VoIP Outage Reporting Makes May FCC Meeting Agenda

Posted on May 9, 2011 by Steve Augustino

It has taken nearly a year since the FCC's Public Safety Bureau first started laying the groundwork, but the FCC is poised to consider expanding its outage reporting rules to cover interconnected VoIP communications and broadband Internet access providers.  The Commission will consider a Notice of Proposed Rulemaking to extend the outage reporting rules at its May 12 Commission Meeting. 

This item has been moving forward under the radar of most VoIP and broadband providers.  As we told you back in July, the Public Safety Bureau sought comment on how to apply its outage reporting obligations to interconnected VoIP services and broadband Internet access services.  The Public Notice produced only a handful of comments and replies.  Even in the few days before the FCC announced its meeting agenda -- typically a very busy time for those with an interest in an order -- only three ex parte notices were filed on the proposal.  The minimal level of interest won't last long, however.  Once the NPRM is released this week, a much larger universe of interested parties is likely to appear. 

Note:   Also on the May 12th agenda are proposed revisions to two international service compliance obligations -- the FCC's settlements policy and its Part 43 reporting requirements for international traffic.  International carriers should pay close attention to both items. 

 

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FCC Begins Groundwork to Extend Outage Reporting Obligations to Broadband and Interconnected VoIP Providers

Posted on July 2, 2010 by Steve Augustino

Despite issues over the FCC's jurisdiction in light of the Comcast decision, the FCC's Public Safety Bureau took a step toward possible extension of the FCC's outage reporting requirements to broadband service providers and providers of interconnected VoIP services.  In a July 2 Public Notice, the Bureau seeks comment "in advance of" a possible Commission rulemaking proceeding.  The comment request in many ways presumes that the outage reporting rules should apply, and asks a number of questions about how they could apply and what changes might be necessary in light of the different technologies involved.  Clearly, the Bureau is seeking to do its homework before the Commission initiates a rulemaking proceeding.

In addition to general questions about whether the rules should be applied to broadband or interconnected VoIP providers, the Public Notice seeks comment on a number of specific questions, including:

Interconnected VoIP

  • What constitutes outages for a service provided by an interconnected VoIP provider?  For example, we know anecdotally that interconnected VoIP service users can collectively experience an outright loss of service comparable to the loss of service experienced by traditional time division multiplex (TDM)-based users.  Are there also levels of service degradation specific to interconnected VoIP service that should be considered?
  • Would an outage reporting requirement based on some threshold [as applies to telecom providers] also be appropriate for interconnected VoIP service providers? If so, what would be a reasonable reporting threshold? 

Broadband Internet Access

  • How should the differences between traditional networks and the packet switched Internet alter what constitutes a reportable ISP outage in the Commission’s Part 4 rules? Should the Commission alter its view of a reportable outage to include events that result in significant degradations to performance as perceived by end-users?
  • What special considerations should be given to services provided via Internet access to Public Safety Answering Points (PSAPs)?
  • If the Commission were to determine significant performance degradations to be outages that should be reported by broadband ISPs, how should the Commission define a significant degradation so as to trigger the reporting requirement? For example, would a threshold for Internet service based on “generally useful connectivity” be an appropriate construct? If so, how should the Commission define “generally useful connectivity” so that an objective reporting threshold can be established? 
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