Public Knowledge submitted these Comments in response to the Federal Communications Commission’s Public Notice of Proposed Rulemaking, In the Matter of Resilient Networks, Amendments to Part 4 of the Commission’s Rules Concerning Disruptions to Communications, and New Part 4 of the Commission’s Rules Concerning Disruptions to Communications.
The transition from legacy telecommunications systems to modern networks rooted in internet technology has revolutionized the performance and variety of services available to consumers. But these changes have come at a cost. Deployed with little or no regulatory oversight, these modern networks suffer from an array of resiliency and security challenges not found in legacy systems.
Keeping Americans connected, especially during emergencies, requires concrete and measurable actions before, during, and after an emergency, including mandatory roaming arrangements, mutual coordination, power backup, and thorough data collection. These commonsense measures, most of which the FCC has already proposed in its various post-outage reports, should apply to all service providers. The Commission can incentivize participation in these resiliency efforts through regulatory fee credits and establish new programs and measures to support disaster relief efforts.