Industry Disagrees With FCC Network Resiliency Proposals

Satellite, wireline, wireless and broadcast industry groups almost uniformly opposed FCC proposals for stricter network resiliency requirements, in comments posted in docket 21-346 through Friday. Providers work voluntarily to share information and preserve their networks, so the FCC should “avoid unnecessary and burdensome additional regulation” said NTCA, similar to NAB, USTelecom and others. The FCC “shouldn’t take an overly prescriptive approach to unpredictable and highly variable events,” said the Competitive Carriers Association.

FCC proposals to require entities to send information to the currently voluntary disaster information reporting system were rejected by broadcasters and cable groups. “Smaller providers face barriers that can limit their ability to participate," said ACA Connects. “Mandating DIRS filings would force stations to redirect their already-strained staff away from trying to maintain or restore service to fill out a government form,” said NAB. AT&T backs a proposal to waive network outage reporting system rules for DIRS participants when DIRS has been activated.

Satellite providers such as Iridium said voluntary DIRS requirements shouldn’t apply to infrastructure that isn’t likely to lose connectivity during disasters. “Require reporting only with respect to transmitting earth stations used to support the DBS system,” said DirecTV. It “could never gather such information regarding receive-only dishes used by its customers and over which it has no control,” said DirecTV. Other satellite entities said the agency should provide more clarity. “Several of the FCC’s proposals need additional detail so that commenters have adequate notice to provide meaningful comments as required by the Administrative Procedure Act,” said the Satellite Industry Association. Issue a Further NPRM on integrating satellite resiliency into broadband funding programs, asked SES Americom and O3B.

Commenters in a variety of industries opposed FCC proposals for backup power requirements, arguing the onus should be on the electric utilities. “It is not realistic to think that wireline broadband providers and all of their customers can duplicate the existing power grid” for weeks “without access to commercial power,” said NCTA. “Refrain from mandating backup power generators at every cell site,” because of safety and legal concerns, said the Wireless Infrastructure Association. The Edison Electric Institute said the FCC should review recommendations from the Broadband Deployment Advisory Committee on maintaining sufficient backup power for network continuity. The FCC “should examine whether its pole attachment policies discourage hardening of communications networks to avoid single points of failure,” said EEI. “There is no reason for specific backup power requirements or for other Commission mandates that dictate how service providers build reliable networks and restore service,” said ATIS.

Any new backup power rules “should give deference to providers’ engineering judgments and support timely deployment of new infrastructure,” said Verizon. “Consider holistic approaches that include extended back-up power as well as other capabilities,” said the Utilities Technology Council. Most wireless outages after disasters are “due to failures in electric utility and backhaul networks rather than problems with Wireless Network infrastructure,” said T-Mobile.

Mandating participation in DIRS and the wireless network resiliency framework is how the FCC can ensure industry is working to keep networks disaster-resistant, said APCO. “Network resiliency will not happen on its own,” said Public Knowledge. Carriers have “significant financial incentives to minimize” investment in network resiliency, PK said. The FCC “must do more to solicit input from frontline workers regarding service restoration efforts and develop mechanisms that hold Framework Signatories accountable,” Communications Workers of America said.

Groups representing the deaf and hard of hearing want the FCC to require emergency alerts to appear across all broadband devices “regardless of whether they connect to a wireless network” and that emergency alerts reach all phones, even if they don’t have an active plan. The FCC should act “to ensure accessibility during and prior to electrical grid failures by ensuring continued accessibility of wireline real-time text," said groups including Telecommunications for the Deaf and Hard of Hearing and the National Association of the Deaf.