On April 7, 2011 the FCC released a Notice of Inquiry, initiating "a comprehensive examination" of the reliability and resiliency of our nation's telecommunications infrastructure, yet another inquiry with ties to the 2010 National Broadband Plan (PS DN 11-60; PS DN 10-92; EB DN 06-119). Through this process, the FCC will examine issues about maintaining continuity of telecom service in natural and man-made disasters and the possibility of mandating standards and requirements for network reliability and resiliency. During the UTC Smart Grid Policy Summit this week, the comment was made that it often takes a disaster to get industries (in general) motivated to improve safety, reliability, asset protection, etc. The situation in Japan has clearly influenced the FCC to get a jump start on the examination of telecom network continuity, reliability, redundancy and resiliency in the face of tragedy. I believe this NOI is a timely and necessary effort, but I worry about the implications of mandating technological and regulatory requirements on small telecom providers. I do not recommend that the FCC piles on any specific and potentially very expensive regulations while simultaneously attempting to reign in subsidies. Additionally, it is never a good idea to mandate specific technologies or protocols. By the time regulatory lag is taken into consideration, something that is an emerging technology today might be a faint flicker of light by the time the rules are implemented. Furthermore, mandating technology and protocol standards can impede innovation and pick industry winners to the detriment of other viable solutions.
For rural telecom service providers, ensuring reliability, resiliency, redundancy and network continuity goes beyond disaster preparedness. I see this issue from a business perspective--rural providers can help attract new businesses to rural areas by ensuring their networks meet the highest standards of "R&R." At the NTCA Legislative and Policy conference last month, one of the attendees from Iowa described a very memorable situation that his RLEC faced recently: a major business was interested in coming to his company's service area, but the business had very high requirements for network redundancy. The provider sought support from the FCC, but the FCC basically told them "its not our problem" Well, apparently the FCC is now making it "their problem" to investigate network R&R, continuity and redundancy issues. In addition to needing reliable and resilient networks to attract new businesses--such as industrial, financial, health care and utility companies--to rural areas, rural providers also need to think about their vulnerability to natural and man-made disasters. Unfortunately, rural areas are extremely vulnerable to tornadoes, floods, crippling ice and snow storms, and other disasters that not only make communications especially critical for public safety, but make it especially challenging for small companies to respond to network malfunctions. What happens when service goes down during a tornado, but all of an RLEC's key employees too far away to respond quickly or caught in the destruction themselves? Furthermore, consumers are beginning to rely more and more on Internet applications like Twitter and Facebook to communicate during times of distress--how do RLECs ensure that their customers have multiple avenues of access to emergency responders and their friends and family during a disaster?
I hope that rural providers plan to participate in this NOI and describe the unique challenges their companies face in providing network R&R. The FCC in fact is seeking input on this exact topic: "We are interested in gathering information about any other factors that have an impact on the ability to maintain or restore communications operations, including those which might be unique to specific circumstances. For example, which of these factors might be more significant with respect to smaller carriers, carriers serving rural areas, or those serving tribal lands? Are there sufficient numbers of properly trained technical personnel to deploy over widespread disaster areas, and if not, is this a factor in not being able to maintain or restore operations of communications networks during emergencies? To what extent do these issues apply to communications infrastructure in geographically remote locations? Do communications service providers have contingency plans in place if key personnel are unavailable to respond to a situation, and if so, how are such contingency plans implemented?" (FCC, 2011 pg. 8, para. 20). I believe rural telecom providers have a great opportunity here to tell the FCC exactly how they protect their network assets and ensure service continuity in the face of disaster, as well as communicate what they may need in order to maintain high standards of R&R going forward in the future with exploding data capacity demands and changes in consumer communication trends.
The FCC is curious about whether it would be better to implement mandatory or voluntary requirements for R&R, redundancy and network continuity. As I mentioned above, I don't think required standards or mandatory compliance is a good idea--I never think mandated technologies or burdensome regulatory requirements are a good idea for RLECs. The FCC asks if requiring emergency response plans would be a wise solution, and I think this should be about as far as they should go with requirements. I believe the market should determine which technologies and protocols are best, not the government. I also do not think the FCC would be able to encompass the diverse variety of communications providers and their equally diverse networks, customers, assets and infrastructure under a single set of regulatory or technology requirements. The regulatory lag in determining the best requirements for everyone would be extremely onerous, then there would be the issue of setting a timeline for compliance and enforcing noncompliance--this could all take years--and a major disaster is not going to wait around for regulations to be implemented.
I am very interested to hear from stakeholders on these issues. I will be paying specific attention to responses from both rural telecom providers and utilities, who have a key role in this inquiry if utility and commercial telecom providers have any intention of converging for smart grid deployment. I hope to see a lot of rural telecom providers submitting comments, which are due July 7, 2011.
Speaking of comments, USF reform comments regarding the Connect America Fund are due next week--I will be reading and summarizing as I did with the ICC comments. I hope to have something published by Wednesday, April 20.
Finally, Rural TeleCommentary hit its 1,000th pageview yesterday (with 101 total pageviews yesterday alone)! I am delighted about how well received this blog seems to be--I never expected it would become so popular. I have had readers from over 25 countries around the world--in every continent except Africa and Antarctica, and I'm starting to make headway with getting linked from other prominent websites and blogs. Thank you to all of my readers! I hope you are all finding my articles interesting and useful.
Cassandra Heyne
ruraltelecommentary@gmail.com
Edit 4/18/11: I caught this informative blog post by Gabriel Marcos of Global Crossing today which very clearly explains the meaning of "redundancy." Looks like he is doing a series of posts on the meanings of redundancy, resiliency, contingency, and continuity.
Gabriel Marcos (Global Crossing) on the meaning of Redundancy
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