He added, "ACA's recommendations for clarifying the definition of 911 service provider will avoid the possibility of inadvertently sweeping in and burdening the average voice communications provider that does not provide direct service to PSAPs, some of which are small entities that may not have the resources to comply or could find it exceedingly onerous to do so."
ACA expressed its views in May 28 reply comments filed with the FCC in connection with the agency's Notice of Proposed Rulemaking (NPRM) on Improving 911 Reliability. This action stemmed from findings and recommendations of FCC staff contained in a report on the June 2012 Derecho storm that blasted the Mid-Atlantic and Midwest and resulted in the loss of some or all connectivity with 77 PSAPs serving more than 3.6 million people in six states.
In its comments, ACA also commented on the FCC's proposed PSAP outage notification requirements. ACA urged that the proposed rules should be clarified to better balance the need of PSAPs for useful information and the need for operators to concentrate their efforts on responding to outages and restoring service.
To this end, ACA suggested that the FCC specify that outage notification to the PSAP should contain only as much information as the service provider has obtained in the normal course of assessing the cause of an outage and restoring service, and that the FCC recognize that any category of the information required to be provided might be an estimate or approximation based on the service provider's best knowledge at the time.
ACA stressed that its primary concern was that any overly proscriptive rule would require providers to report to the PSAP information that, in some instances, they may not have when they are required to contact the PSAP, and that the provider would be required to collect information for the sole purpose of reporting it to the PSAP, an obligation that could come at the expense of rapidly restoring service to customers. Providers from large to small echoed this concern, including the Western Telecommunications Alliance (WTA), an association of smaller providers, and even Verizon.
Lastly, ACA noted that numerous commenters favored a flexible approach to the form and timing of PSAP outage notifications. ACA explained that although phone call outage notification to a PSAP is reasonable, an additional written electronic notification would be more burdensome. To alleviate some of this burden, ACA proposed that the FCC clarify that providers would not be expected to give any more information via electronic means than they provided to the PSAP via telephone when notifying the PSAP that the provider is experiencing a reportable network outage.
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