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ACA To FCC: Base Any New Network Outage Reporting Requirements On Appropriate Thresholds And Unambiguous Metrics

Small Operators Say Relevant Information Can Be Gathered In More Cost-Efficient Manner

PITTSBURGH, August 29, 2016 -  The American Cable Association said new outage reporting requirements are not necessary but any adopted by the Federal Communications 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.

ACA's comments, filed Aug. 26, came in connection with the FCC's Further Notice of Proposed Rulemaking (FNPRM) seeking input on various proposals aimed at updating and 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. 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. In its comments, ACA focused on ways to improve on the FCC's proposed thresholds and metrics for new outage broadband outage reporting requirements.

ACA's primary concern with the FCC's proposal to require outage reporting not only for a complete loss of service, but also in cases of performance degradation is that such reporting would be significantly burdensome for smaller broadband and VoIP providers because it asks them to monitor and report information that they currently do not have the means to do, and to do so, would require them to purchase and deploy monitoring equipment in all of their customers' homes, which is a significant cost.

"The FCC should not adopt its proposed outage reporting metrics because they will not result in consumer benefits, are not targeted to identify significant wide-scale outages that prevent consumers from accessing emergency services, and would impose significant burdens on providers, particularly smaller providers," ACA President and CEO Matthew M. Polka said.

Polka continued, "Instead, the FCC 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."

In the comments, ACA said its members and other broadband providers take network reliability seriously and as such, there is no need for burdensome reporting requirements. As it did when this approach was first proposed by the FCC in 2011, ACA again urged the FCC to ensure that outage reporting are based solely on "hard down" outages and not on performance degradation; reporting thresholds and metrics are sufficiently high to target only significant outages and be simple, clear and unambiguous in application; and outage reporting obligations are confined to outages affecting the provider's own network.

In other respects, ACA said: 

  • The FCC should refrain from imposing outage reporting requirements on dedicated services;
  • The FCC should refrain from requiring cybersecurity-related outage information in reports; and
  • The FCC's rationale for its legal authority to require broadband outage reporting does not withstand scrutiny

"ACA urges the FCC to stay the wise 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.  From an operational and business perspective, nothing has changed in the past five years to make the requirements under consideration less burdensome or less costly, particularly for smaller providers," ACA's Polka said.

About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 750 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America.  Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business.  For more information, visit http://www.americancable.org/

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