[My comments in bracketed blue italics.]
INTERNET PROTOCOL TRANSITION FCC Should Strengthen Its Data Collection Efforts to Assess the Transition’s Effects Why GAO Did This Study The communications sector is essential to the nation’s economy and government operations and for the delivery of public safety services, especially during emergencies. As the sector transitions from legacy networks to IP-based networks, consumer and public safety groups and others have raised concerns about how the communications networks will function during times of crisis. [The old wireline system was powered by the batteries maintained at the telephone company’s central office. Even though mechanisms exist to cut off all telephone lines in an emergency and then bring them up when the system detected an on-hook condition, the system was close to being foolproof. In many cases the network featured redundant pathing and resiliency for downed or damaged lines. However, as people adopted mobility solutions to communications, individual cell sites became even more vulnerable to disasters and power outages. Without cell towers, no connectivity is possible even if the user’s local devices remain accessible to power. There are limits to cell tower capacity and there are few provisions for implementing aerial mobile solutions like those used by law enforcement to spoof cell towers.]
GAO was asked to examine the reliability of the nation’s communications network in an IP environment during times of crisis. GAO examined: (1) the potential challenges affecting IP networks in times of crisis and how the challenges may affect end users, and (2) the actions FCC, DHS, and other stakeholders have taken to ensure the reliability of IP communications. GAO reviewed FCC and DHS documents as well as FCC proceedings and comments filed with FCC on the IP transition and emergency communications. [The GAO’s examination resulted in an assessment of the government’s ability to collect research data and to propose solutions. The GAO did not address the actual issue of resiliency under emergency conditions.]
GAO assessed FCC’s efforts to collect data on the effect of the IP transition. GAO interviewed officials from FCC and DHS, and representatives from the three largest telecommunications carriers, industry associations, and public interest and consumer advocacy groups. [I tend to believe that governmental agencies, private companies, and industry associations simply do not tell the truth if the reality would upset consumers and result in an outcry for costly modifications to existing systems. As for public interest groups, especially those involved in consumer advocacy, it is about media attention and fundraising, and the implementation of profitable programs to extend the advocates power and relevancy.]
What GAO Recommends FCC should strengthen its data collection efforts to assess the IP transition’s effects. FCC did not agree or disagree with the recommendation and stated it has a strategy in place to oversee the IP transition. However, GAO continues to believe FCC should strengthen its data collection efforts. [The FCC has been more involved with the President’s domestic public policies and progressive agenda than they have in activities beneficial to consumers. I personally believe that the FCC should be disbanded and its technical activities be transferred to NIST (National Institute of Standards and Technology).]
What GAO Found As the nation’s telecommunications systems transition from legacy telephone networks to Internet Protocol (IP)-based networks, telecommunications carriers can face challenges during times of crisis that affect end users’ ability to call 911 and receive emergency communications. [The truth is that point-to-point radio communications, such as those offered by amateur radio operators or those with CB radios, are most likely to be effective in a region-wide disaster. Followed by satellite-based services. Cell phones and other wireless devices are likely to become inoperative; for the lack of power or, more importantly, the lack of connectivity. Although pricey, the best solution is private satellite radio connectivity.]
These challenges include (1) preserving consumer service and (2) supporting existing emergency communications services and equipment. For example, during power outages, consumers with service provided over IP networks and without backup power can lose service. The Federal Communications Commission (FCC) is working to address this issue by adopting rules that will require carriers to provide information to consumers on backup power sources, among other things. Another challenge is that IP networks may not support existing telecommunications “priority” services, which allow key government and public-safety officials to communicate during times of crisis. [One of the things that greatly disturbs me is that many government solutions are simply to provide official notice that “bad things can happen” as if this absolves elected officials, agency directors, and other bureaucratic institutors from their responsibility to provide more resilient infrastructure. Unfortunately, we see these political animals avoiding the repair, replacement, or build-out of our critical infrastructure; with designated funds being looted to pursue social programs that are little more that vote-buying exercises.]
FCC, the Department of Homeland Security (DHS), and telecommunications carriers have taken various steps to ensure the reliability of IP communications, for example: • FCC proposed criteria—such as support for 911 services, network security, and access for people with disabilities—to evaluate carriers’ replacement of legacy services when carriers seek to discontinue existing service. • DHS coordinated the development of the Communications Sector Specific Plan to help protect the nation’s communications infrastructure. • Carriers told GAO they build resiliency and reliability into their IP networks as part of business operations and emergency planning. [Why is it that we see these very agencies bemoaning poor performance during actual emergencies and promising investigation and better future performance -- when they claim overwhelming success during simulated disaster exercises?]
FCC is also collecting data on the IP transition, but FCC could do more to ensure it has the information it needs to make data-driven decisions about the transition. FCC has emphasized that one of its statutory responsibilities is to ensure that its core values, including public safety capabilities and consumer protection, endure as the nation transitions to modernized networks. [Why is the FCC so involved in political activities? Pretty much for the same reasons we have seen the IRS and Department of Justice subverted by the Obama Administration.]
FCC stated that fulfilling this responsibility requires learning more about how the transition affects consumers. FCC plans on collecting data on the IP transition primarily through voluntary experiments proposed and run by telecommunications carriers. However, it is unclear if FCC will be able to make data-driven decisions about the IP transition because of the limited number and scale of the proposed experiments. [Designed for failure by default like most government accounting systems?] In particular, there are only three proposed experiments that cover a very limited number of consumers; none of the experiments covers consumer services in high-density urban areas or includes critical national-security or public-safety locations. [Yep! Designed for outcomes that make the carriers look good while not really addressing serious capabilities and capacity issues. Knowing this is true as evidenced by the above statement, one would believe that the agencies would be compelled to run better experiments. Yeah Right!]
FCC also sought comment on how to supplement its data-gathering process; however, soliciting comments may not necessarily result in a change in FCC’s existing policies. GAO found FCC lacks a detailed strategy that outlines how it will address its remaining information needs. Developing a strategy for collecting information about how the IP transition affects public safety and consumers would help FCC make data-driven decisions and address areas of uncertainty as it oversees the IP transition. Highlights Page: (PDF, 1 page) -- Full Report: (PDF, 48 pages) | 
