On July 12, 2017, the Public Safety and Homeland Security Bureau (“Bureau”) of the Federal Communications Commission (“FCC”) issued a Public Notice encouraging communications service providers to implement certain “best practices” to avoid major service disruptions.  The Bureau’s recommendations come on the heels of recent major service outages caused by minor changes to service providers’ network management systems that knocked out 911 service.  These service disruptions are known as “sunny day” outages because they are not caused by weather-related issues or other disasters, but rather internal network management failures due to faulty software or botched upgrades.  The Bureau’s recommendations serve as a warning to service providers, but do not (at this time at least) have an enforceable effect on providers.

Continue Reading FCC (Again) Takes to Bully Pulpit to Urge Network Reliability “Best Practices” to Combat Service Outages

911-emergency-service-777x437  On May 18, 2017, at the Federal Communication Commission’s (“FCC” or “Commission”) May Open Meeting, the Public Safety and Homeland Security Bureau (“Bureau”) presented its final report on its investigation into the VoLTE 911 outage experienced by AT&T Mobility (“AT&T”) on March 8, 2017 (“the Report”).  The Bureau offered a strong critique of AT&T, concluding that the outage could have been avoided had AT&T adopted network reliability best practices previously recommended by an FCC advisory committee.  Despite the criticism, however, neither the Bureau nor the Commissioners made any mention of possible enforcement action against AT&T for the outage — at least not at this time.

Continue Reading FCC Takes No Enforcement Action Despite Report Finding that Avoidable Failures Led to AT&T Mobility 911 Outage

World Global ConnectionsAs Kelley Drye reported in an earlier post, the Federal Communications Commission (FCC) is considering rules that would impose on submarine cable system licensees, and possibly users, network outage reporting obligations similar to those already applicable to other communications providers.  The FCC’s Notice of Proposed Rulemaking (NPRM) solicits comments on a number

As it did when it imposed circuit capacity reporting obligations on all submarine cable licensees earlier this year, the Federal Communications Commission (FCC) once again is looking to step up regulation of submarine cable systems. Citing the critical nature of submarine cable infrastructure and the importance of submarine cable systems to meet U.S. communications requirements, the FCC announced Thursday a proposal to require submarine cable system licensees to report cable network outages. The Notice of Proposed Rulemaking (NPRM), supported by the entire Commission, seeks comment on whether to bring submarine cable licensees into the reporting framework already applicable to many other communications providers, including satellite, cable, wireless and interconnected VoIP providers, among others. These providers are subject today to a complex network outage reporting regime encompassing consideration of factors such as the facilities impacted, the duration of the outage, and the number and type of minutes affected. Moreover the current network outage reporting rules require the submission of multiple reports with time-sensitive deadlines, some as short as 30 minutes where emergency communications are affected.

Continue Reading FCC Wants to Impose Network Outage Reporting Requirements on Submarine Cable System Licensees