In comments submitted to the FCC March 4th, the New York State Public Service Commission (“PSC”) expressed its support for the California Public Utilities Commission’s (“CPUC”) request for direct, password-protected access to the FCC’s Network Outage Reporting System (“NORS”) database. The PSC joined the CPUC in calling for the launch of a proceeding to implement a method of state access to the NORS database.
The CPUC had issued an order in 2009 concluding that the state’s service outage reporting would be improved if it adopted the FCC’s NORS reporting requirements and substituted those requirements for the state’s independent disruption and outage reporting guidelines. The CPUC directed its staff to seek direct access to the NORS database from the FCC. Unless its staff’s request is granted, California carriers must file the same outage reporting information twice: once with the FCC, and then again with the CPUC. In its Petition to the FCC, California noted that dual reporting is both impractical and burdensome both for the carriers and for state agency staff. It argued that the most efficient way for states to obtain NORS information is through secure access to the NORS database itself.
The PSC explained its support for direct access to the NORS database this way:
Access to the NORS database will assist in meeting our mandate of ensuring safe and reliable telecommunication service in New York. Due to increasing reliance on intermodal forms of communication (e.g., cellular and Internet Protocol (IP)), fulfilling this mandate requires that we have information from many different telecommunication providers, some which we do not currently assert jurisdiction over or may not necessarily fall under our jurisdiction. Because required outage reports, which are recorded in the NORS, are applicable to wireline, wireless and cable outages, we believe password-protected access to the NORS database, limited to New York-specific disruptions, will complement our existing outage reporting procedures; limit the creation of additional regulatory reporting obligations in multiple state jurisdictions; and, enhance the common interests of local, state and federal agencies with regard to network reliability and recovery.”
No confidentiality issues would arise from providing direct access to states, the PSC argued, because other federal databases (including the telephone numbering databases) have been shared with the states for years. “In fact,” the PSC noted, “granting such access could streamline the reporting process for both state commissions and carriers, and possibly reduce the need for states to expand mandatory reporting requirements to all telecommunications operators and service providers.”
PULP supports confidential, direct access by state commissions to the vital information contained in the NORS data as this is the only database which includes landline, wireless, and Voice over Internet Protocol (“VoIP”) outage information. With wireless and VoIP having captured half of the voice market in New York State, it is essential that the PSC have access to this database in order to help it meet its mandate to preserve telephone service. It is a necessary first step in protecting ALL of the state’s voice customers.