Industry Groups Support CCA's Proposed Changes to 911 Notification Rules

CCA is right that “strict application” of the order’s 30-minute deadline to notify all potentially affected public safety answering points of outages “would trigger reporting of less meaningful and actionable information than would be available under a more flexible application of the deadline,” CTIA posted Thursday in docket 15-80. CTIA said public safety groups opposing the petition don’t address “practical concerns.”

CTIA also agreed the FCC should develop a centralized PSAP contact database for originating service providers to use for outage notifications. Such a database would be “a more efficient and effective means of enhancing collaboration and information sharing among OSPs and PSAPs” while a “provider-by-provider based approach … would impose unnecessary resource burdens on PSAPs and OSPs alike,” the group said.

Neither APCO nor BRETSA refuted the argument that reporting burdens are “especially weighty for small and rural carriers,” CCA said. Even if the FCC sticks with the 30-minute deadline, “reasonable flexibility is appropriate, such as starting the clock for OSPs at the time of notification from underlying service providers and deeming OSPs compliant when they have initiated notifications within the 30-minute window and are undertaking best efforts to notify remaining PSAPs,” CCA said.

“The notification deadline is particularly troubling for small and rural carriers who frequently have small workforces and remote and diverse geographic territory,” NTCA cautioned: “Small providers are also typically situated in the communities they serve. When a natural disaster causing an outage occurs, the staff may be sheltering in place or addressing losses more generally.” The deadline could be difficult for larger providers as well, the group said: As CCA notes in its petition, “both Lumen and AT&T found that updating PSAP contact information is very time consuming even without considering the outreach and follow-up processes,” NTCA said.

USTelecom said the FCC should grant the petition. “The concerns raised in the Petition are industry-wide and will affect service providers of all sizes,” the group said. Allowing more flexibility would benefit PSAPs as well as providers, USTelecom said: “In order for notifications to all PSAPs to be completed within 30 minutes, and especially if notification must be by both telephone and in writing by electronic means, the notifications will likely need to be initiated immediately upon discovery of the outage, well before the OSP has any actionable information to provide.” Call centers may receive “irrelevant or unusable information -- which will not improve situational awareness or enable them to take action -- simply because providers have no choice but to send notification, no matter how meaningless, by the required deadline,” USTelecom warned.

Southern Linc said it reviewed the 911 outage notifications it provided PSAPs last year and found the average amount of time that elapsed from when the outage was discovered by a third party to when the carrier was notified was 50 minutes and 40 seconds. “In each of these cases, once Southern Linc became aware of these outages it immediately commenced notifying affected PSAPS; however, it plainly would have been impossible to do so within the timeframe set” in the order, the provider said. The FCC “apparently views this timing issue as simply a contractual one with third-party 911 and transport service providers,” but Southern Linc said it agrees with CCA that the commission’s expectation that carriers can address these responsibilities under these contracts “is not grounded in the reality of these relationships.”

The FCC’s order doesn’t specifically address the problems faced by smaller carriers, said the Blooston Group of small and rural carriers. “Providers may serve fewer 911 special facilities than larger carriers, but they lack the resources to develop and maintain databases when PSAP personnel and contact information may change,” the law firm said: “CCA correctly observes that rushing a notification out with incomplete or inaccurate information to comply with an arbitrary 30 minute deadline may be counterproductive, and lead to PSAP confusion and delay.”

Cable groups also support CCA. “CCA establishes in its Petition that the Commission did not adequately address the significant concerns raised in the record regarding the practicality and ability of OSPs to determine and accurately report that a 911 outage has occurred within the 30-minute timeframe,” said NCTA. Requiring OSPs “to meet a strict 30-minute notification deadline regardless of the circumstances on the ground is a recipe for half-baked notifications containing information that may be incomplete, or even inaccurate and potentially misleading,” said ACA Connects: “In some cases, meeting the 30-minute deadline may be virtually impossible, especially for a smaller provider.”