The American Cable Association and ITTA say that new FCC network outage reporting requirements are unnecessary, and that requiring reporting not only of complete outages but also degradation of service will require smaller operators to report info they don't have the means to report.
In comments to the FCC, ACA said the new requirement would mean smaller operators would have to purchase and deploy new monitoring equipment in every customer home.
The FCC is proposing to extend its phone outage reporting requirements to cable's interconnected VOiP phone service and broadband access services as a way to try to insure continuity of emergency communications including 911 service.
ACA said the new cost would not be outweighed by any consumer benefits.
ACA President Matt Polka says the new reporting requirements "are not targeted to identify significant wide-scale outages that prevent consumers from accessing emergency services, and would impose significant burdens on providers, particularly smaller providers."
ACA says the FCC should confine its requirements to complete losses of interconnected VOiP.
ACA also wants the FCC to "refrain from imposing outage reporting requirements on dedicated services [business data services]" and "refrain from requiring cybersecurity-related outage information in reports."
ACA is on the same page with ITTA – The Voice of Mid-Size Communications Companies.
ITTA told the FCC in its comments that it would be "exponentially increasing the burdens on providers without producing any tangible public safety benefits." It also said the FCC should stick with complete outages rather than performance degradation requirements.
ITTA also said the requirement should not be extended to broadband access services because those dedicated services are already subject to service level provisions as part of their contracts.