The Commission proposes to extend outage reporting requirements to interconnected Voice over Internet Protocol (“VoIP”) service providers and broadband Internet Service Providers (“ISPs”) to ensure that 9-1-1 emergency systems work well and are reliable. The National Association of Telecommunications Officers and Advisors (“NATOA”) and the National Association of State Utility Consumer Advocates (“NASUCA”) submitted comments in support of the proposed outage reporting requirements. PK and OTI agree with NATOA and NASUCA that the Commission should impose outage reporting requirements on VoIP and broadband ISPs.

As NASUCA explained, the Commission needs a mechanism to address the problems that arise when consumers lack access to emergency services, and the outage reporting requirements will act as a necessary mechanism. Increasingly, consumers substitute interconnected VoIP and broadband internet services for traditional phone service. VoIP and broadband users rely on the communication services not only to complete many daily tasks, but also to connect to emergency services in times of danger. When VoIP and broadband internet service providers have outages, their customers cannot call for emergency help. At present, consumers, safety officials, and the Commission do not know how VoIP and broadband ISP networks operate or how to prevent future outages because there is minimal data on both outages and service providers’ implementation measures for reliable networks. One thing is certain— the system for outage reporting that currently exists for telephone service providers reduced the number of lost 9-1-1 calls. Therefore, new outage reporting requirements should also reduce lost 9-1-1 calls and improve public safety.

Outage reporting requirements will not only benefit the public in emergency situations, but they will also benefit the public and industries in non-emergency situations by providing reliable networks. The VoIP and broadband internet services need a measurement of reliability because consumers use the services not only for emergencies, but also for many non-emergency purposes such as education and economic activity. Industries benefit from current regulations, which measure reliability by tracking and analyzing data, because the data analyses “have led to the development and refinement of industry best practices” and fewer outages.” Outage reporting requirements for interconnected VoIP and broadband internet service providers will generate the data necessary to measure network reliability and improve the network to give subscribers the low risk of outages that they deserve. National security, safety and past successful results from reporting requirements justify the implementation of the outage reporting requirements for interconnected VoIP service providers and broadband ISPs.