ISPs Should Report Only Hard Outages, Industry Says

WASHINGTON, June 18, 2024 – Trade groups for Internet Service Providers are resisting potential federal plans taking shape regarding when to report broadband network outages.

ISPs have accepted the need to report network service interruptions, but they want to limit reporting mainly to hard network failures, measured by total time elapsed and customers affected in combined user minutes.

A hard network failure refers to a complete loss of connectivity across the whole or part of a service network. Failures can be caused by a number of factors, including physical damage to network components, power outages or hardware malfunctions.

NCTA – The Internet & Television Association, which represents major ISPs such as Comcast Corp. and Charter Communications, filed comments last Wednesday with the Federal Communications Commission in response to a proposed rulemaking that seeks to extend outage reporting requirements to broadband providers.

If rules are adopted, NCTA urged the FCC to limit mandated reports to hard downages.

NCTA Vice President and Associate General Counsel Steven Morris said the trade group’s approach “would ensure that the definition of a reportable outage is straightforward, consistent, and meaningful.”

NCTA warned that the FCCs proposed outage reporting metric as outlined in the proposed rulemaking was too vague. The rulemaking suggested that reports will be required in cases of “significant degradation in throughput.”

NCTA argued that the proposal would not provide a clear quantitative measurement to establish significant degradation. It argued that such a standard would yield inconsistent data as providers would be left to estimate for themselves when to report incidents.

“Reporting based on such metrics could inundate the FCC with information that is not helpful,” NCTA said. 

The NCTA encouraged the FCC to model a hard down threshold off the current one for Voice over Internet Protocol providers. VoIP networks must be down for at least 30 minutes and involve at least 900,000 user minutes of service before a report would need to be filed.

“[Limiting to hard down outages] would provide a straightforward standard for providers to implement if rules are adopted and ensure that the FCC receives meaningful and actionable information,” NCTA said.

WISPA, another major broadband association, has also come out in support of the hard down approach. 

“WISPA agrees with NCTA that requiring outage reporting only for ‘hard down’ outages ‘would provide a clear, bright-line standard that is easily administrable for providers,’” WISPA said in a similar filing to the FCC.