Puerto Rico Hurricanes, Earthquakes Highlight Need for Telecom Network Resiliency

Claro General Counsel Francisco Silva plans to testify on the company's efforts to rebuild its network and restore service after Hurricanes Irma and Maria made landfall in 2017, the impact of the earthquakes, and continued steps to improve service availability in the event of other natural disasters, the company emailed. The company also hopes Friday's panel will address "the state of the Commonwealth's power grid, which bears a direct relationship to how quickly carriers are able to restore service," a spokesperson said.

Free Press wants those affected by disasters to inform regulatory policy, Senior Policy Counsel Carmen Scurato emailed. "The FCC's failure to provide a critical analysis of exactly what went wrong in Puerto Rico after the hurricane has only been compounded by its failure to engage with those most impacted," she said.

“Communications networks are a critical lifeline for people who need help in an emergency," Starks emailed us Thursday. He called it "unacceptable" that after recent natural disasters, "many Puerto Ricans found that connection to life-saving assistance simply was not available.” Many Puerto Rico residents "find themselves on the wrong side of the digital divide," and ending it could improve public safety and ensure access to educational, employment and other benefits. He has called nine witnesses for the hearing at the University of Puerto Rico in San Juan (see 2002200045). Elba Aponte Santos, president of the Asociacion de Maestros de Puerto Rico, was added late Thursday.

Witness Jaime Pla-Cortes, Puerto Rico Hospital Association president, plans to propose "a simple and yet sophisticated" system to provide communications for healthcare systems in emergencies, he emailed. He hopes the meeting "will serve as a way to better understand the communication pitfalls and problems affecting Puerto Rico Healthcare System."

"We hope the Commissioner can understand the need for ... improving the 9-1-1 system, demanding more accountability from our elected officials for public safety, and making sure all telecommunications companies continue to invest in Puerto Rico," emailed local Communications Workers of America 3010 member Luis Benitez-Burgos, also scheduled to attend. "We must ... also have good call center and network maintenance jobs, especially after the crucial role these workers have been playing in the recovery of Puerto Rico."

"The lessons learned from previous hurricanes and more recently the earthquakes in Puerto Rico should serve as a catalyst given its geographic location, vulnerability to natural disasters, and logistical burdens involving response and recovery," emailed another witness, Darrick Kouns, Information Technology Disaster Resource Center's chief of operations in Puerto Rico. "We hope that this hearing will help move Puerto Rico, and therefore the whole industry, forward in innovation and strengthening our communications infrastructure.”

Research and advocacy group Connected Nation's focus "is about connecting as many people as possible," spokesperson Jessica Denson said, and if FCC regulations to harden networks will help, "we're all for it." The group has done "boots-on-the-ground" research in Puerto Rico since the hurricanes, she said.

When considering network resiliency in Puerto Rico, remember military hospitals, veterans' hospitals, and organizations providing money or food to consumers after a natural disaster, said Tony Bardo, assistant vice president-government solutions at Hughes Network Systems, in an interview. "Resiliency needs to be better planned and budgeted for." After Hughes worked with FEMA to install satellite voice and broadband service in Puerto Rico after the 2017 hurricanes, the company trained the agency's staff on how to install and point the satellite dishes in case they needed them again in subsequent emergencies. Hughes offers solar-powered terminals for customers lacking their own backup generators when a storm knocks out the electricity, he said.

Satellite equipment is often used after natural disasters when fixed networks go down because it's relatively quick to install. But delivering the ground equipment to an island quickly can be challenging, said Hughes Senior Vice President-Regulatory Affairs Jennifer Manner. She said network redundancy is critical for public safety answering points that take 9-1-1 calls, and having a second terrestrial line might not be true path diversity if both are connected to the same downed network.

A USF program for Puerto Rico and the U.S. Virgin Islands approved last year is the first time the FCC asks about network resiliency and redundancy plans as part of its competitive application process, said Dangkhoa Nguyen, an attorney adviser for the FCC's Telecommunications Access Policy Division, Wednesday during an FCBA lunch. The bureau released a public notice on procedures for the program's competitive proposal process earlier this month. Price and performance are also competitive factors for the Uniendo a Puerto Rico Fund and Connect USVI Fund program, he said.

The Wireline Bureau will look for objective measurements of network resilience, such as whether buried fiber is used rather than an aerial cable, in considering competitive proposals for each area up for bid, Nguyen said. It will also use a sliding scale when applicants propose path diversity for their networks. Carriers with fixed fiber networks could propose satellite technology as a backup, he said.

Unlike other high-cost USF programs that focus on rural census blocks, funds for the Puerto Rico and U.S. Virgin Islands programs will be available throughout those territories, including in urban centers, so they can address network resiliency even if some overbuilding occurs in the process, Nguyen acknowledged.

Population Challenges

Population displacement in Puerto Rico could put in question the deployable location numbers for fixed voice and broadband service associated with the funds, some suggested. Deployment milestone requirements for fund participants will be based upon the most current census data available, which was updated in 2017 in Puerto Rico, Nguyen said: "The commission has a concern about the accuracy of the data we do have," so carriers will have an opportunity to challenge the counts at the one-year mark of their receiving USF support. If carriers can demonstrate a discrepancy to FCC standards, the agency will reduce that carrier's deployment requirements and adjust its funding support accordingly.

Puerto Rico Telephone Company repeated its concerns about the program framework requiring carriers to notify location discrepancies, in a filing posted Thursday in docket 18-143 (see 1909300048). "While the commission's recognition of the catastrophic destruction and dramatic population shifts was broadly relevant to Puerto Rico following the 2017 hurricanes, those realities have been further exacerbated due to the recent earthquakes," PRTC said. It argued the FCC's policy "implies there is a direct relationship between the costs to build and operate a broadband network and the precise number of locations. The commission recently reached the opposite conclusion" in a rulemaking for its upcoming Rural Digital Opportunity Fund, it said.

PRTC believes carriers in Puerto Rico will face more challenges in assessing location data than rural providers on the mainland would for multiple reasons, including an ongoing economic recession, an unprecedented population exodus after the hurricanes of 2017, and earthquakes that began in December "that will almost certainly generate additional fluctuations and disparity" in data. It said the July 2017 census data that the FCC is relying on for the Uniendo a Puerto Rico Fund was collected before the hurricanes hit that year.