximum flexibility to appropriately adjust and quickly respond to outage incidents."

States and counties sought further investigation of the failures and some offered specific recommendations for FCC action.

The FCC should “require Verizon to identify what elements of its network and supporting central office equipment are mission-critical facilities for 9-1-1 service and explain how Verizon intends to provide the necessary degree of reliability for these mission-critical facilities,” Fairfax County, Va., said (http://xrl.us/bnmheu). The carrier should “publicly identify its risk tolerance policy related to its backup and recovery capabilities for 9-1-1 service,” review and test its Continuity of Operations and Disaster Recovery plans and develop alternative communications methods for Verizon to reach PSAP staff during emergencies, the county recommended. Fairfax reiterated that Verizon should adopt the five recommendations of Northern Virginia 911 directors which were submitted earlier (CD Aug 15 p1).

"We strongly recommend that the FCC re-adopt backup power requirements for wireless and broadband providers” and not to “preempt state authority” in doing so, the California Public Utility Commission said (http://xrl.us/bnmhv2). The commission has asked California wireless carriers for backup power arrangements and plans to share with the FCC in reply comments, it said. The CPUC also recommends the FCC “encourage states to adopt pole attachment requirements” due to poor maintenance.

"Apparently, Verizon was not so well prepared for the commercial power loss,” Fairfax County said. “As a result of the backup power failures, and the failure and damage of other Verizon equipment, 9-1-1 service in Fairfax County failed.” No calls were routed to the Fairfax 911 center for more than seven hours, the county said, which received the worst of the derecho-related outages. Verizon data shows just under 1,900 calls failed to reach the center during the first 29 hours after the storm, the county said. “Over the next two and one-half days, with daily temperatures in the 90-degree range and hundreds of thousands of County residents without power, 9-1-1 service remained sporadic,” the county added. Its comment attacked Verizon’s email to Fairfax officials about the power loss as “unclear,” “a passive and ineffective method of communication” and emblematic of “a chronic, systemic problem that urgently needs correction.” Reviewing the multiple government investigations of Verizon outages and Verizon’s history, Fairfax described a “string of 9-1-1 failures over the past several years” that prove “Verizon cannot be relied upon to diagnose and cure its own problems unassisted.” “Immediate and longer-term changes are needed to improve 9-1-1 service in the metropolitan Washington, D.C., area,” it said.

The Virginia State Corporation Commission reiterated its support for FCC investigation and “the joint interests of both of our regulatory agencies,” said Telecom Director William Irby (http://xrl.us/bnmhpw). The Virginia commission’s interim report on the outages is due Sept. 14 and final report Dec. 31, it said. Although the derecho did not apparently affect 911 service in Maryland, that state’s public service commission noted it has “dealt with other 9-1-1 outage issues and resiliency and reliability issues which may be helpful to the inquiry” (http://xrl.us/bnmhst). The National Association of State Utility Consumer Advocates (NASUCA) underscored the importance of providing “specific information regarding the performance and reliability of different communications platforms to access 9-1-1 service” and generally in a comment supported the investigations(http://xrl.us/bnmhui). “The FCC, state commissions, and state governments must consider and address the bigger picture and assure that the communications industry is subject to meaningful oversight and accountability,” NASUCA said.

Broadcasters touted their utility during emergencies, in comments responding to the FCC’s recent public notice on the reliability of 911 services during this summer’s derecho storm. Broadcasters’ “special role during emergencies” was confirmed again during the storms, NAB said (http://xrl.us/bnmixc). The association urged the commission to consider ways to expand access to broadcast services and the public benefits to emergency broadcasting that would go along with such an expansion, the comments said.

The FCC has spoken to six carriers, 25 public safety answering points -- some multiple times -- regarding the outages, said Public Safety Bureau Chief David Turetsky at the APCO annual conference Monday. “Our focus is on learning all the facts, circumstances and causes of the outage,” he said, urging the hundreds in attendance to submit reply comments reflecting their “vantage point on the front lines.” The bureau expects to release a report later this year, he said. “Our goal is simple: It is to use this information to make people safer. We want to enhance public safety by identifying and applying the lessons learned in order to help make communications more reliable and resilient and to reduce the chances that 911 outages of this type will be repeated,” Turetsky said. “We should not, and do not find it acceptable for 911 to be available reliably in the normal circumstances, where a range of emergencies takes place, but not available reliably where a natural disaster occurs.”