Carriers, Public Safety Weigh In on 9-1-1 Outage Notification Requirements
Tuesday, August 03, 2021 | Comments
Wireless carriers and public-safety organizations weighed in on the FCC’s proposal for changing its rules governing notification of disruptions to 9-1-1 service to public-safety answering points (PSAPs).

In April, the FCC released a third notice of proposed rulemaking (NPRM) proposing changes to its notification requirements. Those changes included harmonizing PSAP outage notifications, mandating the delivery of specific information, requiring carriers to notify consumers of 9-1-1 outages and establishing a timeframe for notification of PSAPs.

Telecommunications service providers and the organizations representing them said that they support the FCC’s goal of improving outage notifications to PSAPs but expressed concerns about several of the proposed rules including the timeframe for providing notice of an outage to PSAPs and a requirement to notify customers of 9-1-1 outages.

“The NPRM’s proposed changes to the PSAP notification requirements, subject to some targeted modifications to mitigate the risk of PSAP confusion and fatigue, will further the commission’s overarching tradition of improving public safety by promoting situational awareness,” Verizon said in its filing. Meanwhile, public-safety organizations said the proposed timeframe might be too long and also addressed the FCC’s proposed notification thresholds.

The Association of Public-Safety Communications Officials (APCO) International said the FCC should amend its thresholds for triggering an outage report to emergency communications centers (ECCs).

“From the perspective of an ECC, the most important question when determining whether an outage notification should be made is whether the ECC would take steps to mitigate the outage’s impact,” APCO’s filing said. “Basing the thresholds on the potential user minutes impacted does not directly align with public-safety considerations. Further, as APCO has suggested, user minutes may not adequately represent the number of people affected, particularly during special events and tourist seasons that attract large crowds to areas that are otherwise sparsely populated.”

APCO said that the commission’s new reporting thresholds should be based on factors that are relevant to ECCs including anticipated time to restore service, nature of the impact and the number of people and size of the area affected.

“For example, an ECC might find that an outage impacting a small area such as a city block warrants notification but only if the anticipated time to restore service is significant,” APCO’s filing said. “In contrast, an ECC may find that even a very brief outage warrants notification if it impacts a large area.”

APCO said that a detailed analysis of outages from service providers would help the commission establish thresholds that better serve public safety.

“Understanding how many outages are going unreported, at what point in the course of an outage a service provider typically understands the scope and restoration time, and how accurately service providers estimate scope and restoration time is essential for establishing more effective reporting thresholds,” APCO”s filing said. “The service providers should share this information, so the 9-1-1 community can make a more informed recommendation to the commission about how to revise the reporting thresholds.”

The association said it is important that the FCC base the thresholds on the benefit to public safety and service providers’ preferences.

“The thresholds should err on the side of notification rather than silence because among other reasons, the initial information about an outage may underestimate its severity,” APCO said in its filing.

Maryland State Senator Cheryl Kagan, who chairs the Metropolitan Washington Council of Governments (COG) 9-1-1 Committee, in comments filed on behalf of the committee, recommended that service providers be required to notify an ECC of an outage when:
• At least 50% of a population within a ZIP code is without service;
• 50% service disruption of landline service within a ZIO code occurs;
• 50% of text to 9-1-1 service is disrupted within a ZIP code; or
• ESInet service is disrupted.

“With the introduction of next-generation 9-1-1 services, the call-handling process has become increasingly complex,” Kagan wrote in her filing. “The process for delivering a call will include multiple providers with multiple links; there is no longer a single provider. Coordination of services to an ECC is more important now than ever, because if any part of the delivery (electric, telephony, call handling, internet) is disrupted, the 9-1-1 call is also disrupted.”

As for an acceptable time for notification following discovery of an outage, APCO said that the FCC should require it as soon as possible but no later than 15 minutes from discovery instead of the commission’s proposed 30 minutes. Additionally, APCO said notifications should be made by telephone and in writing via electronic means, even if providers make information available directly to ECC’s mapping systems.

Sen. Kagan said in her comments that the proposed 30 minute notification timeframe is too long. The COG 9-1-1 committee recommended reducing the notification timeframe to 15 minutes.

The National Emergency Number Association (NENA) did not specify a specific notification time in its comments but said that the timelier the notification, the more useful it is for public safety.

“Prompt notice of an ongoing outage allows PSAPs and 9-1-1 systems to mitigate impacts of the outage or alert the public to alternative means of connecting to 9-1-1; conversely a notification’s utility to 9-1-1 diminishes significantly as time passes,” NENA’s filing said.

T-Mobile said that original service providers should be given more than 30 minutes to send out notifications.

“The commission has recognized that the two-hour filing window for filing initial NORS (Network Outage Reporting System) notifications by OSPs ‘sets an appropriate balance between the commission’s need to be timely apprised of critical outages and the needs of providers to deploy scarce resources effectively when these outages occur,” the carrier wrote. “Adopting a rule that would require OSPs to notify PSAPs of outages within 30 minutes would be inconsistent with this observation and prior commission rule changes designed to eliminate expedited outage notification requirements so that carriers could concentrate on recovery efforts.”

The Competitive Carriers Association (CCA) said that the notification timing rules as they are proposed would disproportionately affect smaller and rural carriers.

“Small and rural carriers often must contend with smaller workforces, limited internal capabilities, and remote and diverse geographical territory,” the CCA said in its filing. “These resources will already be strained in responding to a network outage, and adding particularly fast notification requirements could further tax their personnel.”

The Alliance for Telecommunications Industry Solutions (ATIS) Network Reliance Steering Committee (NRSC) said it opposed the 30 minute time frame.

“In this very short window of time, providers likely will not know the root cause, the outage’s extent or be able to estimate when service would be restored,” ATIS said in its filing. “Instead, ATIS NRSC believes that originating service providers should continue to be required to notify public-safety answering points (PSAPs) of outages within their network as soon as possible.”

If the FCC moves forward with a timeframe, that deadline should be based on when the service provider confirms the outage, ATIS said.

Verizon agreed with ATIS and said that the deadline for notification should not be a rigid deadline.

“The timing of notifications should reflect a safe harbor time period, not an inflexible deadline that applies irrespective of the scope and cause of the outage,” the carrier said in its filing.

T-Mobile also said that while it recognizes the importance of 9-1-1 service and supports rule changes, the proposal should be modified to ensure that they do not create unintended burdens or cause confusion and that any new notification requirements protect the confidentiality of outage data.

“The commission’s proposal to require OSPs (original service providers) to notify PSAPs whenever there is a network outage, including for the first time, commercial outages, should be carefully considered to ensure that the requirement achieves the desired objective — providing PSAPs with actionable information — without flooding PSAPs with unhelpful notifications.”

T-Mobile said that it is not opposed to the FCC expanding its requirements but wants to ensure that any expansion provides actionable information and does not fatigue PSAPs with too many notifications.

“The purpose of the PSAP notification requirement is to provide PSAPs with actionable information and minimize the potential for notification fatigue,” T-Mobile’s filing said. “When there is a 9-1-1 outage, this requirement makes sense because PSAPs can mitigate the impact of the outage by requesting that 9-1-1 calls be routed to administrative lines or otherwise bypass components dedicated to 9-1-1 services. When there is a commercial outage, however, there is nothing an individual PSAP can do to minimize the impact of the outage on wireless callers.”

Additionally, requiring notification when there are commercial wireless network disruptions would greatly increase the volume of notifications received by PSAPs, T-Mobile argued.

“In that case, the majority of PSAP notifications would involve commercial outages and therefore would not provide information that could be used by PSAPs to mitigate the impact of the outage,” the filing said. “This result may cause PSAPs to suffer from notification fatigue. If the proposed rules produce such results, the requirement will reduce the effectiveness of PSAP notification despite the best of intentions.”

T-Mobile, Verizon, UStelecom — the Broadband Association and the ATIS all said the FCC should remove requirements for carriers providing notice to the public.

“With respect to notification to the public, USTelecom believes, as a general matter, that this is best handled by PSAPs or local or state government agencies, not service providers, particularly given that multiple providers may be involved in a single outage and multiple separate provider notifications may be inconsistent and cause confusion,” the organization’s filing said.

Verizon argued that the requirements for notifying the public depart from previous FCC policies where the commission has worked with service providers to inform the public about outages without the disclosure of sensitive information.

“But the proposed rules unnecessarily depart from these established policies,” Verizon said in its filing. “The burdens and risks outweigh the benefits of these disclosures, which could confuse consumers about service availability and the ability to connect to 9-1-1.”

CTIA also expressed concern that the some of the FCC’s proposals would not support the FCC’s objectives to improve 9-1-1 reliability.

“Specifically, many proposals contained in the third NPRM are broad and open-ended and could run counter to the commission’s objectives if not implemented in a way that reflects the technical availability of wireless networks and the importance of relevant and actionable notifications of service disruptions,” the organization said in its filing.

The CTIA argued that some of the proposals would require carriers to provide outage notifications that are different from those required by state law or regulations, which could require service providers to send multiple notifications at different times and with different information, which could potentially lead to confusion about the outage.

The organization also expressed concern about carriers providing 9-1-1 outage notifications directly to consumers.

“For instance, given the nature of mobile wireless services, two consumers in close proximity could foreseeably receive conflicting messages about the availability of 9-1-1 services,” CTIA said in its filing. “Consumers may also receive information from other sources like local media or a local government that does not precisely match the service provider’s postings. Moreover, precisely describing areas impacted by service disruptions could pose implementation challenges for wireless providers, and could contribute to consumer confusion, especially if multiple providers offer different descriptions of impacted areas, either because the impacted areas actually differ or because the providers inadvertently use different language in describing the impacted area.”

AT&T Services agreed with the other carriers and associations and said that public safety entities are better equipped to provide information on outages to consumers.

“Additionally, we are supportive of efforts to increase public awareness of network outages that temporarily disrupt 9-1-1 services,” AT&T said in its filing. “AT&T already makes outage information available to customers on its website and through text messages, and it will continue to share this important information with our customers. However, public-safety entities have the tools to push outage information out to their communities. Those tools are more effective at quickly alerting their communities of an outage than service providers posting outage information on their websites.”

The Voice on the Net (VON) Coalition argued that the notification requirements should not be placed on voice over IP providers.

“These proposed rules assume that all originating service providers have knowledge of service outages that affect 9-1-1 and sufficient insight into the cause of the outage to be to identify its geographic scope, which PSAPs may be affected and how long the outage may last,” VON’s filing said. “… The practical reality is that most interconnected VoIP providers are one step removed from the 9-1-1 ecosystem and many are one step removed from the source of widespread service outages.”

CTIA also encouraged the FCC to develop a PSAP contact database that it said would help advance efforts “towards greater coordination, collaboration and information sharing among providers and PSAP representatives, including for outage reporting and coordination during emergencies and disasters.” However, CTIA said, the database should only be used on a voluntary basis.

AT&T said it supports the effort to create a contact database but said that all involved parties would benefit from the FCC hosting the database instead of having carriers host the database.

In its comments, NENA said it supports the development of a PSAP contact information database and noted that it manages a secure contact information database for every PSAP in the U.S. With sufficient funding, staffing and governance, that database could meet the requirements of a PSAP contact information database, the organization said. The database would also need to be made public safety grade, NENA added.

Find the full NPRM here.

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