Verizon Says Carriers Should Be Required to Meet 911 Certification Requirement
The FCC should require all carriers to certify their systems meet “a core set of 911 resiliency practices,” which would be developed by public safety and other stakeholders, Verizon and Verizon Wireless said in reply comments. The comments responded to a March NPRM (http://bit.ly/YtIwc5) from the commission, reacting to last year’s derecho wind storm. It led to outages that affected 77 public safety answering points across Ohio, the central Appalachians and the Mid-Atlantic states, with 17 PSAPs losing service completely (CD March 21 p4).
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"The comments in this proceeding make clear that 911 service providers are focused on ensuring the availability and reliability of their services and are actively engaged in applying the lessons learned from the Derecho,” Verizon said (http://bit.ly/133G5RQ). Mandates and new regulations aren’t the answer, the wireless carrier and telco said. “The Commission should focus on such a certification approach, and reject calls for prescriptive mandates and audits that would be diversionary and counterproductive.”
AT&T said the FCC should focus on problems identified in the commission’s January report on the derecho, looking at problems experienced by a few carriers, rather than imposing broad, new mandates. “The Notice afforded commenters favoring prescriptive regulation an opportunity to develop a factual record on why it is necessary or advisable for the Commission to abandon its successful reliance on dynamic best practices in favor of prescriptive regulations, and to demonstrate how new regulations will increase 911 reliability,” AT&T said (http://bit.ly/ZeVQEU). “But regulation proponents have failed on both counts. Commenters favoring prescriptive regulation largely assume a record of industry-wide failure that does not exist, either in the Derecho Report or elsewhere.” AT&T said the record developed by the commission shows: “(1) most 911 Service Providers performed well during the derecho despite the historic severity of the storm; (2) this success resulted from the widespread adherence by 911 Service Providers to voluntary industry best practices; and (3) industry-wide regulatory remedies are not needed."
But the National Emergency Number Association said industry best practices alone aren’t enough. “Contrary to some commenters’ views, NENA is convinced that minimum reliability requirements premised on risk-based analysis of 911 system vulnerabilities are a superior alternative to self-policed, and therefore often ignored, compliance with industry-developed best practices,” NENA said (http://bit.ly/15azTIK). NENA urged the FCC to seek additional comment on a requirement that carriers and system service providers (SSPs) maintain a 24x7 “911 Resolution Team.” While the commission didn’t “explicitly request comment on the creation of dedicated 911 resolution teams in the Notice, a number of commenters have noted the potential benefits of such an arrangement,” the group said. “NENA agrees that such teams would be incredibly beneficial: As many commenters noted, 911 systems are comparatively unusual in topology and operation. Consequently, many in the 911 community have experienced occasions when carrier or SSP personnel are unfamiliar with the provisioning, maintenance, and operational minutiae of 911 systems."
New York City disagreed with AT&T’s reading of the derecho report. “Voluntary compliance with industry best practices regarding critical 911 call delivery infrastructure systems has proven inadequate, as was illustrated in the Derecho report, and 911 service providers do not currently have sufficient incentive to fully comply with best practices recommendations,” the city said (http://bit.ly/15jkKEm).