ATIS URGES COMMISSION TO ENSURE THAT ANY OUTAGE REPORTING FOR VOIP AND BROADBAND SERVICE PROVIDERS IS REASONABLE.

WASHINGTON -- The following information was released by the Alliance for Telecommunications Industry Solutions:

The Alliance for Telecommunications Industry Solutions (ATIS) submitted comments on behalf of its Network Reliability Steering Committee (NRSC) in response to the Federal Communications Commission's Proposed Extension of Part 4 of the Commission's Rules Regarding Outage Reporting to Interconnected Voice Over Internet Protocol Service Providers and Broadband Internet Service Providers. ATIS to expressed its view that the proposed expansion of the Commission's outage reporting rules to interconnected voice over internet protocol (VoIP) service providers or broadband internet service providers (ISPs) is not warranted.

To the extent that the Commission does impose such reporting obligations on interconnected VoIP service providers and broadband ISPs, ATIS notes that these obligations must be reasonable. Therefore, ATIS urges the Commission to ensure that any data collected is already readily available to reporting entities via the normal network management process. ATIS also opposes reporting obligations that would require the submission of performance characteristic data, such as latency or jitter.

For interconnected VoIP service providers, ATIS recommends that any reporting be based on similar criteria as is currently used for other service providers under Part 4 of the Commission's Rules. However, ATIS strongly urges the Commission to modify its outage reporting criteria for all filers to reduce burdens by, among other things, requiring the submission of outage reports only for outages that last at least 120 minutes, rather than the current 30 minute threshold.

"As the preeminent industry subject matter experts on communications network reliability and outage reporting, the NRSC has made an in-depth consideration of the Commission's extension of Part 4 of the outage reporting rules," said Susan Miller, President and CEO, ATIS. "Its analysis shows that voluntary, collaborative efforts are more effective than regulatory mandates in fostering cooperation, promoting innovation, and providing the flexibility needed to meet new and evolving challenges associated with ensuring communications reliability."