By Ryan Johnston

Ensuring that a network is able to remain operational during a natural disaster is critical. To understand the landscape of our national telecommunications networks during these disasters the Federal Communications Commission (“FCC” or “Commission”) has in place two reporting systems. The Disaster Information Reporting System (“DIRS”) was created after Hurricane Katrina ravaged the gulf coast. Until recently, it was a voluntary, web-based system through which the Commission collected operational status and restoration information from communications providers. Similarly, the National Outage Reporting System (“NORS”), created in 2004, is a system through which communications providers are required to report outages in their networks that last more than 30 minutes. These two reporting systems account for all of the nation’s federal telecommunications disaster reporting. 

In January, 2024, the FCC mandated that all cable, wireless, wireline, and Voice Over Internet Protocol (“VoIP”) providers are required to report information under DIRS. Additionally, the Commission required that all entities submitting to DIRS submit a final report within 24 hours outlining current infrastructure status at the time of DIRS deactivation. 

The Commission also released a Further Notice of Proposed Rulemaking (“FNPRM”) asking for public comment on whether broadcasters, satellite providers, FirstNet, and Broadband Internet Access Services, should also be required to report to DIRS and NORS. Similarly, the Commission proposed  requiring broadcast providers to report to DIRS subject to a lower informational standard than other providers. Finally, The Commission sought comment on whether providers should be required to report the location of mobile recovery assets such as cells on wheels (“COWS”) and cells on light trucks (“COLTS”).  

On May 13, 2024, NCC filed comments with the FCC urging the Commission to require all providers of emergency response information to file under both DIRS and NORS. This ensures that the FCC will have a clear understanding of how providers are handling disasters and that all households are able to receive disaster response information no matter the technology used. 

Further, NCC highlighted that creating disparities in information submissions will continue to leave gaps in the Commission’s situational awareness and overall information gathering. Regardless of technology used, all providers should be required to submit uniform information to DIRS or NORS.

NCC also urged the Commission to mandate the reporting of mobile recovery assets such as COWS and COLTS. In doing so, the Commission can ensure that it is aware of potential areas that have been reconnected, even if only temporarily. In addition, NCC argued that providers should be required to report plans for future COW/COLT deployments and unit power levels to give the best estimates of emergency coverage possible. 

These new requirements are essential to help not just the federal government respond to natural disasters and other emergencies, but also to help state and local governments coordinate with providers and target emergency response efforts in the most efficient ways possible.

You can read NCC’s full comments to the FCC here.