USTelecom on Passage of the Bipartisan Infrastructure Investment and Jobs Act Read more

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Author

Mike Saperstein

Streamlining Service Restoration
by Streamlining Reporting Obligations

When it comes to reacting to a service outage, minutes matter. So when solving problems ranging from tragic natural disasters to isolated service disruptions, administrative processes shouldn’t be the first thing on carriers’ minds. But service providers dealing with outages are required to jump through numerous administrative hoops while hustling to restore these critical services.

That’s why USTelecom has asked the Federal Communications Commission (FCC) to revisit some of these redundant requirements, take a serious look at their costs and benefits, and streamline the reporting obligations so providers can fulfill their commitments to restoring service as quickly as possible.

View our filings here: https://www.ustelecom.org/public-safety/

We have also reaffirmed with the FCC our industry’s commitment to meaningful coordination with various stakeholders outside their organization—like power companies and wireless providers—to improve wireless resiliency during emergencies.

Legacy Reporting Requirements

Legacy service outage reporting requirements, as they stand now, require a three-part submission process. This means during the first critical moments to restore service, companies—including very small providers with limited resources—must divert their resources from restoring service to filing paperwork, and often with little more to report than they knew before. We’d like to see this streamlined into a thorough two-part system that mirrors the reporting requirements for VoIP providers.

Similarly, we encourage the FCC to go from yearly to every three years for reporting required by the 911 Reliability Order. The information gathered in the massive audit responding to that Order does not change substantially on a year-to-year basis—the work is largely done. Basically: same information, fewer reports.

Coordination on Backhaul Resiliency

Many of our members are in the business of providing backhaul service to wireless providers—or are wireless providers—so we know coordination is key for maintaining and restoring service during an outage or disaster. Lockstep coordination between the backhaul provider, wireless providers, and other stakeholders (like power companies) is standard practice for our industry.

The Commission should be careful not to impose duplicative processes intended to promote coordination (that is already occurring), but would only divert scarce resources from restoration efforts during disasters.

Action over Reporting Redundancy

We are 100% on board with the Commission’s constant evaluation of ways to improve network resiliency. But the FCC should favor the Executive Branch’s effort for regulatory efficiency over redundant filing requirements, and seize the moment to ease these burdens. For many small providers especially, some administrative procedures do more harm than good.

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