Industry Opposes New FCC Disaster Reporting Requirements

The record shows separate outage reporting requirements for wireless carriers aren’t needed, CTIA said. Reporting on the availability and location of mobile recovery assets through the disaster information reporting system risks providing “outdated information to state and local emergency responders making real-time decisions and would paint a misleading picture that ignores the variety of solutions that providers use to maintain service after a disaster,” the wireless group said.

Any new requirements should be aligned with the reporting obligations already imposed under the mandatory disaster response initiative (MDRI) rules, CTIA said: “Providers are deploying permanent network infrastructure and providing overlapping cell site coverage that enhance resiliency.” CTIA discussed in more detail the work of its largest members to harden their networks.

No one backing the FCC’s proposed additional information collection obligations on broadcasters has made a case for what public authorities would do with the additional information, or how it would benefit the public or broadcasters, NAB said. "Emergency responders simply have too many critical demands on their limited resources during a disaster to help a broadcaster restore service,” it said. NAB said it knows of no instance in which a DIRS filing resulted in government action that helped a radio or TV station obtain fuel or repair a transmitter.

Similarly, the record demonstrates expanding mandatory DIRS reporting to satellite networks “would impose unnecessary burdens on them without any clear public interest benefit,” the Satellite Industry Association said. No organization advocating extending mandatory DIRS reporting to satellite explains how that “would provide real public interest benefits,” SIA said. If the agency opts to require satellite to fill DIRS, such reporting should be “a simple, binary ‘available/unavailable’ report,” it said: The inherent resiliency of satellite networks means they are presumptively available in an area subject to DIRS reporting. Any detailed reporting would “clutter DIRS with unhelpful information,” SIA added.

While no additional reporting requirements are necessary, NCTA said if the FCC takes that route, outage reporting obligations should apply only for “hard down” outages where service is out instead of degraded. Performance degradation metrics don’t necessarily correlate with service outages, it said, adding that the commission hasn’t proposed quantitative metrics for determining what constitutes a significant degradation. NCTA also urged against requiring providers subject to a DIRS obligation to submit an “after action” report about preparation work and its impact on the resiliency of the network during the DIRS event.

USTelecom also raised concerns about new requirements. Providers need “flexibility to manage their response during an ongoing disaster and reporting mandates should not distract from these efforts,” USTelecom said: “The record shows that requiring providers to submit reports about their efforts for every DIRS activation will impose significant costs and be very time consuming.” The FCC also already receives much of the information that would be reported, the group said.

The National Rural Electric Cooperative Association (NRECA) agreed with comments that the FCC shouldn’t impose additional requirements on broadband providers, especially relatively small players like electric co-ops. “NRECA is very concerned that its members may face an additional regulatory burden at the worst possible time, during a disaster response,” the group said. As providers of essential electric power, co-ops “are well aware of the time constraints and resource issues associated with restoring service following disaster-related outages,” NRECA said.

Southern Linc said additional reporting requirements could duplicate what DIRS, the network outage reporting system, and the MDRI already mandate. “Any requirement to report information on the availability and location of mobile recovery assets during an emergency will neither result in any actionable information nor enhance situational awareness, but doing so does risk creating confusion that could impede emergency response and recovery efforts,” Southern Linc said.

“To the extent the Commission should decide to extend such reporting requirements to [broadband] providers, it should do so in a way that does not unduly burden smaller providers and allows sufficient time for them to come into compliance with these new obligations,” the Wireless ISP Association said.

DirecTV urged the FCC not to impose reporting requirements on direct broadcast satellite providers. “Those few commenters in favor of broader reporting requirements who even mentioned DBS simply swept it in with other satellite systems without acknowledging the salient differences presented by a one-way video programming service, much less providing a rationale for applying the rules in spite of those differences,” DirecTV said.