Carriers Ask FCC for Flexibility in Making Disaster Preparations

"It is imperative that the Commission continue to give wireless carriers flexibility to plan for and respond to catastrophic events,” CTIA said (http://xrl.us/bnonm2). “The Commission can provide no greater incentive than the carriers’ existing interest in protecting their significant network investments and providing wireless consumers with robust service. Wireless carriers have voluntarily employed best practices based on network disaster recovery teams’ experiences.” CTIA noted that many wireless facilities already have backup power supplied by batteries and diesel generators. “In some cases, a COW [cell on wheels] or COLT [cell on a light truck] may be a better solution than a backup power source, and carriers should have the flexibility to make such judgments,” CTIA said.

The FCC should “consider re-adopting backup power requirements for communications facilities, in particular for wireless facilities,” the California Public Utilities Commission said (http://xrl.us/bnoni5). Based on data it’s analyzed, wireless facilities have less backup power than wireline, the CPUC said. “Of the data received from the state’s largest wireless providers, over 90 percent of the cell sites in California have backup power supplies, but a majority of these sites have supplies that last less than eight hours."

Fairfax County, Va., suffered the worst of derecho 911 outages (CD Aug 16 p5), though other jurisdictions in Maryland and Virginia also took Verizon to task. Despite no “appreciable impact on 9-1-1 operations,” in Maryland’s Montgomery County, the municipality reported high call volume “busied out” four 911 trunks: One wireline, one wireless and two VoIP (http://xrl.us/bnonex). “The County does have issues with the fact that while Verizon did send a ‘Mass Call Notification,’ it did not notify the PSAP of the trunk outages,” it said of the county’s public safety answering point. “The County is also not satisfied that Verizon acted in a timely fashion to restore the 9-1-1 trunks.” Verizon’s fixed the problems and is taking corrective actions to prevent them in the future, and not all of its 2,000 PSAP customers may want a company representative on-hand during emergencies, the telco said in earlier replies (CD Sept 6 p9).

Loudoun County, Va., attacked Verizon for failing where PSAPs succeeded. “The power failures in Arlington and Fairfax had a top-down, cascading, and negative effect on intranetwork communications between Verizon central offices,” County Administrator Tim Hemstreet said (http://xrl.us/bnonmo). “The 9-1-1 service is a service in which responsiveness is measured in seconds, not minutes or hours. Yet when Verizon’s equipment failed, and 9-1-1 calls were not being routed to Loudoun County’s PSAP, Verizon failed to notify the County.” Loudoun County reported 81 blocked 911 calls over a 36-hour period, with 356 calls “processed via 9-1-1 wire line and wireless trunks.” Verizon initially provided the numbers in a email with scant detail, Hemstreet said. “It took 39 days, following the Derecho storm, for Verizon to provide the information on how many calls were not processed, before Loudoun County’s PSAP Director could calculate the percentage of missed calls; 23.75 percent."

Montgomery County, Md., highlighted the reliability of its wide area network and that county-owned system’s ability to weather such emergencies through backup power. “What the Commission should investigate is whether higher standards need to be developed for facilities that handle critical 911 and emergency communications services,” the county said, dismissing any claim from Verizon that it followed industry standards. The county also questioned the telco’s claims that glitches in its backup power were to blame for 911 outages. The incident’s “troubling,” the county said. “A 911 provider should reasonably anticipate both types of power-related challenges, yet on and after June 29th, Verizon had not appeared to do so."

T-Mobile offered similar comments as CTIA. “T-Mobile recognizes the importance of consumer access to communications networks during major emergencies and has worked extensively to ensure the reliability and resiliency of its network,” the carrier said (http://xrl.us/bnmhtb). “Competitive market forces and strong dedication to servicing customers further ensure that commercial mobile radio service carriers deploy and maintain reliable, resilient networks. T-Mobile’s network has been subject to numerous national disasters over the years and the company has modified its practices and procedures based on lessons learned during these events."

"The comments filed in response to the Public Notice demonstrate the serious efforts that telecommunications carriers have taken, and are still taking, to harden their networks and to reduce the duration of outages caused by extraordinary events such as the derecho storm,” MetroPCS said (http://xrl.us/bnonvt). A backup power mandate won’t inoculate carriers against outages, the carrier said. “Verizon’s outages during the derecho poignantly illustrate the inability of back-up power rules to assure communications during a disaster,” it said. “Despite having back-up generators at two locations that lost power, Verizon’s service still went down because those generators failed to function properly, notwithstanding routine maintenance. Thus, even if the Commission had earlier put in place a sweeping back-up power requirement, there would have been no change in the result."

CTIA also used its reply to fire back at NAB, which argued in derecho comments (http://xrl.us/bnmixc) that “it is time to seriously consider” whether wireless carriers should be required to do more to make sure consumers can listen to live radio broadcasts through chips embedded in cellphones (CD Aug 21 p5). “Wireless carriers, unlike broadcasters, comply with voluntary and stringent mandatory outage reporting requirements to ensure that the Commission and the public are fully informed of system outages,” CTIA said. “In addition, the Commission should reject inapposite arguments raised by the NAB concerning its self-serving drive to have the government mandate business practices that benefit solely their interests rather than the interests of the public.” A NAB spokesman cited a February news release in which NAB said it supports a market-based solution. “From a public safety perspective alone, voluntary introduction of radio chips in cellphones makes perfect sense,” NAB said.

AT&T addressed a single issue, asking the FCC to reject the CPUC’s calls for the federal agency to approve the state regulator’s petition seeking direct access to the FCC Network Outage Reporting System (NORS) database. “The Commission should disregard the CPUC’s comments in this docket, as it bears no direct relationship to the issues raised in the CPUC Petition for access to NORS,” AT&T said (http://xrl.us/bnonod). “To the extent that the Commission considers the CPUC’s comments seeking access to NORS, AT&T renews the concerns it raised in its Comments on the CPUC Petition: given the commercially sensitive and national security sensitive information in NORS, the Commission should deny the CPUC access to the NORS database unless and until all parties are assured that the data is adequately protected.”