ATIS Files Comments with FCC in Response to Hurricane Katrina Panel Recommendations

August 11, 2006, Washington – The topic of disaster readiness checklists was one of six key issues addressed by ATIS in comments to the Federal Communications Commission (FCC) in response to the Notice of Proposed Rulemaking regarding the Recommendations of the Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks.

ATIS filed these comments on behalf of its Network Reliability Steering Committee (NRSC), which has worked for 13 years to foster network reliability and to recommend voluntary Best Practices.

ATIS supports the development of voluntary disaster readiness checklist(s) for communications providers through consensus-based industry bodies, but cautions against one-size-fits-all checklists. By keeping the checklists voluntary, ATIS notes, the industry can more easily make improvements as necessary to address lessons learned and changes in telecommunications networks. The ATIS comments also offered the following:

• ATIS concurs that a single point of contact should be established for outage reporting data in the wake of an emergency and agrees that the FCC could effectively provide this function, provided this does not preclude participation by the Department of Homeland Security through the National Communications System (NCS). In addition, ATIS urges the FCC to limit the disclosure of company-specific outage data, and develop safeguards to share aggregated outage data with industry groups, in order to foster continued improvement in network reliability.

• ATIS supports the granting of automatic Special Temporary Authority (STA) and waivers of certain regulatory requirements to facilitate the swift restoration of communications services to areas affected by hurricanes and other disasters. These waivers will provide necessary flexibility to communications providers to use available network facilities in the most effective manner to restore services to customers.

• ATIS supports the development of industry-only planning and recovery groups and is willing to assist these groups in their efforts to evaluate network-related practices to foster reliability and resiliency. ATIS recommends that the FCC facilitate, but not mandate, the establishment of these groups at national or regional levels.

• ATIS agrees with the Hurricane Katrina Panel recommendation that existing priority communications services, including Telecommunications Service Priority (TSP), be promoted within the telecommunications industry to ensure national security and emergency preparedness circuits receive priority attention during disaster recovery situations. ATIS notes that these existing programs, if utilized, can greatly assist service providers in prioritizing the provisioning and restoration of important communications services.

• ATIS supports voluntary, industry-developed Best Practices regarding circuit diversity and notes that a number of these Best Practices have already been developed. ATIS strongly believes that the successful development of Best Practices requires the industry to work in a cooperative setting free from regulatory mandates.

About ATIS

ATIS is a technical planning and standards development organization that is committed to rapidly developing and promoting technical and operations standards for the communications and related information technologies industry worldwide using a pragmatic, flexible and open approach. Participants from more than 350 communications companies are active in ATIS’ 23 industry committees and Incubator Solutions Program. www.atis.org

-30-