Federal Communications Commission fcc 13-158 Before the Federal Communications Commission
Need for, and Objectives of, the Report and Order
Download 0.56 Mb.
|
- Navigate this page:
- A.Summary of Significant Issues Raised by Public Comments in Response to the IRFA
Need for, and Objectives of, the Report and Order.CLXXVIII.In this proceeding, the Commission adopts rules to improve the reliability and resiliency of 911 communications networks nationwide by ensuring that service providers (1) adhere to vital best practices or reasonable alternative measures to mitigate the risk failure and (2) provide public safety answering points (PSAPs) with timely and actionable notification of 911 outages. Specifically, we adopt rules requiring “Covered 911 Service Providers” to take reasonable measures in three key areas to ensure reliable 911 service and submit an annual certification of adherence to essential practices regarding (1) circuit diversity auditing, (2) backup power at central offices that directly serve PSAPs, and (3) diverse network monitoring. To allow flexibility and account for differences in network architecture, service providers may also certify that they have taken reasonable alternative measures to mitigate the risk of 911 service failure, so long as they briefly explain why such measures are reasonable under the circumstances and provide supporting documentation to the Commission upon request. In addition, we amend our outage reporting rules to clarify Covered 911 Service Providers’ obligations to provide PSAPs with timely and actionable notification of outages affecting 911 service. A.Summary of Significant Issues Raised by Public Comments in Response to the IRFACLXXIX.No comments were submitted specifically in response to the IRFA. A broad range of commenters agree with the goal of improving 911 reliability, although some expressed concerns about the anticipated cost of complying with any rules the Commission might adopt.1 For example, Alaska Communications Systems (ACS), Blooston Rural Carriers, NTCA - The Rural Broadband Association (NTCA), and the Western Telecommunications Alliance (WTA) comment that new regulations promoting best practices could negatively affect small government jurisdictions and small industry. ACS states that “it is not always possible to follow every industry best practice in remote areas such as the Alaska bush.”2 Blooston states that rural carriers already have limited personnel and numerous reporting requirements, and that implementing additional requirements would be overly burdensome.3 Moreover, Blooston states that “there is no indication in the Derecho Report that there are significant failures by rural ILECs,” and that any additional reporting requirements should be limited to carriers that experienced failures.4 WTA states that it “does not believe that there is a clear and established need for expanded new nationwide 911 service requirements and reporting rules for all service providers at this time,” and that the proposed requirements and procedures will be “unduly burdensome and expensive for RLECs and other small entities.”5 NTCA states that the Commission should “refrain from implementing new requirements for physical diversity upon small rural carriers” due to their size, limited control over interconnecting agreements, and the limited availability of diverse transport routes.6 NTCA adds that rural carriers should not be subject to additional backup power requirements.7 CLXXX.The IRFA solicited comment on the impact of the proposed rules to small businesses, as required by the RFA. The Commission sought comment on alternatives for rural carriers including: 1) the establishment of different compliance and reporting requirements; 2) clarification, consolidation, or simplification of compliance or reporting requirements for small entities; 3) the use of performance, rather than design, standards; and 4) an exemption from coverage of the rule, or any part thereof, for small entities. Regarding Blooston’s comment in which it objected to burdensome reporting requirements and proposed to limit additional requirements to those carriers which experienced failures in the June 2012 derecho, we conclude that reliability and resiliency of critical 911 communications infrastructure is a nationwide concern that is not limited to the service providers directly affected by the derecho. Rather, the record indicates vulnerabilities that likely exist nationwide and have not been resolved on a purely voluntary basis.8 In too many cases, the Commission has found that neither voluntary best practices nor other compensating steps (e.g. carriers following their own internal practices) were sufficiently implemented to safeguard the public’s access to 911 call centers on a nationwide basis. CLXXXI.Commenters uniformly agree that industry-led best practices, such as those developed by CSRIC, reflect the best available consensus on appropriate steps to ensure 911 network reliability and resiliency. CSRIC’s prioritization of many of these best practices as either “critical” or “highly important” to maintaining reliable communications further suggest that they are cost-effective and likely to achieve their objectives. To the extent that some commenters argue that such best practices may not be applicable in all cases and should therefore be purely voluntary, we note that the certification adopted here allows flexibility for Covered 911 Service Providers to implement specific best practices or reasonable alternative measures in the manner most appropriate for their networks. Regarding NTCA’s comment that the Commission refrain from imposing physical diversity requirements and backup power requirements on rural carriers, the rules adopted here allow Covered 911 Service Providers to certify reasonable alternative measures to mitigate the risk of failure where physical diversity and the specified level of backup power may not be feasible. Moreover, the backup power portion of the certification applies only to those central offices that directly serve a PSAP, or approximately one-quarter of all central offices. Service providers may also demonstrate that specific certification elements are not applicable based on their network architecture. Thus, the rules we adopt allow small and rural entities to comply with minimum cost and reporting burden so long as their efforts to provide reliable 911 service are reasonable under the circumstances.
Directory: edocs public -> attachmatch attachmatch -> Commissioner ajit pai attachmatch -> Before the Federal Communications Commission Washington, D attachmatch -> Before the Federal Communications Commission Washington, D attachmatch -> Before the Federal Communications Commission Washington, D attachmatch -> Before the Federal Communications Commission Washington, D attachmatch -> Before the Federal Communications Commission Washington, D attachmatch -> Federal Communications Commission fcc 15-77 Before the Federal Communications Commission attachmatch -> Statement of commissioner ajit pai Download 0.56 Mb. Share with your friends:
|