The FCC released a Notice of Proposed Rulemaking on September 27, 2013 entitled, “Improving the Resiliency of Mobile Wireless Communications Network, Reliability, and Continuity of Communications Networks, Including Broadband Technologies.” The CTIA recently submitted these comments in response. “The CTIA shares the Commission’s interest in improving the resiliency of communications networks but is deeply concerned about the Notice’s proposal because:
- The proposal will mislead the public about wireless service availability, with consumers believing that the percentage of inoperable cell sites is equivalent to the proportion of a carrier’s service territory where service is unavailable when disasters occur. It will not promote informed decision making.
- The proposal will not increase incentives to increase network resiliency. If anything, it will increase incentives for providers to restore inoperable cell sites as quickly as possible, even where that approach would undermine restoration of actual service.
- The proposal is not only arbitrary and capricious for the reasons above, but it would unlawfully interfere with wireless carriers’ First Amendment rights.
For these reasons, the Commission should instead rely principally on the ongoing CSRIC process, which has promoted network resiliency in the past and continues to focus on identifying carrier best practices with respect to network resiliency.” To read the FCC’s proposal, please click here.
Reader Interactions