The US regulator has updated a number of resiliency standards, although unlike in some countries, power back-up requirements have yet to return to the forefront of debate
Extended use of the ‘Disaster Information Reporting System’
On 25 January 2024, the Federal Communications Commission (FCC) published a series of rule changes to expand the required use of the Disaster Information Reporting System (DIRS) by telecoms operators. American operators are currently required to report outages on an ongoing basis to the Network Outage Reporting System (NORS) and provide operational status reports should the FCC activate the DIRS during a disaster. The recent rule changes now make participation in the DIRS mandatory for cable communications, wireline, wireless, and interconnected VoIP providers, which were previously invited to participate in the programme on a voluntary basis. The FCC will also now require operators filing with the DIRS to submit an incident summary within 24 hours of the deactivation of the system. The regulator is further consulting on extending follow-up reporting requirements to also require operators to submit after-action reports detailing how their networks fared during a given emergency or disaster event.
DIRS rules follow the ‘Mandatory Disaster Response Initiative’ adopted in 2022
Changes to the requirements of the DIRS system are only the latest in work the FCC has done in recent years to improve network resilience during times of emergency or disaster. In June 2022, the FCC adopted the Mandatory Disaster Response Initiative (MDRI), which was based on the voluntary Wireless Resiliency Cooperative Framework created by industry in 2016. The MDRI outlines a set of required preparedness measures and emergency response actions for mobile operators including:
Facilitating roaming during network outages, where technically feasible;
Establishing mutual aid agreements between operators for physical asset sharing and coordination before and during disasters;
Improving municipal preparedness in coordination with local governments;
Increasing consumer readiness and preparation; and
Improving public communication of restoration times through publication of DIRS data.
Mobile operators are also required to test their roaming capabilities under the MDRI, to ensure readiness to comply with roaming requirements in an emergency situation. Under the MDRI, the FCC also expanded the emergency scenarios in which the programme would be automatically activated to include the activation of the DIRS by the FCC as well as activation through the Federal Emergency Management Agency or local authorities declaring states of emergency.
The legacy of Hurricane Katrina continues to inform network resilience requirements
Following numerous failures in emergency response during Hurricane Katrina in 2004, the FCC launched a comprehensive review of network resilience and disaster response policy, known as the Katrina Panel. In addition to the establishment of the DIRS, the Katrina Panel also recommended the adoption of standards for power back-up, also referred to as battery back-up, for mobile network operators. While the initial requirements for power back-up were limited to emergency communications systems (911 service providers), the FCC did also attempt to enhance power back-up rules to require operators to provide eight hours of power at remote sites. That rule was dropped following extensive protest from industry, although some states have since adopted their own localised requirements for power back-up. Notably, California, which is particularly vulnerable to wildfires during which electrical lines are often disabled to limit spread, requires 72-hours of power back-up at cell towers. As vast swaths of the United States continue to face new or exacerbated threats of extreme weather such as wildfires and hurricanes, federal and state-level scrutiny of mobile network resilience is only likely to grow.
