ATIS Urges Commission to Ensure that Any Outage Reporting for VoIP and Broadband Service Providers Is Reasonable
WASHINGTON — The Alliance for Telecommunications Industry Solutions (ATIS) submitted comments on behalf of its Network Reliability Steering Committee (NRSC) in response to the Federal Communications Commission’s Proposed Extension of Part 4 of the Commission’s Rules Regarding Outage Reporting to Interconnected Voice Over Internet Protocol Service Providers and Broadband Internet Service Provider. ATIS to expressed its view that the proposed expansion of the Commission’s outage reporting rules to interconnected voice over internet protocol (VoIP) service providers or broadband internet service providers (ISPs) is not warranted.
To the extent that the Commission does impose such reporting obligations on interconnected VoIP service providers and broadband ISPs, ATIS notes that these obligations must be reasonable. Therefore, ATIS urges the Commission to ensure that any data collected is already readily available to reporting entities via the normal network management process. ATIS also opposes reporting obligations that would require the submission of performance characteristic data, such as latency or jitter.
For interconnected VoIP service providers, ATIS recommends that any reporting be based on similar criteria as is currently used for other service providers under Part 4 of the Commission’s Rules. However, ATIS strongly urges the Commission to modify its outage reporting criteria for all filers to reduce burdens by, among other things, requiring the submission of outage reports only for outages that last at least 120 minutes, rather than the current 30 minute threshold.
For broadband ISPs, ATIS advocates that any Commission rules be consistent with broadband reporting principles that had previously been proposed by the ATIS NRSC. For national and metro outages, ATIS recommends that any filing of outage reports be based on the discovery of an outage lasting a minimum of 120 minutes resulting in the complete loss of service and impacting a minimum of 100,000 customers.
“As the preeminent industry subject matter experts on communications network reliability and outage reporting, the NRSC has made an in-depth consideration of the Commission’s extension of Part 4 of the outage reporting rules,” said Susan Miller, President and CEO, ATIS. “Its analysis shows that voluntary, collaborative efforts are more effective than regulatory mandates in fostering cooperation, promoting innovation, and providing the flexibility needed to meet new and evolving challenges associated with ensuring communications reliability.”
Access a copy of the comments ATIS submitted to the FCC.
ATIS is the leading technical planning and standards development organization committed to the rapid development of global, market-driven standards for the information, entertainment and communications industry. More than 200 companies actively formulate standards in ATIS’ Committees, covering issues including: IPTV, Cloud Services, Energy Efficiency, IP-Based and Wireless Technologies, Quality of Service, Billing and Operational Support, Emergency Services, Architectural Platforms and Emerging Networks. In addition, numerous Incubators, Focus and Exploratory Groups address evolving industry priorities including Smart Grid, Machine-to-Machine, Connected Vehicle, IP Downloadable Security, Policy Management and Network Optimization.
ATIS is a founding partner for the 3rd Generation Partnership Project (3GPP), a member and major U.S. contributor to the International Telecommunication Union (ITU) Radio and Telecommunications’ Sectors, and a member of the Inter-American Telecommunication Commission (CITEL). ATIS is accredited by the American National Standards Institute (ANSI). For more information, please visit www.atis.org.
About the ATIS NRSC
Formed in 1993 at the recommendation of the first Network Reliability and Interoperability Council, the ATIS NRSC strives to improve network reliability by providing timely consensus-based technical and operational expert guidance to all segments of the public communications industry. The NRSC addresses network reliability improvement opportunities in an open environment and advises the communications industry through the development of standards, technical requirements, reports, bulletins, Best Practices, and annual reports. The NRSC is comprised of industry experts with primary responsibility for examining, responding to, and preventing service disruptions for communications companies. NRSC participants are the industry subject matter experts on communications network reliability and outage reporting.