Press Release

SVP Harold Feld to Testify Before FCC on Network Resiliency

October 25, 2021
newspaper

Public Knowledge Senior Vice President Harold Feld will testify before the Federal Communications Commission this Tuesday, October 26 at 11am ET. His testimony in the Field Hearing on Disaster Communications will explain fundamental changes the FCC, other agencies, and the private sector must make for more resilient networks in the face of increasingly violent weather events.

You can view Harold Feld’s written testimony here.

The following is an excerpt from the testimony:

“We must fundamentally change our approach to how we view network preparedness and crisis response. At the moment, each player in the communications environment is on its own, responsible for its own network hardening and response. The existing wireless framework reflects this mentality. First, it is wireless only – despite the fact that wireless communications depend on functioning wireline broadband networks for backhaul. One of the important changes in the information made publicly available during Ida through the Disaster Information Reporting System (DIRS) was more granular data as to why wireless towers were down. This allowed the public to see and understand that it is not just a question of power, or physical destruction, but also a question of functioning wireline networks to provide communication from the cell tower to the network. We cannot have reliable wireless communications in an emergency without expanding the framework to include the entire communications ecosystem.

“More importantly, the current Wireless Communications Framework makes mutual aid and assistance between networks a matter of last resort. Only after a network has done everything in its power to stay online and come back online, and only if it will not inconvenience the functioning network, will networks offer each other mutual assistance. The attitude continues to be ‘everyone is on their own.’ But one of the greatest strengths of our modern communications network is its redundancy and adaptability. Rather than one wireline network hardened to maximum reliability (and collecting the cost through a regulated rate), we have multiple networks that interconnect and can interoperate with one another. Any engineer will tell you that redundancy is a critical part of reliability, but we continue to require every network to behave as if it were the only player in the game.

“Ideally, coordination and mutual assistance would begin before the disaster hits so that we can minimize the interruptions to vital communications throughout the crisis, rather than wait until the disaster has passed. State governors and the Federal Government frequently declare a state of emergency before a hurricane or other severe weather event so that emergency services can start and preparations can begin. We need the same for the telecom environment. Ideally, emergency roaming agreements and other coordination of traffic load and response would begin as soon as a state of emergency or other imminent disaster trigger occurred. Coordination and mutual assistance would continue until the FCC ascertained that the DIRS database was no longer necessary.”