[VoiceOps] Reproting VoIP outages FCC ruling

[Mark R. Lindsey]

The new outage reporting rules are finally out:
	http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-12-22A1.pdf

My musings are based on a brief review.

1. 911 Outage Reporting

The most interesting element is the requirement to notify the FCC of any outage involving a 9-1-1 special facility if that outage lasted 30 minutes or more. 

It's a 911 outage if for 30 minutes or more,
	-- Customers can't have a working conversation with 911
	-- You can't deliver calling party information accurately
	-- You don't have working re-route capability

You only have four hours to file a report about one of those outage. So if you have an outage from 1:00am until 1:30am, then you've got until sometime around 5:00am to get it reported.

For ordinary traffic, you now have to report an "outage" that affects 900,000 user minutes of service, as long as that outage lasted 30 minutes or longer.


2. IP Network Outages

But if a VoIP Service Provider accesses its customers through T1s, MPLS, Ethernet, etc., then do outages on those networks constitute reportable outages?  In some cases, it appears so.

"Our intention is that non-facilities-based VoIP providers report service outages that meet the threshold to the extent that they have access to information on service outages affecting their customers."

If the VoIP SP actually owns, operates, leases, or otherwise utilizes those links to their customers, then, yes, an outage on an IP network would be considered a reportable outage.

And if the VoIP SP can detect a problem with the networks connected to their customers, then that contributes to the number of user minutes affected. E.g., a Level3 outage might affect 30% of the user population, and we have 50,000 users in the user population, and service was down for 90 minutes, then that's 0.3 * 50000 * 90 = 1,350,000 user minutes. So this would be a reportable outage.


3. Ordinary Outages

If customers can't have working non-911 phone calls for 900,000 user-minutes or more, and it lasts at least 30 minutes, then it appears you have to report it.


4. Example Cases

So how about a SIP trunks to Intrado or Dash that's installed for 911?

What about a SIP trunk that's used for both ordinary calls and for 911?

So how about those MPLS tails from Level3 or XO? 

Or how about those T1s you lease from Verizon?

What if they have packet loss great enough to interrupt working RTP flows, but not high enough to prevent SIP registration?

I'm not a lawyer.

-- Mark R Lindsey mark at ecg.co +1-229-316-0013  http://ecg.co/lindsey




On Feb 16, 2012, at 11:04 , Carlos Alvarez wrote:

> I haven't read the whole ruling, but so far from our perspective we're
> still left not knowing what really constitutes an "outage."  We have
> multiple types of connectivity and multiple carriers to connect to.
> If we lose an origination carrier, for example, that has no impact on
> emergency calls, but some customers won't receive inbound calls.  Is
> that an outage under this?
> 
> I can't think of an outage we have had that would prevent a customer
> dialing 911.  But the customers themselves have plenty of internet
> issues that might cause that.
> 
> 
> On Wed, Feb 15, 2012 at 9:31 PM, Ujjval Karihaloo
> <ujjval at simplesignal.com> wrote:
>> Correct and the VoIP services rely on the Internet backbone in general that
>> causes issues which ITSPs has no control over as well
>> 
>> 
>> 
>> 
>> On Wednesday, February 15, 2012, Bret Palsson <bret at getjive.com> wrote:
>>> This is an interesting move. The way I see it, the FCC isn't going to get
>>> very good data. Say a VoIP provider has one datacenter, and they have an
>>> outage. How will the FCC track who didn't have 911 service at that time? For
>>> all they know, the datacenter went down and that location might not have
>>> access to 911. What about the potentially hundreds of thousands of endpoints
>>> and their location?
>>> It makes more sense for wireless and wired operators that have localized
>>> towers and central offices. If one of those locations experience an outage,
>>> they have a better idea of who doesn't have access to 911, geographically
>>>  speaking.
>>> Another scenario: What happens when a customers ISP goes down? It's not
>>> the job of the VoIP provider to monitor that connection to say it's down.
>>> I really don't think they will get the data they expect with this ruling.
>>> The only good data they will get is, provider A has more uptime than
>>> provider B.
>>> Other opinions?
>>> -Bret
>>> 
>>> On Feb 15, 2012, at 8:38 PM, Ujjval Karihaloo wrote:
>>> 
>>> What is the impact of this ?
>>> 
>>> 
>>> 
>>> 
>>> http://news.cnet.com/8301-1023_3-57378872-93/fcc-requires-voip-providers-to-report-service-outages/
>>> 
>>> 
>>> 
>>> Ujjval Karihaloo