Wireless RERC on the Record: Improving the Wireless Resiliency Cooperative Framework

May 20, 2019 - The Wireless RERC submitted reply comments in response to the FCC’s Public Notice, Improving the Wireless Resiliency Cooperative Framework [PS Docket No. 11-60]. The comments commended the voluntary actions and investments of the wireless industry for strengthening their networks to withstand disaster events. However, we contended that more could be done to ensure that people with disabilities are included in the planning and deliberations, and consequential actions of the Framework. Specifically, the Wireless RERC agreed with Verizon’s assertion that “the Framework also should continue to preserve wireless providers’ ability to determine, based on sound engineering principles and objective factors like available coverage and traffic demands, where and how to allocate their assets and services in a locality to most effectively and efficiently respond to a disaster.[1]

The impacts of large-scale disasters are highly variable and continually changing as events unfold. Prescribing a metric for where and how much pre-positioning of assets based on population size could potentially delay restoration to the hardest impacted areas that contain some of our nation’s more vulnerable to disaster populations. For example, the population-size formula would systematically exclude rural areas from pre-disaster positioning of assets. There is a higher prevalence of disability in rural America compared to urban areas.[2] This fact, coupled with a population-size formula, places rural residents with disabilities in jeopardy of extended delays to wireless services that they rely on for accessible communications. We also recommended that the criteria for mutual aid and service restoration not rule out area’s that have been deemed to have no user access. There are many residents without the financial resources to comply with evacuation orders. Though the area may have been designated as mandatory evacuation, reports have shown that people with disabilities and the elderly often remain in these areas. Thus, providers retaining the flexibility to quickly restore communications access via wireless devices would literally be a lifeline for residents who need saving by search and rescue parties.

Wireless RERC reply comments also supported comments made by CTIA and the Telecommunications for the Deaf and Hard of Hearing, Inc. (“TDI”), Hearing Loss Association of America (“HLAA”), National Association of the Deaf (“NAD”), Coalition on Inclusive Emergency Planning/Washington State Independent Living Council (“CIEP/WASILC”), and California Coalition of Agencies Serving the Deaf and Hard of Hearing, Inc. (“CCASDHH”) (collectively “Consumer Groups”). The full document can be accessed below.