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STATEMENT

of

MICHAEL K. POWELL

Commissioner

Federal Communications Commission

Before the

Senate Special Committee on the Year 2000 Technology Problem

July 31, 1998




SUMMARY OF THE OPENING STATEMENT OF

FCC COMMISSIONER MICHAEL K. POWELL

BEFORE THE

SENATE SPECIAL COMMITTEE ON THE YEAR 2000 TECHNOLOGY PROBLEM

Good morning, Mr. Chairman, Senator Dodd and distinguished members of the Committee. I commend the Senate Special Committee on the Year 2000 Technology Problem for its active participation on this issue. I welcome this opportunity to share with you what the Federal Communications Commission (FCC) has learned about industry efforts to address the Year 2000 Problem, as well as to discuss the fundamental importance of the national telecommunications infrastructure and the potential impact of the Year 2000 Problem on embedded telecommunications networks and systems.

At the FCC, we are working to promote an effective public-private, "mission-oriented" partnership to ensure that users of telecommunications services enjoy as close to the same level of quality and reliability on and after January 1, 2000, as they do today. We believe that the FCC can play an important role by encouraging companies to share information with each other and with their customers. This will increase the sharing of solutions, avoid duplicative testing, help companies spot undetected problems, and reduce customer uncertainty and anxiety.

We have developed and continue to work on strategies for outreach and advocacy to all the industries we regulate, including wireline and wireless telephony, cable, and radio and television broadcast. We have also been looking into ways to facilitate the development of effective contingency plans in the event that a major disruption to the network should occur. Although we have programs for all the various telecommunications industries, my remarks today will focus mainly on wireline telecommunications carriers.

As an initial matter, it is important to remember that no single entity owns or controls the public switched telephone network. In addition to the major telecommunications companies that provide service to the majority of the country, there are also 1,400 small to mid-size independent telephone companies that serve many rural and insular parts of the country as well as the U.S. territories and possessions. And each of these companies is only one in a long chain of interdependent companies required for the network to operate. Without a doubt, the telecommunications network is a tremendously complex and interdependent thing, and consists of millions of interconnected parts.

As a result, the ways in which the Year 2000 Problem could affect telecommunications companies seem almost unlimited. However, I believe that with time and greater knowledge of the scope of the problem, and by maximizing the amount of information available to all companies facing the Year 2000 Problem, we will be able to better predict where and how problems in the network are likely to occur. In my role as Defense Commissioner, I plan to work closely with the industry and the Network Reliability and Interoperability Council to help them prepare for those problems.

We have sent over 200 letters to major companies and organizations in all sectors of the telecommunications industry asking them about their efforts to become Year 2000-ready. In June and July alone, we organized eight informational forums with representatives of different sectors of the telecommunications industry to facilitate information sharing and learn how the FCC can assist industry efforts to tackle the Year 2000 Problem.

I also represent the Commission on the President's Council on Year 2000 Conversion, and co-chair the Telecommunications Sector Group. In an attempt to better facilitate communication, I have asked representatives from each of the communications industries to sit on the sector group. We had our first meeting with the industry participants on July 17, 1998.

Our general assessment of the telecommunications industry remains positive. Our inquiry letters, for example, asked 20 carriers, accounting for about 98.1% of the country's access lines, to report on their top critical systems. We learned that generally, the carriers have completed their review of the inventory for these systems, they have completed assessing the impact of the Year 2000 Problem on these systems, and they have set completion dates for remediation, testing and integration by the second-quarter of 1999.

We have no information suggesting that the major U.S. equipment manufacturers will not be able to meet projected demands for equipment. Manufacturers report that most of their software and hardware products are already Year 2000-ready and have been made available to customers. They have targeted end-of-year 1998 or first quarter 1999 for general availability for all Year 2000-ready products.

The carriers are also cooperating on interoperability and end-to-end testing. The Telco Year 2000 Forum has contracted with Bellcore and is already performing integration testing on Year 2000-ready equipment. ATIS will conduct inter-network interoperability testing in January and February 1999, and is also working with Bellcore. This type of cooperative industry testing is very important because it is nearly impossible to conduct interoperability and end-to-end tests on the actual public-switched telephone network.

I would also like to take this opportunity to announce that C. Michael Armstrong, Chairman and CEO of AT&T, will chair the Network Reliability and Interoperability Council (NRIC) which will play a central role in our Year 2000 efforts. We believe that NRIC will be invaluable in coordinating overall testing, advising the FCC on the status of the industries' readiness, and assisting the Commission in facilitating the development of contingency plans. A representative of NRIC will also sit on the Telecommunications Sector Group of the President's Council.

While we have programs in place to work this problem, all that we have observed is not comforting. With regard to the independent telephone companies, it is important to note that there are some 1,400 small to mid-size companies that serve many rural and insular parts of the country. The Commission is working continuously to reach out to these companies to make sure that they are aware of the problem and are taking steps to address it.

We are even more concerned about international telecommunications carriers. The United States, Canada and the U.K. are forging ahead, but we have many concerns about carriers in other nations, especially those in developing countries, that have not yet taken the necessary steps to prevent system failures. We have been working independently to address this problem, as well as monitoring the work of the International Telecommunications Union.

In my role as Defense Commissioner, I have endeavored to make sure that the FCC is ready to continue operations in the event of a national emergency. In this regard, the FCC's Compliance and Information Bureau (CIB) has been revising the agency's continuity of operation plan, as well as a plan to maintain our ability to coordinate and grant special authority to help companies continue operating in an emergency. With respect to national emergency plans, CIB is reviewing and updating these plans. I will work with National Communications System (NCS) and the industry to continue to examine the appropriate role of the FCC in the event of an emergency.

Without a doubt, the legal liability issue is a serious impediment that continues to impede the flow of timely and candid information. We support the efforts to pass legislation that would promote the exchange of information by limiting the way such information could be used against the company. I believe there is a significant role to be played by the Congress and the Administration with regard to the legal liability issue and other barriers to the information flow.

As we move closer to the Millennium, all of our concerns become more acute. I believe that the FCC has begun to establish the kind of inter-company and private/public partnerships that will facilitate the flow of information and get it to those most in need. It will also permit the government to become aware of and respond to needs of the industry as they arise. Our national well-being is dependent upon the reliability of all the nation's telecommunications networks, and government and industry must work together to ensure that whatever disruptions occur do not lead to widespread outages and failures. To that end, the FCC is committed to taking whatever actions it can to facilitate information sharing and industry compliance efforts.


STATEMENT OF
FCC COMMISSIONER MICHAEL K. POWELL
BEFORE THE SENATE SPECIAL COMMITTEE
ON THE YEAR 2000 TECHNOLOGY PROBLEM

INTRODUCTION

Good morning, Mr. Chairman, Senator Dodd and distinguished members of the Committee. I commend the Senate Special Committee on the Year 2000 Technology Problem for its active participation on this issue. I welcome this opportunity to share with you what the Federal Communications Commission (FCC) has learned about industry efforts to address the Year 2000 Problem, as well as to discuss the fundamental importance of the national telecommunications infrastructure and the potential impact of the Year 2000 Problem on embedded telecommunications networks and systems.

My comments today will focus primarily on wireline telecommunications services. However, it is important to note that the FCC is engaged in outreach and assessment initiatives in each of the different subsectors of the communications industry, including terrestrial wireless, radio and television broadcast, cable television, international telecommunications and satellites. Appended to my testimony, as Appendix A, is a summary of how each of these different industries may be affected by the Year 2000 Problem and what industry and the FCC are doing to address these problems.

BACKGROUND

As you are aware, there are many automated and intelligent systems that were not designed to account for the millennial date change of January 1, 2000, and if not addressed, the Year 2000 Problem or so-called "Millennium Bug" could consequently affect every telecommunications subsector. At the FCC, we have developed and continue to develop outreach and advocacy strategies to raise industry awareness of the issue, as well as methods for assessing and monitoring the industries' efforts to address the problem. Finally, we have been looking into ways to facilitate the development of effective contingency plans in the event that a major disruption to the network should occur.

As an initial matter, it is important to remember that no single entity owns or controls the public switched telephone network. There are the major telecommunications carriers, like the Bell Operating Companies, GTE, AT&T, MCI and Sprint, that provide service to the majority of the country. But there are also 1,400 small to mid-size independent telephone companies that serve many rural and insular parts of the country as well as the U.S. territories and possessions. And these companies are only one in a long chain of interdependent companies required for the network to operate domestically.

For example, in order to fix the Year 2000 Problem, the carriers rely on manufacturers of central office switches and other network equipment. And then there are the end users which must make sure their equipment--such as their telephones, voice mail systems, Private Branch Exchanges (PBXs), and local area computer networks--are all Year 2000-ready otherwise they will not be able to send or receive voice and data traffic. These groups are, in turn, dependent upon other manufacturers for their equipment, who are, in turn, dependent yet again on other providers for parts and services like power. And on it goes.

Without a doubt, the telecommunications network is a tremendously complex and interdependent thing, and consists of millions of interconnected parts. The public switched telephone network processes millions of calls per minute. To transit each and every call, automated and intelligent machines and systems (in the possession of the thousands of telecommunications carriers and users described above) make calculations for the most efficient multi-path, real-time interaction of all points along the established circuit between the call's origination and destination.

For example, in milli-seconds, a phone call from Washington, D.C. to New York travels from your telephone, to the Private Branch Exchange (i.e., switchboard) in your building, to the local exchange carrier's central office switch, through the carrier's network components and systems that route your call to an inter-exchange carrier (or carriers), through long-distance trunk lines (or other telecommunications facilities like microwave, satellite, fiber optic), to another local exchange carrier's central switch, and ultimately to the telephone on the other end. Make the same call two minutes later and the call may be routed in a completely different manner as calculated by the network.

The foregoing description points to the mathematical impossibility (i.e., the infinite number of permutations and combinations of routing possibilities and service events to transit a voice or data call) of testing the entire public telephone network for Year 2000-readiness or of expressing a high degree of confidence about the readiness of the network. If any one of those components/systems (e.g., central office switch), network elements (e.g., advance intelligent network, Signaling System 7), or network interconnectors (e.g., local exchange carrier, interexchange carrier, Internet Service Provider, private telecommunications network user) is affected by the Year 2000 Problem, a call might be disrupted.

However, I believe that with time and greater knowledge of the scope of the problem, and by maximizing the amount of information available to all companies faced with this problem, we will be able to better predict where and how problems in the network are likely to occur. In my role as Defense Commissioner, I plan to work closely with the industry and the Network Reliability and Interoperability Council to help them address these problems.

FCC EFFORTS

In mid-March, the Commission created its Year 2000 Task Force. In mid-April, at the request of FCC Chairman William Kennard, I agreed to oversee the FCC's Year 2000 efforts and represent the agency on the President's Council on Year 2000 Conversion, which was established on February 4, 1998. I also co-chair with Dennis Fischer of the General Services Administration (GSA) the Council's Telecommunications Sector Group.

At the FCC, we are working to promote an effective public-private, "mission-oriented" partnership to ensure that users of telecommunications services enjoy as close to the same level of quality and reliability on and after January 1, 2000, as they do today. We believe that the FCC can play an important role by encouraging companies to share information with each other and with their customers. This will increase the sharing of solutions, avoid duplicative testing, help companies spot undetected problems, and reduce customer uncertainty and anxiety.

In Appendix A, attached to my testimony, you will find summaries of actions that the FCC has taken to promote its outreach and assessment efforts. As a result, I will only highlight those efforts here.

In an attempt to encourage private sector compliance efforts and to foster information sharing we have set up a special Internet site (www.fcc.gov/year2000/) which has received over 24,000 hits to date. Chairman Kennard, myself, the other commissioners, and FCC staff are all highlighting this problem in speeches and in meetings with leaders in the telecommunications industry.

We have sent over 200 letters to major companies and organizations in all sectors of the telecommunications industry asking them about their efforts to become Year 2000-ready. In June and July alone, we organized eight informational forums with representatives of different sectors of the telecommunications industry to facilitate information sharing and see how the FCC can assist industry efforts to tackle the Year 2000 Problem. In addition, I have asked representatives of each of the communications subsectors to participate on the Telecommunications Sector Group of the President's Council. We had our first meeting with the industry participants on July 17, 1998. I believe that their participation in the sector group will better facilitate communication and information sharing between government and private industry.

We have elected this engagement approach, rather than an adversarial regulatory one for a number of reasons. First and foremost among them is that there is very little time to get this job done. Only private firms can fix these problems and we must have their full cooperation and must obtain timely and candid disclosure of information. We are of the opinion that a heavy regulatory approach will lead to guarded communications, the involvement of lawyers rather than technologists and managers, and a huge loss of time while we haggle over requests and regulatory demands. Furthermore, most formal regulatory actions require compliance with standard procedures which often take months, time we do not have. Moreover, significant time would be lost to developing, issuing, evaluating and compiling lengthy data requests. Such efforts would divert both the FCC's limited resources and those of the companies from actually working the problem, which after all is what matters most.

Only the industry can fix this problem. It is important to remember that telecommunications carriers and users rely upon a complex, technical network that is engineered for near unfailing reliability. The Bellcore standard is 99.9999 percent up time. (For example, the Bellcore standard for switch reliability requires that any given switch not be inoperable for more than 3 minutes per year. That is 3 minutes of 525,650 minutes in a year.) Thus, these companies have a strong stable of trained experts in network reliability issues. They have experience with identifying threats to network reliability, planning corrections and executing those corrections. They also have experience doing similarly Herculean tasks, having pulled the public switched telephone network apart during the AT&T divestiture and the re-engineering that took place when the country instituted the three-digit area code convention.

ASSESSMENT

Our general assessment of the telecommunications industry remains positive. Our inquiry letters dispatched in late April, for example, asked 20 telecommunications carriers, accounting for roughly 98.1% of the country's access lines, to report on their critical systems. We learned that generally, the carriers have completed their review of the inventory for these systems, have completed assessing the impact of the Year 2000 Problem on these systems, and they have set completion dates for remediation, testing and integration by the second-quarter of 1999.

We are led to believe that most major U.S. equipment manufacturers will be able to meet projected demands for equipment. The major manufacturers have had extensive Year 2000 programs in place for some time, and have been working closely with both local and long distance carriers to develop strategies for Year 2000-readiness. Manufacturers report that most of their software and hardware products are already Year 2000-ready and have been made available to customers. They have targeted end-of-year 1998 or first-quarter 1999 for general availability for all Year 2000-ready products. Our continuing dialogue with the industry should allow us to assess any change due to unexpected increases in the demand for products.

The carriers are also cooperating on interoperability and end-to-end testing. Testing is (and will continue to be) the hardest, yet most important, part. Most telecommunications companies estimate that testing comprises 50-70% or more of their Year 2000 efforts. And we have learned that testing often uncovers more problems that need to be fixed.

The Telco Year 2000 Forum, which is comprised of eight large regional local exchange carriers, has contracted with Bellcore and is already performing integration testing on Year 2000-ready equipment. ATIS, which is an industry-funded organization whose mission is to advance new telecommunications technologies, will conduct inter-network interoperability testing in January and February 1999, and is also working with Bellcore. According to ATIS, the interoperability tests should encompass network configurations that serve over 90 percent of the country. This type of cooperative industry testing is very important because it is nearly impossible to conduct interoperability and end-to-end tests on the actual public switched telephone network. Unlike the Securities Industry Association's interoperability tests where the securities exchange network can be shut down from daily traffic, the nation's phone network has to be up and running 24 hours a day, 7 days a week and it involves millions of different elements. The telephone companies cannot disconnect their network and turn the clock ahead to the year 2000 to do a test.

I would also like to announce that C. Michael Armstrong, Chairman and Chief Executive Officer of AT&T, has agreed to chair the Network Reliability and Interoperability Council (NRIC) which will play a central role in our Year 2000 efforts. The new Council will have a staff group dedicated to the Year 2000 effort, headed up by A. John Pasqua, Vice President-Corporate Year 2000 Program, also from AT&T, and we hope a representative from a major equipment manufacturer. We believe that NRIC will be invaluable in coordinating overall testing, advising the FCC on the status of the industries' readiness, and assisting the Commission in facilitating the development of contingency plans. A representative of NRIC will also sit on the Telecommunications Sector Group of the President's Council, which will facilitate constructive dialogue between the industry and those government entities that rely most heavily upon the telecommunications infrastructure.

While we have programs in place to address this problem, all that we have observed is not comforting. At this juncture, with respect to the telecommunications industry, the FCC continues to be concerned about the effect of Year 2000 problems on small to mid-size independent carriers as well as on international telecommunications carriers. These two areas of concern arise from the numerous informational meetings the FCC's Bureaus have conducted and the reports received that many of the companies: (1) may not realize (or may be slow to realize) the seriousness of the problem; and (2) will not have the financial resources, available personnel, or management structure to begin implementing appropriate Year 2000 compliance measures.

With regard to the independent telephone companies, as I stated, there are some 1,400 small to mid-size companies that serve many rural and insular parts of the country. The Commission is working continuously with various trade associations, to which many small and mid-size carriers belong, in an effort to alert their members that they need to begin Year 2000 remediation efforts now. Moreover, the FCC has commenced a dialogue with the National Association of Regulatory Utility Commissioners (NARUC), and specifically the association's Communications Committee for the purpose of promoting State-level awareness of the Year 2000 Problem because of the close regulatory relationship between telecommunications carriers and their State regulators. In fact, just two days ago I attended NARUC's annual Summer meeting where they convened a Communications Committee panel on State-level Year 2000 initiatives. Finally, the FCC intends to transmit letters to each and every one of the 1,400 small and independent carriers in the coming weeks.

We are even more concerned about international telecommunications carriers. The United States, Canada and the U.K. are forging ahead, but we have many concerns about carriers in other nations, especially those in developing countries, that have not yet taken the necessary steps to prevent system failures. We are further concerned that international economic challenges may prevent foreign carriers and users from addressing the Year 2000 problem. For example, in Europe, we have concerns as to whether carriers and users will be ready for the onset of the Euro and still be able to implement Year 2000 compliance efforts. Moreover, in Asia, we are concerned that the current recession and economic difficulties could prevent carriers and users from satisfactorily meeting the Year 2000 challenge.

In concert with the other Bureaus and offices of the Commission, the FCC's International Bureau hosted a series of roundtable discussions with the U.S. communications sector to raise awareness, seek solutions, and informally survey progress of industry efforts. In tandem with these roundtables, we have raised the issue with foreign delegates in the context of the FCC Visitor's Program and Foreign Regulator Workshops. The Year 2000 problem has also been addressed in speeches presented in bilateral discussions and international forums. We have also circulated letters to the U.S. international telecommunications companies informing them of our efforts and encouraging them to take prompt and effective action, including with their foreign correspondents.

In addition, the International Telecommunications Union (ITU) has been addressing this issue. The ITU has established a Year 2000 Task Force with five subgroups (including a contingency planning subgroup) spearheaded by British Telecom's Ronald Balls to increase international awareness and provide direction on the global Year 2000 Problem. The ITU also has circulated "The Year 2000 Millennium Compliance Questionnaire" to its 5,000 members--governments, telecommunications carriers, and operators--however, the response has been poor. The ITU is redoubling its efforts to mobilize governments to put pressure on operators to respond to the questionnaire. The questionnaire will serve to uncover where efforts are needed and what resources should be directed to those countries.

Other activities of the ITU include hosting workshops, making presentations, and participating in discussions and roundtables. It has established a "Y2K Ambassadors" program to serve as regional coordinators for assistance on Year 2000 Problems and activities around the world. The FCC has agreed to be such an Ambassador for the region of the Americas. The ITU is supporting and involved with Year 2000 testing in Europe and Africa, and dispersing information on various Year 2000 standards such as British Standards Institute (BSI) to telecom and satellite operators, which are its members.

IMPACT OF YEAR 2000

As I stated earlier, the telephone network is a very complicated and interdependent thing and consequently it is difficult to predict with any level of certainty all the ways that the failure of one piece of the network could trigger failures elsewhere in the system. For example, if calls to a particular country fail to be completed, there will likely be many redial attempts, which will place increased burden on one central office switch. Securities trading may target a specific country at a particular time of day. Calls that do not go through will result in increased and unexpected traffic at that switch. In addition, a carrier may be unable to bill correctly for calls. As a result, the carrier receives no revenue or delayed revenue from its customers. As a consequence, the carrier is unable to pay its suppliers in a timely manner.

There are also secondary effects to consider. For example, although no date-sensitive information crosses the interface between two carriers, the Year 2000 issue poses problems when carriers try to conduct maintenance on systems. Performance data is collected on either side of the interface. Some reports are generated on a date/time basis. The problem arises when a failure occurs. If one carrier sees a problem and the other does not, it is difficult to determine which carrier is right, and therefore difficult to identify the root of the problem. There could also be testing and coordination delays. Most carriers are planning to conduct Year 2000 tests with each other.

These are only examples of the types of problems the industry must confront in addressing the impact of the Year 2000 Problem. I believe our role is to facilitate the sharing of information that both raises concerns like these and facilitates the search for solutions.

THE ROLE OF THE FCC DEFENSE COMMISSIONER

In addition to my role as FCC Commissioner and member of the President's Council, I have additional responsibilities in connection with my role as the designated Defense Commissioner. Section 0.181, Title 47 of the Code of Federal Regulations sets out the duties of the Defense Commissioner at the FCC. In Appendix B, appended to this statement, you will find a copy of this section of the code.

In my role as Defense Commissioner, I have endeavored to make sure that the FCC is ready to continue operations in the event of a national emergency. In this regard, our Compliance and Information Bureau (CIB) has been revising the agency's continuity of operation plan to ensure that the agency will continue its work in the event of an emergency that affects FCC headquarters. The revised plan was developed with the help of an expert from National Communications System (NCS) who was detailed to the Commission to help with this project.

In addition, CIB has recently reviewed and evaluated its plan to handle emergency authorizations and other industry-related needs if an emergency were to occur after business hours. In general, this procedure grants CIB the authority to authorize special temporary authority for services requested that it believes are necessary to ensure safety and the continued operation of the network.

With respect to national emergency plans, I inherited some plans when I took on the role of the Defense Commissioner. CIB is reviewing and updating these plans. Any plans will be coordinated with NCS. As I stated earlier, it is premature to make even educated guesses on where our efforts in contingency planing will best be served, but I will work with NCS and the industry in this regard.

ACTIONS THAT THE CONGRESS AND THE ADMINISTRATION SHOULD TAKE TO FACILITATE YEAR 2000 COMPLIANCE EFFORTS

Without a doubt, the legal liability issue is one of the most serious impediments that continues to impede the flow of timely and candid information. Concerns with respect to releasing information related to Year 2000 compliance have been raised at every one of our informational forums. The concerns proffered by industry are associated in part with issues of product disparagement, antitrust violations, third-party liability, carrier-vendor contractual relations, and so on. Consequently, some companies have been reluctant to divulge information due to concerns about liability.

We support the efforts to pass legislation that would promote the exchange of information by limiting the way such information could be used against the company. Respondents to FCC requests for information have requested confidential treatment, invoking 47 C.F.R. 0.459. Several others have labeled their submissions to the letters "proprietary information." Others have expressed reluctance at our sharing this information, despite having not made an explicit confidentiality request. Another factor that interplays is the Trade Secrets Act, 18 U.S.C. 1905, which provides criminal penalties for unauthorized disclosure of information. Thus, I believe there is a significant role to be played by the Congress and the Administration with regard to the legal liability issue and other barriers to the information flow.

CONCLUSION

As we move closer to the Millennium, all of our concerns become more acute. Our efforts so far have begun to establish the kind of inter-company and private/public partnerships that will facilitate the flow of information and get it to those most in need. It will also permit the government to become aware of and respond to needs of the industry as they arise. Our national well-being is dependent upon the reliability of all the nation's telecommunications networks, and government and industry must work together to ensure that whatever disruptions occur do not lead to widespread outages and failures. To that end, the FCC is committed to taking whatever actions it can to facilitate information sharing and industry compliance efforts.

I would be happy to answer any questions you might have.

APPENDIX A

OVERVIEW OF THE YEAR 2000 PROBLEM
IN THE COMMUNICATIONS SECTOR: CONCERNS AND ACTIONS

Common Carrier Bureau

Biggest concerns:

What the FCC is doing:

What industry is doing:

Cable Services Bureau

Biggest concerns:

  • Power system failures could disrupt cable service, including the cable system's emergency alerting system messages.

  • Timed controllers used for pay-per-view and other video programming, commercial insertion, local origination equipment and converter boxes are examples of equipment which may malfunction.

  • Billing systems could generate faulty data.

  • Satellite telecommunications links could be disabled.

    What the FCC is doing:

    What industry is doing:

    Mass Media Bureau

    Biggest concerns:

    What the FCC is doing:

    What industry is doing:

    Wireless Telecommunications Bureau

    Biggest concerns:

    What the FCC is doing:

    What industry is doing:

    International Bureau

    Biggest concerns:

  • Whether foreign telecommunications companies, especially large segments of the developing world, will be able to provide service on January 1, 2000. This could have a huge impact on international trade, foreign investment, the global economy, and even national security.

  • Whether the operability of the global telecommunications network, which is critical to public safety, emergency preparedness and personal communications will be jeopardized.

  • In many foreign countries, particularly in Asia and Africa, telecommunications companies are only now becoming aware of the Year 2000 problem and they lack the resources to fully address it.

  • We are concerned that some telecommunications carriers have not yet taken the necessary steps to prevent system failures.

  • We are concerned that international economic challenges may prevent foreign carriers and users from addressing the Year 2000 problem, (e.g., in Europe, whether carriers and users will be ready for the conversion of the Euro and still be able to implement Y2K compliance efforts and in Asia, whether the current recession and economic difficulties could prevent carriers and users from addressing the Y2K challenge).

  • We are concerned that terminating calls overseas, which relies on the networks of foreign Public Telecom Operators (PTOs) could be a problem.

  • We are concerned about the Y2K readiness of satellite systems. The primary concern regarding satellite systems appears to relate to the earth stations, which control the satellites from the ground, rather than the satellites, themselves, which generally are not date-dependent.

  • We are concerned whether revenue streams will be curtailed by operations/support systems (billing) problems associated with telecom networks and earth to space degradation and/or complete failure.

    What the FCC is doing:

    We are considering:

    What industry is doing:

    Compliance and Information Bureau

    Biggest concerns:

    What the FCC is doing:

    Office of Engineering and Technology

    Biggest concerns:

    What the FCC is doing:

    Office of the General Counsel

    What the FCC is doing:

    Office of Plans and Policy

    What the FCC is doing:

    Office of Inspector General

    Biggest Concern:

    What the FCC is Doing:

    APPENDIX B

    47 C.F.R. 0.181 -- The Defense Commissioner.

    A Defense Commissioner and two Alternate Defense Commissioners are designated by the Commission. The Defense Commissioner directs the defense activities of the Commission and has the following duties and responsibilities:

    To keep the Commission informed as to significant developments in the field of emergency preparedness, defense mobilization, and any defense activities that involve formulation or revision of Commission policy in any area of responsibility of the Commission.

    To represent the Commission in national defense matters requiring conferences or communications with other governmental officers, departments, or agencies.

    To act as the Defense Coordinator in representations with other agencies with respect to planning for the continuity of the essential functions of the Commission under national emergency conditions, and to serve as the principal representative of the Commission to the Interagency Emergency Planning Committee of the Federal Preparedness Agency/General Services Administration.

    To serve as the principal representative of the Commission to the Interagency Civil Defense Committee of the Defense Civil Preparedness Agency of the Department of Defense.

    To serve as the principal point of contact for the Commission on all matters pertaining to the National Communications System.

    To take such measures as will assure continuity of the Commission's functions under any foreseeable circumstances with a minimum of interruption.

    In the event of enemy attack, or the imminent threat thereto, or other disaster resulting in the inability of the Commission to function at its offices in Washington, D.C., to assume all of the duties and responsibilities of the Commission and the Chairman, until relieved or augmented by other Commissioners or members of the staff, as set forth in 0.186 and 0.383.

    To approve national emergency plans and develop preparedness programs covering: provision of service by common carriers; broadcasting facilities, and the safety and special radio services; radio frequency assignment; electromagnetic radiation; investigation and enforcement.

    To perform such other duties and assume such other responsibilities related to the Commission's defense activities as may be necessary for the continuity of functions and the protection of Commission personnel and property.

    [29 FR 14664, Oct. 28, 1964, as amended at 41 FR 31209, July 27, 1976]