XVII.On June 29, 2012, a fast-moving derecho storm brought a wave of destruction across wide swaths of the United States, beginning in the Midwest and continuing through the Appalachians and Mid-Atlantic states until the early morning of June 30. The derecho resulted in twenty-two deaths and widespread property damage, and left millions of residents without electrical power for as long as two weeks.21
XVIII.While the destruction caused by the derecho resembled that of other major storms in some respects, it also proved different in others. For example, the landfall of a hurricane is typically predicted days in advance, allowing first responders and communications providers time to prepare. The derecho, however, moved rapidly across multiple states with very little warning. The derecho thus put critical infrastructure to an unexpected test and revealed significant vulnerabilities in service providers’ networks and operations.
XIX.The derecho caused particularly widespread disruptions to 911 services.22 From isolated breakdowns in Ohio, New Jersey, Maryland, and Indiana, to systemic failures in northern Virginia and West Virginia, a significant number of 911 systems and services were partially or completely down for as long as several days. Across the storm’s path, at least seventy-seven PSAPs serving more than 3.6 million people in six states lost some degree of network connectivity, including vital information on the location of 911 callers.23 At least seventeen 911 call centers in three states lost service completely, affecting the ability of more than two million residents to reach 911.24 Nearly 9 percent of all PSAPs in the six affected states experienced some loss of service, affecting more than 8 percent of those states’ total residents.
XX.The effects were particularly severe in northern Virginia, where four PSAPs in the densely-populated National Capital Region lost service completely, and in West Virginia, where eleven PSAPs could not receive 911 calls for as long as twelve hours.25 Fairfax County, Virginia, for example, notes that the disruption of 911 service it experienced after the derecho “was the longest and most severe 911 outage since Fairfax County implemented Enhanced 911 in 1988,” leaving 1.1 million county residents without access to 911 for seven hours and preventing nearly 1,900 911 calls from reaching the Fairfax County PSAP.26 Other affected PSAPs lost ALI links or had to reroute calls to other jurisdictions.
A.PSHSB Derecho Report
XXI.Immediately after communications and 911 services were restored, the Bureau began a comprehensive inquiry to determine why each outage occurred and how such problems could be prevented in the future. The Bureau analyzed more than 500 confidential NORS reports containing information on the cause, duration, and resolution of each outage, as well as numerous DIRS reports from the areas hit hardest by the derecho. Bureau staff also interviewed representatives of eight communications providers, twenty-eight PSAPs, three battery manufacturers, one generator manufacturer, and numerous state and county entities. In addition, the Bureau participated in several federal, state, and local meetings and hearings on the effects of the derecho.27 These interactions clarified and expanded the information the Commission had already received via NORS and DIRS.
XXII.On July 18, 2012, the Bureau released a Public Notice seeking comment on issues surrounding the derecho, including the cause of the outages, their effect on public safety, and the resiliency and reliability of 911 networks generally.28 This Public Notice focused on actions to ensure dependable 911 service, both now and in an NG911 environment. In response to the Public Notice, the Bureau received several dozen comments and reply comments from parties representing a diverse range of interests, including local governments concerned about a pattern of 911 outages29 and communications providers calling for new voluntary best practices to address problems experienced during the derecho.30
XXIII.In its January 2013 Derecho Report, the Bureau announced the results of its inquiry and provided specific recommendations for Commission action to improve the reliability and resiliency of 911 networks nationwide. The Bureau found that many communications outages during the derecho, including 911 outages, could have been prevented through implementation of best practices developed by entities such as CSRIC and the Alliance for Telecommunications Industry Solutions (ATIS) Network Reliability Steering Committee (NRSC).31 The Bureau found that, above and beyond any physical destruction by the derecho, 911 communications were disrupted in large part because of avoidable planning and system failures, including inadequate physical diversity of critical 911 circuits and a lack of functional backup power in central offices.32 Links and aggregation points supplying telemetry data to network operations centers (NOCs) also failed, depriving communications providers of visibility into critical network functions.33 Among other things, the Bureau recommended that the Commission take action to ensure that 911 service providers (1) routinely audit critical 911 circuits for physical diversity, (2) maintain adequate central-office backup power, (3) deploy physically diverse network monitoring links, and (4) provide PSAPs with timely and actionable notification of communications outages.34
A.911 Reliability Notice of Proposed Rulemaking
XXIV.On March 20, 2013, the Commission adopted a Notice of Proposed Rulemaking (911 Reliability NPRM or NPRM) outlining options to implement recommendations from the Derecho Report.35 These options ranged from reporting and certification obligations, to mandatory reliability requirements supported by site inspections and compliance reviews. The NPRM noted that the implementation options need not be mutually exclusive and sought comment “on whether each of these approaches can stand alone, or whether the Commission should adopt two or more options as part of an integrated approach.”36 The NPRM also proposed to amend the Commission’s rules to require 911 service providers, and other communications providers subject to the existing rule, to notify PSAPs of communications outages “immediately,” with specific information about the nature of the outage and area affected.37 In response to the NPRM, we received twenty-nine comments and nine replies representing a broad range of communications providers, trade associations, PSAPs, and public safety organizations.38
Share with your friends: |