Comment Letter to the FCC on Enhancing Network Resiliency During Emergencies

Ms. Marlene H. Dortch 
Secretary  
Federal Communications Commission 
45 L Street, NE 
Washington, DC  20554                                                     

Re: Resilient Networks; Disruptions to Communications, PS Docket Nos. 21-346, 15-10 86 FR 69609 

Dear Ms. Dortch: 

The U.S. Chamber of Commerce’s Technology Engagement Center (“C_TEC”) appreciates the opportunity to respond to the Federal Communications Commission’s (“the Commission”) Notice of Proposal Rulemaking (“Notice”) to enhance the reliability and resilience of our nation’s communications networks during emergencies.¹ 

America’s communications networks play an essential role in connecting Americans and are revolutionizing the way that people work, learn, seek medical care, and communicate with friends and family. The private sector plays a leading role in building, securing, and maintaining these communications networks investing billions annually, and industry sectors ranging from healthcare to financial services rely on communications networks to effectively function, which includes connecting with consumers. Consequently, natural disasters and other emergencies can pose significant risks to the reliability and continuity of communications networks and thus can adversely impact the provision of vital services during an emergency.² 

The Chamber recognizes the importance of investing in resilient infrastructure to address natural disasters. In 2020, the Chamber released a slate of policy principles to reduce risk from natural disasters and support economic growth.³ Relevant principles the Commission should keep in mind including coordination and integration between different levels of government and the private sector, facilitate innovation to improve resiliency, and promote public-private partnerships.⁴ 

The Chamber offers two specific comments to the Commission on the appropriate approach to improving communications network resiliency. First, the Wireless Network Resiliency Cooperative Framework (“Framework”) represents an effective public-partnership to respond and prepare for natural disasters, and accordingly the private sector has made substantial investments in network resiliency and improving coverage and capacity.⁵ While there may be opportunities to make targeted improvements to the Framework, the Chamber believes that the Framework should remain voluntary and should not be codified. Maintaining the voluntary nature of the Framework would empower the Commission and the Framework participants to engage in regular dialogue to continuously improve the effectiveness of the Framework as well as encourage other wireless providers and other entities to join the Framework.  

Furthermore, the flexibility enabled by a voluntary Framework can also help facilitate innovation to strengthen the resiliency of communications networks as connectivity and device options continue to develop. We also caution the Commission to not reflexively extend wireless network recommendations and/or commitments regarding resiliency to non-wireless networks.  Non-wireless networks have remarkably different technologies and structure and, as a result, forcing resiliency recommendations and/or commitments on such networks would have a disruptive effect and not generate any resiliency results that the Commission hopes to achieve.   

Second, the Notice calls for “Enhancing Municipal Preparedness and Restoration” and “Improving Public Awareness” to facilitate coordination and ensure that the public and stakeholders are familiar with the service status that may occur during an emergency.⁶ The Chamber believes it is important to include agencies or entities involved in disaster preparedness and response in the implementation of the Framework, which encompasses local and national, public and private organizations. Natural disasters and emergencies often involve significant public health risks and unreliable communications networks could result in heightened risks to public health.⁷ 

Thank you for the opportunity to participate in this proceeding and if you have any follow up questions, I may be reached at (202) 463-5973 or by e-mail at mfurlow@uschamber.com.  

Sincerely,  

Matt Furlow 
Policy Director
Chamber Technology Engagement Center 
U.S. Chamber of Commerce