WASHINGTON -- Today, the Alliance for Telecommunications Industry Solutions (ATIS), on behalf of its Network Reliability Steering Committee (NRSC), submitted comments to the Federal Communications Commission (FCC) in response to the FCC's 2010 biennial review of regulations. ATIS recommends that the FCC modify the three-step outage reporting process mandated in Section 4.9 of FCC rules because current reporting obligations impose a significant burden on communications providers' resources without providing a corresponding public benefit. Specifically, ATIS does not believe that the 120-minute Notification obligation, as it currently is written, would necessarily provide immediately available information applicable to homeland security and public safety situations.
ATIS recommends that the FCC modify Section 4.9 to require that communications providers make initial Notifications of outages within 120 minutes only if those outages are related to vandalism or terrorism, impact special facilities (such as airports or 911/E911 facilities), or are related to Signaling System 7 (SS7) isolations. These events warrant immediate notification because of their potential impact on public safety and/or homeland security. For other outages, the NRSC believes that a different timeframe should be considered.
"ATIS and its NRSC appreciate the opportunity to comment on changes needed to streamline the FCC's outage reporting rules," said Susan Miller, ATIS' President and CEO. "Our goal is to ensure that the Commission's rules are not unnecessarily burdensome to the industry."
The NRSC recommendations come in response to FCC request for public comment as part of its 2010 biennial review of its regulations with particular focus on data collection requirements (Public Notice, FCC 10-204).
Federal Communications Commission (FCC)
Alliance for Telecommunications Industry Solutions (ATIS)