By Donny Jackson

FCC commissioners this month are scheduled to consider new rules regarding the Disaster Information Reporting System (DIRS) and the Network Outage Reporting System (NORS), as well as a proposal seeking comments whether FirstNet should have reporting obligations and whether deployable coverage should be reported.

Under the proposed new rules, all cable, wireless, wireline and interconnected voice-over-IP (VoIP) providers would be required to report outages when the DIRS is activated and must provide the FCC with a final report within 24 hours of DIRS being deactivated. The proposed rules also would suspend NORS reporting obligations for providers subject to DIRS, according to the FCC.

In the further notice, the FCC seeks comments whether FirstNet should be subject to NORS and/DIRS reporting. FirstNet currently is not required to file such outage reports, but its nationwide contractor—AT&T—does have to fulfill these obligations. The further notice also asks whether commenters believe “mobile recovery assets”—for example, deployable coverage solutions like cells on wheels (COWs) and cells on light trucks (COLTs)—should be noted in coverage assessments for NORS and DIRS.

In addition, the further notice proposes that DIRS reporting obligations be expanded to include broadcast, satellite and broadband providers.

FCC Chairwoman Jessica Rosenworcel noted the proposed rules and a further notice of proposed rulemaking in a blog she released last week outlining the preliminary agenda items for the Jan. 25 open meeting.

“Fast and reliable reporting of communications outages during disasters can help emergency-management personnel make smarter and faster decisions when they matter most,” according to Rosenworcel. “It can also offer valuable lessons to prevent service disruptions in the future.

“The Commission will consider rules to transition the current voluntary outage reporting structure to a mandatory structure for certain communications providers, as well as proposals to expand reporting from other providers.”

Adopted in 2007, the DIRS reporting of commercial network outages has proven to be a useful tool to help the public gauge carriers’ progress in restoring terrestrial communications networks to “normal” status after a disaster. However, many industry observers have questioned whether the daily DIRS maps may create an overly negative perception about wireless coverage in a given geographic area, because it does not reflect whether service providers have provided connectivity through deployable solutions like SatCOLTs in an area.

“We tentatively conclude that, if information regarding the location of mobile recovery assets were required to be supplied in DIRS, the Commission would obtain this information more efficiently and uniformly across providers than is currently the case, likely leading to better public safety outcomes,” according to the FCC’s draft further notice. “We seek comment on this conclusion. Should we require such reporting? If so, which subject providers should be required to provide such information?

“If reporting is adopted, we seek comment on what types of mobile assets should be reported (including COWs and COLTs) based on provider type, the level of granularity for which location information should be reported (e.g., on a zip code or street address basis) and on whether this information should be reported directly in existing DIRS forms or through other means. Should information on the time of deployment, coverage, or available power for such assets be reported as well?”

A potential wrinkle to the relevance of NORS and DIRS reporting is the expected development of satellite-direct-to-phone (Sat2Phone) technology that leverages low-Earth-orbit (LEO) satellites as cellular towers in space. If deployed as designed in cooperation with a carrier—the business model being pursued by companies like AST SpaceMobile, Lynk and SpaceX—Sat2Phone could provide seamless coverage to users outside a terrestrial-network coverage footprint in virtually all outdoor locations within the next several years.

Commercial wireless carriers have provided the FCC with network-outage information for years, but the requirement has not been extended to the FirstNet Authority’s nationwide public-safety broadband network (NPSBN). The NPSBN is being built and maintained by AT&T, which is subject to NORS and DIRS requirements, which has allowed some officials to make inferences about the health of the terrestrial FirstNet system, according to the language in the proposed further notice.

“FirstNet is not currently subject to NORS or DIRS outage-reporting obligations and has never participated in NORS or DIRS on a voluntary basis,” according to the further-notice draft.

“However, its importance to the public-safety community and the unique customer base it serves leads us to consider whether outage reporting is necessary and appropriate to provide a more complete picture of the overall health and resiliency of an increasingly important component of the nation’s communications infrastructure, particularly during specific disasters during which FirstNet is specifically designed to provide more robust outcomes.”

One question noted in the further-notice draft is whether the FCC has the authority to require such network-outage reporting from the FirstNet Authority, which was established by Congress in 2012 with statutory reporting requirements. This law mandated that the FCC grant the FirstNet Authority a license to the 20 MHz block of Band 14 spectrum in the 700 MHz band, but the FirstNet Authority is housed within the National Telecommunications and Information Administration (NTIA) branch of the federal government.

“Do the Commission’s general Title III authorities, coupled with section 6003(a) of the Public Safety Spectrum Act, support our ability to seek information beyond FirstNet’s statutorily mandated reports?” the further-notice draft asks. “What other provisions might support such reporting? What quantitative estimates of potential costs and benefits of this integration are available? What would be additional improvements to public safety and other measures of welfare due to specifically reporting by FirstNet? How would the magnitude of these benefits compare to the benefits estimated in the Second Report and Order?”