FCC Outage Reporting Requirements Said Complicated, Multilayered

Lumen falls under rules for voice LECs, for VoIP providers and for 911 covered service providers, among others, said Carolyn Brown, Lumen public policy director. “Overall, for my company there’s around 20 different FCC outage thresholds that apply to us,” she said.

T-Mobile doesn’t have as many areas to cover as Lumen, said Eric Hagerson, its director-public safety and security government affairs. The way carriers have to calculate potentially affected users “generally distorts the picture of the outage; it makes it seem larger or that it’s affecting more people than it actually is,” he said: “It’s not uncommon for carriers to know exactly how many customers were impacted.” T-Mobile asked to be able to report that number. “The FCC said, ‘No, you need to still report on [those] potentially affected,’” Hagerson said.

There has been “a general expansion” of the reporting requirements wireless carriers face, Hagerson said. The FCC looked at expanding outage reporting from voice to broadband, he said. “Now that we’ve moved into all packet-based networks for both voice and data I’m not sure whether that’s necessary or not,” he said.

Verizon has to deal with rules as a legacy provider in its traditional service area and as a wireless and VoIP provider nationwide, said Robert Morse, associate general counsel. The company faces significant challenges as a result of the 911 reporting rules, he said. For a large outage “we may need to notify hundreds or even thousands of PSAPs in a very short period and, under the rules, both by email and telephone,” he said. “We’re going to need to be communicating even more regularly with PSAPs, and when PSAPs aren’t responsive, probably with their overarching state 911 agencies as well,” he said.

Southern Linc is concerned about FCC requirements to report 911 outages within a 30-minute window, said Holly Henderson, its manager-public policy and strategic alliance. “We’re like the PSAPs are,” she said. “We’re getting the same outage notifications that they are with perhaps little information … at least in the initial round,” she said. Southern Linc also worries about over notification as a result of tight timelines, she said: “We operate in the Southeast in three states, and we’re getting notices from everywhere. … We don’t need to know what’s going on in Idaho.”

The FCC never classified interconnected VoIP as a telecom or an information service, said Pillsbury’s Glenn Richards, who represents the Voice on the Net Coalition. Instead, the FCC “has basically been applying rules on a case-by-case basis since 2005,” Richards said: “The world has evolved since 2005” and there’s now non-interconnected VoIP, one-way VoIP, fixed, nomadic and mobile, he said. In 2012, the FCC applied outage reporting requirements to VoIP and subsequent orders have included VoIP in any changes to the rules, he said.

There are complications for VoIP providers, which usually aren’t the broadband provider, when it comes to 911 outages, Richards said. The services are very disaggregated and provided over different modalities and equipment, he said. Most interconnected providers rely on third parties to offer 911 service, he said: “The great complication for VoIP providers is actually trying to figure out where the point of failure is.”

Outage reporting is critical to 911 call centers, said Renee Gordon, director of the PSAP in Alexandria, Virginia, and a member of the FirstNet Authority board. When there’s an outage affecting others in its region “we start to test -- we start to test our non-emergency calls, our emergency calls,” she said: “This is so important to the PSAP that we have some kind of notification.” PSAPs need outage information “immediately.”

The National Emergency Number Association has been fully engaged on rules for 988 outages and created a new standard for 911 and 988 interactions, which is out for public review, said April Heinze, NENA’s 911 & PSAP operations director. “The standard is focused on addressing both operational and technical issues that 911 and 988 … are facing today,” she said. The first version is expected to be finalized this summer, she said.