Recognizing that the outages affected the ability of Public Safety Answering Points (PSAPs) to receive emergency 911 calls from several sources, and that the outages occurred on the networks of providers serving the PSAPs directly, the FCC is contemplating limiting the application of reliability proposals to the class of entities acting as "911 service providers." ACA agrees with this approach.
ACA set forth its views in May 13 comments filed in connection with the FCC's Improving 911 Reliability Notice of Proposed Rulemaking (NPRM), which stems from findings and recommendations in the Derecho Report prepared by the agency's Public Safety and Homeland Security Bureau in response to the storm hammered the mid-Atlantic and Midwest regions.
911 service is available to all customers of ACA members offering voice service, but only a few of these providers are also direct service providers to a PSAP. For that reason, ACA members depend on the reliability of 911 service providers to make sure their customers' 911 calls are delivered to the local PSAP. It is failures by these 911 service providers that have the greatest impact on 911 system reliability and have the potential to cause the most widespread harm.
Based on the Derecho Report's findings that other voice providers failed to provide timely and complete information about their reportable outages to 911 service providers, ACA understands the importance of ensuring PSAPs have accurate situational awareness when service outages affect public safety.
ACA member companies who provide voice services take their responsibility seriously to notify PSAPs of their significant outages as required by existing rules. This means that in addition to allocating time and resources to ensuring that their customers regain connectivity and access to 911 systems by addressing the source of the outage as quickly as possible, ACA Members make sure that PSAPs are aware of their outages and often provide all available supplemental information. In fact, the FCC's Derecho Report did not suggest that the failure of service providers generally to notify PSAPs of outages was a problem, but rather that the problem was provision of untimely or incomplete information by certain 911 service providers.
ACA members do not oppose the FCC providing greater clarity on when service providers must provide notice to the PSAP, and providing additional guidance on the categories of information that should be provided to the PSAP regarding an outage. However, the FCC should adopt a reasonable standard regarding the scope of the information that needs to be provided. This would avoid the situation in which a network service provider would have to significantly delay the restoration of service to their customers as a result of trying to satisfy rules for reporting the outage to a PSAP.
By adopting a practical set of PSAP notification requirements, the FCC can ensure that PSAPs are adequately notified with relevant information, but also that that service is restored to customers as quickly as possible - an equally important outcome.
ACA proposes that the network outage reporting requirements make clear that service providers would be required to provide to PSAPs only the information outlined in the NPRM that they would have obtained in the normal course of assessing the cause of an outage and restoring service, and recognize that the information that would be provided may be an estimate or approximation based on the service provider's best knowledge at the time.
In addition, the FCC should clarify that providers would not be expected to give any more information via electronic means than they provided to the PSAP via telephone when reporting that the provider is experiencing a reportable outage on its network.
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