From: The National Law Review
Laura H. Phillips | Drinker Biddle & Reath LLP
As part of its unrealized effort to bring policy coherence to the migration of traditional switch-based telephone networks towards all IP-based architectures, the Federal Communications Commission (FCC) recently commenced a rulemaking aimed at improving accountability for the reliability of the 911 service “ecosystem” as network architectures continue to evolve.[1] Over the objections of Republican Commissioners Pai and O’Reilly, the FCC’s Democratic Chairman and Commissioners voted to adopt a Policy Statement and to propose a new federal framework with specific rule to address service failures that can lead to multi-state 911 service outages. The Notice of Proposed Rulemaking (Notice) proposes that the agency keep pace with evolving technologies and address the reliability challenges that the IP transition presents by adopting a new and expanded federal governance structure for 911. Comments on the proposals contained in the Notice are due to be filed by March 9, 2015, with Reply Comments due to be filed by April 7, 2015.
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Enhancing Situational Awareness in a Multi-Provider World. The Notice asks which entities would be subject to a certification process if such a requirement were adopted, and what the scope of new services would be that would trigger the need for a certification. Various factors are suggested with respect to analysis of network monitoring capabilities, situational awareness and sharing of outage information. Some questions highlighted for comment include whether the certification should address issues regarding diversity redundancy of the network, the possibilities of equipment failure, and the ability to switch to backup systems. Finally, the Notice asks for comment on the extent to which the certification risk analysis should include cybersecurity or supply chain risk assessment. The Notice asks whether it would be sufficient for service providers to conduct their own analysis or whether the certification analysis should be done by an independent third party. The Notice also asks if an FCC advisory commission such as CSRIC should develop best practices recommendations that would be basis for certification.
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