Network Reliability and Interoperability Council IV (NRIC IV)

Summary of Meeting

October 14, 1999

I. INTRODUCTION

NRIC IV convened its fifth meeting at 1:30 P.M. on October 14, 1999, in the Commission meeting room at the headquarters of the Federal Communications Commission (FCC or Commission), 445 12th Street, S.W., Washington, D.C. 20554. In accordance with Public Law 92-463 (The Federal Advisory Committee Act), the meeting was open to the public. The FCC provided notice of the meeting in a Public Notice (DA 99-2113) released October 7, 1999, and in the Federal Register (64 FR 52788-01). Approximately 150 people attended the meeting. An audio feed was provided through the Year 2000 website maintained by the FCC (www.fcc.gov). The meeting was also carried on closed circuit television (with close captioning) to the meeting room and to various sites around the Commission

Panelists Present

Panelist Presenters (Continued)

Panelists-Presenters

FCC Staff Members Present

II. Opening Remarks

Marsha MacBride, Executive Director of FCC Year 2000 Task Force, a member of the NRIC IV Steering Committee, and the Designated Federal Official for NRIC IV (hereafter NRIC), welcomed group and introduced Michael Armstrong, Chairman of the Board and Chief Executive Officer of AT&T and the NRIC Co-Chair. Mr. Armstrong presided.

Mr. Armstrong noted this was the last formal meeting of NRIC IV. He thanked FCC Defense Commissioner Michael Powell not only for being the NRIC Co-chair but also for his active participation in NRIC activities, for his knowledge and understanding of the issues involved, and for being so supportive of all of those working to addressing these issues. For their assistance with NRIC activities, Mr. Armstrong also thanked Mr. John Pasqua of AT&T, the NRIC Steering Committee Chair, and Mr. Frank Ianna, President of AT&T Network Services.

Mr. Armstrong pointed out that only about 78 days are left until the Year 2000. Through the extensive efforts of members of the various focus groups and sub-committees, he noted NRIC has made a significant contribution to both industry and public understanding of the Year 2000 challenge. He also took note of the successful industry forum hosted by NRIC on August 5 to share with the public and the industry some of the work that had been completed on these issues.

Mr. Armstrong added that there were still has some readiness issues to address relative to the international situation, to smaller local exchange carriers (LECs), and to the local Public Safety Answering Positions (PSAPS) used to handle 911 and other emergency calls. But even here, he noted that reports later in the meeting would show that major progress has been made in these areas as well. In addition to Commission Powell, Mr. Pasqua, and Mr. Ianna, Mr. Armstrong thanked the many other persons who had participated in NRIC and made it a real industry success. He then introduced Commissioner Powell.

Commissioner Powell welcomed the group and acknowledged Mr. Armstrong’s active and intimate participation in the efforts of NRIC. Commissioner Powell also thanked others in industry and government for their contributions including Marsha MacBride. He said there remains much to be done but that news from this final meeting of NRIC IV would be positive. He submitted that NRIC IV could have no greater legacy than such positive news.

In response to frequent queries, Mr. Armstrong noted he is highly confident but not comfortable with the Year 2000 readiness of our industry because preparations must continue through the end of the year. He explained that focus group reports and a report on the proposed charter for NRIC V would be presented at this meeting.

II. FOCUS GROUP REPORTS

A. Focus Group I

1. General. Mr. P.S. Sahni of AT&T, the Chair of Focus Group I, presented the report. He noted Focus Group I has responsibility for determining how the Year 2000 problem could adversely affect public telecommunications networks. It includes a subcommittee on Year 2000 network assessment (headed by Gerry Roth of GTE), a subcommittee on Year 2000 testing (headed by Lou Scerbo of Telcordia Technologies), and a subcommittee on Year 2000 contingency planning (headed by Ronnie Lee Bennett of Lucent Technologies). Mr. Sahni identified key messages from these subcommittees.

2. Key Messages From Subcommittees of Focus Group I.

Network Assessment Subcommittee Key Messages

Major Carriers. As of the end of September, the major carriers (both LECs carriers and interexchange carriers) are expected to complete their remediation and implementation programs.

Mid-size and Smaller Local Exchange Carriers. It appears that most mid-size and small local exchange carriers will be Y2K compliant by the end of December.

International Traffic. The risk profile for international traffic from the United States continues to improve. A majority of this traffic now falls in the in the low and medium risk categories.

With regard to traffic between the United States and "high volume" traffic countries, about 84 per cent of this traffic is now in the low/medium risk category – an improvement of 4 per cent since NRIC’s July 14 report. "High traffic" refers to countries with at least 100 million minutes of traffic with the United States.

With regard to traffic between the United States and "low volume" traffic countries, about 70 per cent of this traffic remains in the high-risk category. "Low traffic" refers to countries below 100 million minutes of traffic with United States.

Testing Subcommittee Key Messages.

Domestic Situation. Exhaustive interoperability testing by major domestic LECs and interexchange carriers has been or is nearly completed. In the course of this testing, no Year 2000 date change related anomalies have been reported. This testing included equipment from a majority of exchange access and interexchange switch and signaling vendors.

International Situation. Under the auspices of the ITU and ATIS, the interoperability testing to date has included major international gateway switch vendor equipment and equipment from North American service providers. Though the trials included good testing coverage, no Year 2000 anomalies were reported.

Contingency Planning Subcommittee Messages.

The focus has been on the assembly of a unified communications plan. The components of that plan are now in place. The Network Communications Center of the National Communications System (NCC/NCS) is expected to act as the focal point for data collection from both domestic and foreign sources. Sources will include major local exchange carriers, interexchange carriers, industry forums, ITU members, and government agencies. The NCC/NCS will share information with the FCC and the National Information Coordination Center (ICC) as well as with national information coordination centers in other countries.

3. Overall Assessments

Domestic. The risk of failure of the domestic public switched telecommunications network (PSTN) is minimal.

International. The risk of call failure between the North American region and other world regions is minimal. Potential impacts include some delay in call setup due to network congestion in some foreign markets and possible degradation of service quality over time due to non-compliant components in some foreign networks. In addition, the unpredictable impact of Year 2000 on non-telecommunications infrastructure (electricity, gas, and oil) could have an adverse impact on foreign telecommunications networks.

4. Report of Network Assessment Subcommittee (Subcommittee 1 of Focus Group 1)

a. Domestic Communications

(1) Larger Carriers Surveyed by Subcommittee.

Gerry Roth with GTE summarized the report of the assessment subcommittee. He noted over 99+ percent of the public telecommunications network and its support systems were Year 2000 compliant as of the end of September 1999. According to the end of September estimates provided by both the large LECs and the large interexchange carriers, 100 per cent reported that they would be completed by that date.

Large LECs. Of the more than 203 million access lines in the U.S., large LECs serve about 88 million of those lines. Those LECs expected to be 100 percent complete with Year 2000 preparations by the end of September.

(2) Small and Mid-Sized LECs Surveyed by FCC.

Small and mid-sized LECs serve the about 15 million of the 203 million access lines in the U.S. These small and mid-size LECs trail the large LECs but 98 per cent of them plan to complete their Y2K preparations by the end of December.

The large June Year 2000 readiness survey conducted by the FCC remains the most authoritative survey of small and mid-size local exchange carriers in the United States. Of the approximately 1200 small and mid-size carriers contacted, 1051 carriers (or about 87 per cent) responded to the Commission survey. The 13 percent that failed to respond remain somewhat of a concern. Of those carriers that did respond, 98 per cent expect to be Year 2000 compliant by the end of December 1999. About 190 either acknowledged that they did not expect to be fully compliant by year-end or did not respond to the survey. Those that did respond but do not expect to be fully compliant by year-end include about 25 carriers serving between 200 and 400,000 access lines in the United States. The Communication is working with these carriers toward a solution to this shortfall. Depending on the situation with each carrier, those efforts may lead to special contingency plans for alternate routing of traffic within that carrier’s network or, perhaps, to arranging routing or other assistance from other nearby LECs.

(3) Other Domestic Surveys

Other surveys and related information tend to support the FCC survey data. The National Telephone Cooperative Association (NCTA) surveyed its member cooperatives. Of the 395 cooperatives that responded to the NCTA survey (about 80 per cent), 100 per cent reported that they would complete their Year 2000 preparations by the end of December. The U.S. Department of Agriculture Rural Utility Service (RUS) also surveyed local exchange carriers. Of the 775 local carriers that responded to the RUS survey (about 94 per cent), approximately 98 per cent reported that they would complete their Year 2000 preparations by the end of December. Equipment manufacturers separately advise that Year 2000 compliance upgrades for every known rural switch in the U.S. either have been completed already or are scheduled for completion before the end of the year. Thus, where small or mid-size local exchange carriers report that they do not expect to complete their Year 2000 preparations before the end of the year, the problem appears to be with "back office" systems (e.g., billing equipment) rather than with critical elements of their communications networks (e.g., switching equipment).

Mr. Roth suggested some potential impacts if small or mid-size local exchange carriers serving less than two percent of all access lines in the U.S. are not Year 2000 compliant by the year-end.

First, call processing and call completion should not be impacted by such non-compliance.

Second, impacted companies, if any, would be geographically distributed so large pockets of outages are not likely to occur. Outages could well be similar to those resulting in the past from winter storms or cable cuts.

Third, basic telephone services (e.g., 911 service, ISP access, access to 800 numbers, directory assistance, and access to long distance service) would likely continue to be available.

Fourth, some service delays might occur, such as slower dial tone access or alarm responses, but that such delays would more likely be due to network congestion rather than to any Year 2000 problems.

Fifth, possible secondary effects in some back office systems might have an impact on features of importance to customers. Those features include billing accuracy, customer care response times, repair response times, and responses to new service requests.

Sixth, some deterioration in service could occur over time if carriers did not take make their systems Year 2000 compliant in the first quarter of the Year 2000.

Finally, any telecommunications outages in the United States are not expected to rolling and widespread. If they occur at all, such outages are expected to be gradual, isolated, and not simultaneous. Accordingly, any such outages likely would be addressed adequately by dynamic traffic re-routing and by timely repairs. Also, some spot outages (particularly any spot hits on back office systems) might not be seen till mid-January, February, or even later in the year.

b. Foreign and International Communications

Mr. Roth reported that overall the Year 2000 readiness of foreign countries is improving. Of the original six sources of Year 2000 information on foreign countries, however, he noted three elected not to update their information for the last quarter. Thus, to normalize the available information over time, the subcommittee excluded earlier data from these last three sources in preparing the current report.

He noted 224 countries were included in last combined survey.

Of those 224 countries, 53 were identified as "high" traffic countries because they had 100 million or more minutes of reciprocal traffic with the United States in 1997. In addition, these 53 countries account for about 90 percent of all reciprocal traffic with the United States.

Among these 53 "high traffic" countries, 84 percent (up from 80 percent in the last report) are now in the "medium" and "low risk" categories.

The following eleven countries are believed to remain in a "high risk" category together with several smaller African nations. These countries include:

India, Indonesia, Russia, China, Egypt, Italy, Pakistan, Czech Republic, Israel, North Korea, and Ukraine. While included on this "high risk/high traffic" list, Mr. Roth noted that four of these countries (India, Indonesia, China, and Italy) had participated in "Gateway to Gateway" Y2K testing with either North American or intra-regional countries and those tests did not uncover any Y2K problems with the facilities tested.

Among the 224 countries, 171 were identified as "low traffic" because they each had less than 100 million minutes of reciprocal traffic with the United States in 1997. These 171 countries only account for about 10 percent of the 1997 reciprocal traffic with the United States. Of these 171 countries, 131 (about 70 percent up from 67 percent) are now found in the "high risk" category. These countries are listed as "high risk" because they have not yet brought themselves into compliance or because they had not yet communicated their compliance to the public.

Mr. Roth summarized the likely impacts of Y2K internationally:

(1) Virtually no Y2K problems are expected in remediated network infrastructures;

(2) Network congestion may become an issue in some locations causing minor delays or rerouting;

(3) Network management, provisioning, and capacity issues may be detected over the first few months of the new year;

(4) Networks with non-compliant Y2K elements may experience problems locally;

(5) Unpredictable infrastructure failures, changes consumer behavior, or problems with customer premises equipment (CPE) or private networks could adversely impact telecommunications

5. Report of Interoperability Testing Subcommittee (Subcommittee 2 of Focus Group 1)

On behalf of Subcommittee 2 Chair (Lou Scerbo of Telcordia Technologies), Eddie Carlucci of AT&T delivered Subcommittee Report.

Mr. Carlucci reviewed the Subcommittee’s charter and methodology.

He noted that the Subcommittee had conducted its own surveys, obtained test results from others, made recommendations, and drawn various conclusions.

He reported many industry groups, forums, and other industry segments that had provided or were providing the Subcommittee with the results of their interoperability tests. Among others, he noted that the North American Testing Team (part of the ITU) had completed extensive tests with carriers in 27 countries (or national PTTs) with particular attention to those countries that exchanged a high volume of traffic.

Finding No. 1. In response to earlier questions about the potential Y2K impact on Internet service, the Subcommittee reported that interoperability testing between a large Internet Service Provider (ISP) and a major Internet backbone provider was scheduled to occur later this month (October 1999).

Finding No. 2. In response to earlier questions about the ability of a Y2K -ready network provider to inter-operate successfully with the equipment of a non-Y2K-ready network provider, the Subcommittee reported its finding that the potential Y2K impacts in the non-Y2K ready network would not propagate between the interfacing networks. Accordingly, the Subcommittee will pursue no further interoperability testing in this area. Mr. Carlucci noted, however, that in such a situation, the non-Y2K-ready carrier might experience various problems as a result of the degraded performance of its own network.

Finding No. 3. In response to earlier questions on the matter, the Subcommittee reported it had not been able to arrange interoperability testing with smaller LECs because those LECs were not able to participate without disrupting their current operations. As a substitute for such tests, the Subcommittee recently arranged testing involving a large Enhanced Service Provider (ESP) (e.g., an SS7 provider) that serves many smaller and medium size LECs, a CLEC, and a large interexchange carrier. Mr. Carlucci reported all tests to date with this ESP had been completed successfully and that the remaining tests were expected to be completed by the end of this month (October 1999).

Conclusions. Based its work to date, the Subcommittee drew the following conclusions:

(a) The risk of failure of the domestic public switched telecommunications network (PSTN) is minimal. As reflected in the interoperability matrices prepared by the Subcommittee, a large amount of testing has been completed. Accordingly, the Subcommittee believes that additional testing – beyond that already planned – is not warranted.

(b) The risk of international call failure between the North American Region and Other World Regions (gateway-to-gateway) is minimal; however, the completion of calls to countries with non-compliant networks may be degraded.

6. Report of Contingency Planning Subcommittee (Subcommittee 3 of Focus Group 1)

Ronnie Lee Bennett of Lucent Technologies delivered the report of the Year 2000 Contingency Planning Subcommittee. Mr. Bennett noted that his subcommittee’s efforts were part of a larger industry effort led by Eugene Chiappetta of the Telco 2000 forum.

a. Communications Plan.

As part of an "early warning" communications plan, participating U.S. carriers and various ITU members have entered into agreements to contribute information to a central NCC/NCS data base. In coordination with the FCC and DOD, that information will be reviewed at the ICC under the terms of those agreements. Status data and other information would then be passed both to our National Information Coordination Center and to similar national coordination centers in other countries. Finally, such information would be shared with the international Y2K coordination center sponsored by the UN. Mr. Bennett provided some details on processes and current status of the NCC Y2K database.

b. Contingency Planning Workshop and Matrices

In April of this year, the Subcommittee held a successful contingency planning workshop in Northern Virginia for small and mid-size carriers. While the Subcommittee is prepared to hold another workshop on this topic, Mr. Bennett also noted the availability to such carriers of contingency planning documents, contingency matrices, and other developmental tools on the NRIC web site.

B. CPE Readiness and Contingency Planning (Focus Group 2)

1. Focus Group 2 Report

William Blatt of Prism Communications, the Focus Group II Chair, delivered the Focus Group report. He noted his Focus Group had concentrated on the Y2K readiness of various categories of customer premises equipment (CPE) including: private branch exchange (PBX) and key systems, facsimile machines, modems, cellular telephones, devices for the disabled, private data networks, and public safety answering positions. Based on its data collection and other activities to date, the Focus Group found that there are no major problems or industry-wide issues that cannot be handled with planning, including the processing of emergency (911) calls.

With regard to the making of emergency (911) calls, Mr. Blatt explained that his Focus Group had examined both the readiness the CPE used by individuals to make such calls and the readiness of the Public Safety Answering Positions (PSAPs) that processed such calls from the Public Switched Telephone Network (PSTN).

2. Recommendations of Focus Group 2

a. Recommendations for the FCC.

Focus Group 3 recommends that the FCC continue to provide the public will information by using all available channels. Focus Group II also urges the FCC to declare a moratorium on regulatory mandates that would impact network interfaces or CPE.

b. Recommendations for Suppliers and Service Providers

For suppliers and service providers, Focus Group 2 makes many recommendations including the following:

(a) Communicating the current Y2K status of products;

(b) Communicating the availability of Y2K upgrades; and

(c) Making Y2K solutions available when needed.

c. Recommendations for End Users

For end-users of CPE, Focus Group 2 makes many recommendations

including that they:

(a) Become informed;

(b) Inventory all systems;

(c) Contact vendors to establish compliance status;

and

(d) Plan and budget for needed upgrades.

3. Report from National Emergency Number Association (NENA)

In light of the interest in the Y2K readiness of the public safety

answering positions (PSAPs) located around the country, Mr. Blatt invited William H. Hinkle, President of the National Emergency Number Association (NENA) to address this meeting. As Mr. Hinkle was not able to attend, James W. Hobson spoke on behalf of NENA and Mr. Hinkle.

Mr. Hobson reported 4300 is the primary population of PSAPs in the US. He explained that "primary" PSAPs are the ones that actually receive emergency calls from callers. NENA obtained survey results or other responses that represent 2754 of those 4300 PSAPs.

As of the October 1, 1999, Mr. Hobson noted that about half (1379) of the 2754 respondents reported that their PSAPs were completely Y2K compliant. Of the remainder, 1368 reported that that they would be Y2K compliant before January 1. Only seven of the responding 2754 PSAPs reported that they did not expect to be ready by the New Year.

Mr. Hobson noted that NENA examines PSAPs from three different degrees of service from basic 911 services (first degree) through enhanced CPE equipment (second degree) to management information service (MIS) equipment (third degree). Assuming that NENA’s survey respondents reflect the situation among the 4300 primary PSAP population, NENA expects basic 911 services (first degree) largely to be present among these 4300 PSAPs. Also in the NENA survey, a large percentage of those who responded (2747 of 2754 or 99.78 percent) reported that their enhanced 911-capabilities (second degree) would be Y2K compliant by the end of the year. Regarding the readiness of MIS equipment (third degree) and the impact on emergency services, Mr. Hobson sought clarification from Mr. Blatt.

While not entirely familiar with the situation, Mr. Blatt suggested that any Y2K problems with MIS equipment were not expected to have an impact on the provision of basic services (first degree) by PSAPs but that, in some cases, such problems might delay the provision of enhanced 911-services (second degree). For example, if the person making a 911 call were not able to provide a correct address, the dispatcher might have to look up the address on the basis of the caller’s phone number rather than receive that address automatically with the incoming call.

Mr. Hobson reported that NENA seeks to complete a vendor survey in addition to its PSAP survey and to secure survey responses from those PSAPs that have not yet responded. For further information on NENA and its activities, Mr. Hobson encouraged those in attendance to contact W. Mark Adams, Executive Director of NENA, at 800-332-3911.

Noting about 36 per cent of the PSAPs were not represented in the survey, Commissioner Powell asked how many of these non-responders offered basic services and how many offered enhanced services.

Mr. Hobson did not know. Assuming non-responders were from smaller rather than larger municipalities, Mr. Hobson thought a majority of this group offered only basic services. He said he would attempt to obtain such information on non-responders and submit it at a later date.

Commissioner Powell also sought confirmation that if the enhanced service of a PSAP were disrupted, the PSAP would not fail but would simply revert to the provision of basic service. Because basic service simply means that the emergency call reaches the PSAP, Mr. Hobson did not believe that any disruption of a PSAP’s enhanced service would interfere with that PSAP’s basic service

C. Network Reliability Steering Committee (Focus Group 3)

1. Focus Group Report.

Ray Albers, the Chair of Focus Group 3, noted that his Group, unlike others within NRIC, does not focus on the Y2K issues. Rather, he explained, they examine more generally the reliability of the public telecommunications network services in the United States. As part of that effort, they determine whether "best practices" previously recommended should be modified or supplemented. They also look at whether these "best practices" should be extended to other industry segments.

He provided some network reliability highlights for 2Q99. He noted that these highlights and more detailed information could be found at the ATIS website on the Internet (www.atis.org/atis/nrsc/document.htm).

2. Best Practices Subcommittee (Subcommittee 1 of Focus Group 3)

Rick Harrison from Telcordia Technologies provided the report from the Subcommittee 1 on "Best Practices." He explained there had been an unusually high number of outages (22) during the previous reporting period (7/1/98 to 6/30/99). This was the highest outage frequency in the 7-years that reports have been provided to the FCC. He explained the reasons for some of these outages and the extent to which they involved failures to follow best practices.

Mr. Harrison also described proposals for new best practices and the deletion of some earlier practices that were no longer the "best." He noted changes in best practices for essential services and for suppliers.

3. Data Analysis Subcommittee (Subcommittee 2 of Focus Group 3)

P.J. Aduskevicz provided the report from Subcommittee 2 on Data Analysis and Future Considerations.

She described the four task teams established to accomplish the work of the Subcommittee:

1. Task Team 1-- The Interface Team

2. Task Team 2 -- Current Process Team

3. Task Team 3 -- Future Considerations Team

4. Task Team 4 -- Recommendations Team

On the subject of reporting outages, Ms. Aduskevicz drew a distinction between those carriers subject to mandatory reporting requirements under Section 63.100 of the Commission’s Rules and those who may chose to file reports voluntarily

Through the sharing of various information by wireline carriers on the Subcommittee with non-wireline segments of the industry, the Subcommittee learned that that many non-wireline Subcommittee members (e.g., wireless, cable, paging) were familiar with the outage reporting requirements but that some could use more information on best practices. Accordingly, the subcommittee recommends that NRIC best practices be reviewed by non-wireline service providers.

For those not subject to the mandatory reporting requirements, the Subcommittee also recommended development of a voluntary reporting trial with participation by providers of Commercial Mobile Radio Service, satellite, cable, and data networking services as well as ISPs. The purpose of these voluntary reports would be to alert the NCS/NCC to any "widespread outages" that have significant public impact. For the proposed trails, the Subcommittee made specific recommendations on the criteria for "alert situation" and for "outage" examples.

V. Rechartering of NRIC

Dale Hatfield, Chief of FCC Office of Engineering and Technology, presented to the group and reviewed a draft document for the FCC to re-charter the Network Reliability and Interoperability Council. In the following three areas and others, he explained the work that NRIC V would accomplish:

(1) Y2K Review;

(2) Network Reliability; and

(3) Network Interoperability

In response to Mr. Hatfield’s presentation, Ray Albers sought and received confirmation that there would be an opportunity for interested persons to comment on the draft new charter before FCC adoption. Mr. Albers expressed particular concern that, under Section 2(d) of the proposed charter, a committee of the proposed NRIC V would develop, refine, and modify best practices. He noted that this was the work already accomplished by the best practices committee of NRIC IV and that any decision to repeat that work should at least await the release of that subcommittee’s final report.

Mr. Hatfield added that the document was a draft intended to stimulate just such discussion and other feedback from interested parties. On the particular issue of whether NRIC V would continue to examine best practices, Mr. Hatfield submitted that continued emphasis on such practices remains important because of changes in networks and because of continued concerns whether all those in the industry continue to follow such best practices.

V. Closing Remarks and Adjournment

Michael Armstrong, Co-Chair of NRIC IV, invited any further questions or other comments from the floor. Hearing none, he thanked everyone. He added that if anything further needed to be brought to the attention of any NRIC committee or focus group, John Pasqua at AT&T should be contacted and that Mr. Pasqua would coordinate the effort.

Michael Powell, Co-chair of NRIC IV, thanked Michael Armstrong for his many contributions to the success of NRIC IV.

Mr. Armstrong adjourned the meeting at 5:15 PM.