Improving Network Resiliency

The FCC, in Docket FCC 22-50, is requiring changes that it hopes will improve the reliability and resiliency of cellular networks to be better prepared for and respond better to emergencies. The order cites recent emergencies like Hurricane Ida, the earthquakes in Puerto Rico, severe winter storms in Texas, and worsening hurricane and wildfire seasons. This makes me wonder if we might someday see similar requirements for ISPs and broadband networks.

The FCC wants to leverage the industry-developed Wireless Network Resiliency Cooperative Framework as a starting point for introducing new rules it is calling the Mandatory Disaster Response Initiative (MDRI).

The new rules first codify and make mandatory the existing voluntary industry framework to apply to all facility-based mobile wireless providers. That framework includes five principles: (1) providing for reasonable roaming under disaster arrangements when technically feasible; (2) fostering mutual aid among wireless providers during emergencies; (3) enhancing municipal preparedness and restoration by convening with local government public safety representatives to develop best practices and establishing a provider/PSAP contact database; (4) increasing consumer readiness and preparation through development and dissemination with consumer groups of a Consumer Readiness Checklist; and (5) improving public awareness and stakeholder communications on service and restoration status through FCC posting of data on cell site outages on a county-by-county basis.

The new rules require cellular network owners to regularly test its emergency capabilities. This is in response to network failures in some of the disasters mentioned| in the order where network owners were not prepared to deal with an emergency. The new order further requires cellular network owners to file a report with the FCC after every declared emergency to describe in detail how the carrier ended up responding to the emergency.

It’s a change that is overdue because, as the FCC notes, lives are dependent during an emergency on a functioning cellular network. It’s a shame that the FCC has to make such an order. There was a time when big carriers and telcos took social obligations like emergency preparedness seriously and took pride in the ability to respond to emergencies. I can recall decades ago how big telcos would publicize how quickly they were able to restore service, even after disasters completely destroyed central offices and networks.

But as the number of cellular carriers has grown and as the industry is getting more competitive and seeing lower margins, functions like emergency preparedness, that don’t contribute to the bottom line slowly slide through lack of attention and funding.

I suspect at some point that we’ll see similar rules for broadband networks. I’m aware of numerous examples in recent years where failures in the backhaul fiber network have isolated towns from the Internet. I’ve mentioned Project Thor in Colorado a few times, which is a municipally-driven initiative to connect cities in northwest Colorado by fiber, which was prompted by repetitive outages on CenturyLink backhaul networks that were killing Internet access for hospitals, 911 centers, and other public safety critical infrastructure.

One issue the order doesn’t address is that there are still large parts of rural America that have poor or nonexistent cellular coverage. The coverage maps of the big cellular carriers are a joke in much of rural America. My consulting firm does surveys, and it’s not unusual in rural counties to see 30% or more of residents claiming to have no cellular coverage at their home. For these folks, a broadband connection is their lifeline to the world in the way that a cellular connection is vital to others during and after an emergency.

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