[VoiceOps] Reproting VoIP outages FCC ruling

J. Oquendo sil at infiltrated.net
Tue Feb 21 14:48:10 EST 2012

On 2/21/2012 2:13 PM, Mark R. Lindsey wrote:
> 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.

I can see it now...

Carrier: "Technically, we didn't have an 11 hour outage"
Powers that be: "Can you elaborate?"
Carrier: "We're not sure 1) which carrier is to blame and 2) why they're 
really at fault so at this point we can't"
Powers that be: "Can you clarify your comment before we impose what is 
now going to be a bigger fine on your business?"
Carrier: "We have multi-homed redundancy from 6 upstream carriers and 
all were available however, some rebels without a cause using silly 
masks were DDoSing DNS servers"
Powers that be: "What is DDoSing?"
Carrier: "They were overwhelming the services enough so that individuals 
placing real requests were denied legitimate access"
Powers that be: "What is a DNS server"
Carrier: "DNS servers resolve names to IPs. Our customers weren't able 
to get to www.MyVoIPIsBetterThanYours.biz but they were able to get to 
our address at 20x.xxx.xxx.xxx"
Powers that be: "Who's responsible for the DNS server"
Geeks at the Carrier: "Dan Kaminski!"


J. Oquendo

"It takes 20 years to build a reputation and five minutes to
ruin it. If you think about that, you'll do things
differently." - Warren Buffett

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