The American Cable Association, which represents small and medium operators, filed comments with the FCC saying that new outage reporting requirements adopted by the Commission should be based on “appropriate thresholds and unambiguous metrics that provide the FCC with relevant information about significant outages while minimizing burdens on smaller providers.”
The crux of ACA’s concern with the FCC’s proposal is that it could require outage reporting not only for a complete loss of service, but also with performance degradation. That would be a particular burden for smaller broadband and VoIP providers, the association says.
Why? ACA points out it’s because it asks them to monitor and report information that they currently do not have the means to do, and would require them to buy monitoring equipment in all of their customers’ homes.
ACA’s comments were made in reference to the FCC’s further notice of proposed rulemaking (FNPRM), which is looking at expanding the FCC’s Part 4 outage reporting requirements.
“The change is intended to reflect the increasingly important role the FCC views broadband networks and IP-based services playing with respect to the nation’s 911 and Next Generation (NG) 911 emergency communications, which in turn support the nation’s emergency preparedness, management of crises, and essential public safety-related communications” ACA notes in a statement. “Although ACA agrees on the important role of broadband, it reminded the FCC that its statutory authority with respect to network outage reporting is limited and that it must therefore be circumspect as to the scope of any new reporting obligations.”
ACA President and CEO Matthew M. Polka states that the FCC should not adopt the proposed outage reporting metrics because they will not result in consumer benefits, and aren’t targeted to identify significant wide-scale outages that prevent consumers from accessing emergency services. They’d “impose significant burdens on providers, particularly smaller providers,” Polka says.
He further suggests the Commission should limit its collections to “targeted and useful information” concerning complete loss of broadband consumer connectivity to the internet or complete loss of interconnected VoIP service.
“This would still provide the FCC with the information it seeks to assist it in the development, after the fact, of best practices and reduce reporting burdens to the minimum necessary to allow it to achieve situation awareness of significant outages that impede consumer access to 911 and E911 emergency services in a timely manner,” he says.
Polka is urging the FCC to continue the course it set in 2012 and recommends that “to avoid undue burdens on operators, any new mandatory outage reporting requirements be narrowly tailored in scope, simple and unambiguous in application, and based on information providers collect in the ordinary course of business.”
He thinks there hasn’t been any change in the last five years to make the requirements under consideration less burdensome or less costly for smaller providers.
Filed Under: Industry regulations
