Tech Topic 15: Outage Reporting Systems

Our last topic addressed the use of diversity routing to provide alternative connectivity between a PSAP and its local switching centers. In this way, redundant - albeit by different means - routing is present to preclude the PSAP from losing its connections to the local network. Redundancy is one of the core concepts for public safety communications networks and it also contributes part and parcel to the resiliency - another core concept - of public safety networks, so that communications systems are always available to support the public safety user. This topic addresses situations when communications fail. This includes situations where there are network failures that affect redundancy, but do not result in a loss of service to the end-user. It introduces the systems that are used by the Commission to document large scale outages and how these reports are used to form the basis for analysis of overall system performance.¹

The Commission's efforts to promote the reliability and security of the nation's communications infrastructure include gathering and analyzing information regarding communication network service disruptions that reach certain thresholds. In 2004 the Commission adopted a Report and Order and Further Notice of Proposed Rule Making that required wireless, paging, and satellite service providers to report service disruptions. ² Wireline and cable service providers were already subject to network outage reporting requirements. The Report and Order enhanced the Commission's reporting requirements and provided for the electronic filing of all outage reports. Because the record did not completely address the reporting of service disruptions for airports, the Commission sought comment in a Further Notice of Proposed Rulemaking on the extent to which, if at all, the FCC should modify its reporting requirements for airports.

The new rules became effective on January 3, 2005. In sum, the FCC requires wireless, wireline, cable, and satellite communications providers of switched voice and paging communications to electronically report information about significant disruptions or outages to their communications systems that meet specified thresholds set forth in Part 4 of the FCC's rules (47 C.F.R. Part 4). The Part 4 rules also require communications providers to report certain communications disruptions affecting specific aspects of 9-1-1 communications, special offices and facilities (e.g., major military installations) and communications at certain classes of airports. Given the sensitive nature of the Part 4 outage data to both national security and commercial competitiveness, this information is presumed to be confidential and protected from routine public disclosure. The rules were introduced along with a new secure, web-based reporting system, the Network Outage Reporting System (NORS). ³ The Public Safety and Homeland Security Bureau (PSHSB) coordinates with the FCC's Enforcement Bureau to ensure compliance with the outage reporting obligations. NORS and the outage reports it collects were used effectively in the Commission's development of situational awareness in the early hours of Hurricane Katrina. It has also revealed a number of reliability issues that have been passed to an industry body, the Network Reliability Steering Committee (NRSC), a subcommittee of the Alliance for Telecommunications Industry Solutions (ATIS), for further study and resolution.

The Report and Order established a common metric for use across all communications platforms to determine the general outage-reporting threshold criteria. This common metric is the number of user-minutes potentially affected by an outage.

Communications providers that experience a reportable outage must submit a Notification, followed by an Initial Report, and then a Final Report. The Notification must be submitted within 120 minutes of discovery of a reportable outage. The Initial Report must be filed 72 hours after discovery of a reportable outage. The Initial Report must contain all pertinent information then available about the outage. The Final Report must be filed within 30 days after discovery of a reportable outage and must contain all pertinent information then available about the outage as well as any information not contained in or that has changed from the Initial Report. The person submitting the Final Report shall be authorized by the communications provider to legally bind it to the truthfulness, completeness and accuracy of the information in the report. The person submitting the Final Report must also attest to these criteria.

Aggregate reliability statistics based on NORS data are reviewed with industry on a regular basis in an effort to facilitate a voluntary process of continuous improvement in network reliability and resiliency. For example, recently the FCC analysis team discovered that certain types of transport network outages were higher than would otherwise be expected. After working with industry via the NRSC, the incidence of these outages has dropped sharply.⁴

Accordingly, NORS provides a means to collect outage-related information after the fact and then identify and address any short-comings on a going-forward basis. Thus, NORS is not intended to provide a complete portrait of communications infrastructure during a major disaster. For example, NORS is not designed to keep track of the ongoing status of telecommunications equipment in a disaster area. In addition, NORS does not cover some of the communications assets that are very important during a disaster such as broadcast stations or CATV systems. Further, during disasters, there is a significant correlation between the status of communication assets and the availability of commercial power. Service providers subject to NORS do not report on the status of equipment that is on back-up power but is still functioning. In summary, NORS is not a suitable vehicle to meet the response requirements to support national security or emergency response efforts.⁵

In the event of a major incident or disaster, the FCC and the Department of Homeland Security's National Communications System (NCS) need accurate and timely information regarding the status of communications services in the incident area, particularly during restoration and recovery efforts. To address this need, the Commission established a Disaster Information Reporting System (DIRS). DIRS is a voluntary, web-based system that communications companies, including wireless, wireline, broadcast, and cable providers, can use to report communications infrastructure status and situational awareness information during times of crisis. PSHSB launched DIRS on September 11, 2007⁶ following lengthy coordination with industry.

DIRS is activated at the direction of NCS, typically when it deems there to be a major disaster or incident affecting the public communications networks. When activated, communications providers voluntarily submit DIRS information electronically to the FCC concerning outages of:

Switches
Public Safety Answering Points (used for receipt of 911 calls and dispatch of first responders)
Interoffice facilities
Cell sites
Broadcast stations
Cable television systems

The information is collected and verified by PSHSB staff then passed as situational reports to the NCS for consideration by national level authorities in responding to the crisis and establishing situational awareness for the event. The timely submission of outage information in these circumstances is critical. As with the information collected by NORS, the outage information collected under DIRS is presumed confidential.

Following Hurricane Katrina, the Commission has been very proactive in seeking information from its licensees in the aftermath of a disaster or other crisis. The Commission has also sought information from public safety agencies and health care facilities. This information has helped the Commission in its efforts to assist carriers and licensees in recovering from outages and returning their systems to fully operational status.

In sum, the current outage reporting processes that are used by the FCC consist of the NORS-based outage reporting requirements as well as the voluntary status reporting accomplished via DIRS during and in the aftermath of crisis situations. These systems form the basis for forward-looking improvements in network reliability and resiliency and situational reporting by the Commission during crisis or other emergency situations.

¹ The import of Section 1 of the Communications Act of 1934 in chartering the Federal Communications Commission Congress is clear, calling for the establishment of an agency, "for the purpose of the national defense, for the purpose of promoting safety of life and property through the use of wire and radio communication, … there is hereby created a commission to be known as the 'Federal Communications Commission'." See 47 U.S.C. § 151. In 2006, the Commission established the Public Safety and Homeland Security Bureau "to promote a more efficient, effective and responsive organizational structure and to better promote and address public safety, homeland security, national security, emergency management and preparedness, disaster management, and related issues." See Establishment of the Public Safety and Homeland Security Bureau, Order, 21 FCC Rcd 13655 (2006). See also Amendment of Part 0 of the Commission's Rules to Delegate Administration of Part 4 of the Commission's Rules to the Public Safety and Homeland Security Bureau, Order, 23 FCC Rcd 1611 (2008).

² See New Part 4 of the Commission's Rules Concerning Disruptions to Communications, ET Docket No. 04-35, Report and Order and Further Notice of Proposed Rule Making, 19 FCC Rcd 16830 (2004).

³ See the FCC's NORS web page at http://www.fcc.gov/pshs/services/cip/nors/nors.html

⁴ See the NRSC of ATIS web page at http://www.atis.org/nrsc/index.asp.

⁵ This is especially important in light of normal network operational reporting systems employed by most providers that use telemetry systems to report and monitor outages of major equipments and systems to their network operations centers (NOCs). Since the carriers employ much more detailed operational status reporting in their operations centers, they have available much more direct and timely status of the condition of their networks. This timely information may or may not meet the threshold conditions of NORS reporting requirements, but more importantly the up to date status of the condition of their network is extremely important in a crisis.

⁶ The FCC's DIRS web page can be viewed at http://www.fcc.gov/pshs/services/cip/dirs/dirs.html. See the public notice announcement of DIRS at http://fjallfoss.fcc.gov/edocs_public/attachmatch/DA-07-3871A1.pdf.