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Harold Feld Testimony On Building Resilient Networks

June 22, 2021

Public Knowledge makes the following recommendations for Congressional action:

1. Provide the information necessary for proper planning and for the market to reward investment. Direct the FCC to combine the National Outage Reporting System (NORS) NORS and the Disaster Information Reporting Service (DIRS) into a single, publicly available database that permits the public to identify carrier performance on a granular level. Direct the FCC to conduct a full report after every significant outage.

2. Provide clear authority to the FCC and the States. Clearly empower the FCC and states to create necessary rules for network reliability, cybersecurity, and cooperation among relevant stakeholders. Congress should direct DHS to fully integrate the FCC into its disaster response in line with the GAO recommendations. Additionally, Congress should require the FCC and the Department of Energy to develop enforceable guidelines for cooperation between power companies and communications providers.

3. Create metrics necessary to set standards and promote accountability. Require the FCC, National Telecommunications Information Administration (NTIA), National Institute of Standards (NIST), and the Department of Homeland Security (DHS) to develop suitable metrics to measure reliability and resiliency for wireline, fixed wireless, mobile terrestrial wireless, and satellite networks.

4. Promote sustainability and avoid environmental degradation. Require further study to create recommendations for environmentally friendly and sustainable solutions, and to reduce existing practices that risk degrading the environment.

5. Make federal and state assets available in disaster recovery. Permit and encourage the federal government and state governments to make available in an emergency communications resources such as fiber, spectrum, operating government networks, or other assets to communications providers to restore communications to the general public.

6. Fund network upgrades that promote reliability. Provide federal money to pay for necessary upgrades to communications networks to enhance reliability. In particular, provide funding to replace aging copper networks with modern fiber networks built to modern resiliency standards. Where legacy carriers wish to retire their copper networks without replacement, create incentives to sell these networks to alternative providers (including state or local governments, community anchor institutions, and cooperatives) willing to provide wireline service. Additionally, federal grant programs that fund deployment should include mandatory reliability metrics.

7. FCC studies that address the specialized needs of specific communities. Require the FCC to report to Congress on the special needs of island communities, geographically isolated communities, Tribal lands, low-income and traditionally marginalized communities of color, and communities in environmentally sensitive areas. The report should include steps the FCC will take under its existing authority to address identified special needs, and recommendations to Congress for any other necessary action.