When natural disasters like hurricanes, earthquakes, and wildfires strike, people rely on communications technologies to stay informed, summon help, and contact authorities and loved ones. Promoting this essential public safety function is one of the core, founding principles of the Federal Communications Commission. Therefore, you might imagine that there are rules and regulations ensuring that our essential wireless communication infrastructure remains operable during a disaster. Unfortunately, you would imagine wrong.
Over the last several years, hurricanes, wildfires, and other increasingly violent natural disasters have repeatedly devastated our telecommunications networks. Industry efforts to prevent outages and restore service have been improving, but have proven inconsistent and unreliable. For example, the day after Hurricane Ida made landfall, 52% of Louisiana’s 2,700-plus cell sites were out of service leaving first responders unable to access AT&T’s so-called “First Responder Network.” Failures of this kind prompted the FCC to launch a new proceeding asking whether it should adopt new rules to ensure that there are minimum standards for wireless network resiliency. While service providers remain divided on the best path forward—and are fighting against the FCC’s proposals for common-sense rules to keep networks operating during disasters—Public Knowledge supports the FCC’s efforts to address gaps within its current resiliency and reliability rules and believes the FCC must act decisively to make these rules mandatory and enforceable.
For years, companies have touted their voluntary and non-binding “Wireless Network Resiliency Cooperative Framework” as a substitute for real rules. This framework has now existed for nearly six years, yet the major wireless service providers still find themselves unable to agree on even the most basic elements of how to coordinate and cooperate with one another during an emergency.
In recent comments filed with the FCC, Public Knowledge highlighted how major wireless service providers remain at odds with one another on some simple—yet vitally important—emergency response elements. For example, the voluntary Framework’s first objective was to establish rules for roaming agreements, allowing customers of one provider to use another provider’s network where there were service interruptions or to distribute high volumes of calls. Yet, despite six years of work under the voluntary Framework, AT&T still does not guarantee to offer roaming within the first seven hours following a disaster, while another major provider, T-Mobile, argues that networks should activate roaming as soon as possible. For smaller, regional carriers the roaming problem is even worse. Smaller local carriers have struggled to negotiate emergency roaming agreements with larger providers. Without roaming agreements, communities struck by natural disasters face real danger. Preserving a community’s connectivity during a crisis is essential for first responders and so that people can call 911, get information about evacuations, or alert their loved ones that they are safe.
Wireless service providers have had years to voluntarily establish rules to ensure network resilience and reliability during disasters, but they have failed to reach any consensus on these critical issues. Meanwhile, government experts have identified three simple changes that will improve network resiliency. The FCC and the Department of Homeland Security both routinely and extensively study the performance of communications infrastructure in the wake of disasters, and those studies point to three primary policy changes that are needed: (1) additional backup power capabilities to keep infrastructure online, (2) preemptive and reciprocal roaming arrangements to keep people connected when infrastructure does go down, and (3) more substantial reporting requirements so that decision-makers can continue to learn and improve. There are also other important actions the FCC should take, like integrating TV and radio broadcasters—especially local ones—into disaster planning.
The vulnerabilities in the current voluntary Framework are as numerous as they are severe; it is now time for providers to stop fighting against common sense rules aimed at protecting our communities and for the FCC to adopt real binding rules that ensure meaningful resilience and timely restoration of America’s communications networks when they are needed most.