8. Issue 4: Level of Implementation of Best Practices
by the Different Telecommunications Industry Segments
8.1. FAR Analysis
Best Practices provide recommendations regarding system design, construction and operation that are intended to ensure the reliability and interoperability of telecommunications networks, including during emergencies.28 For example, Best Practice Number 7-7-0701 provides that network operators, service providers and property managers should provide security for portable generators. Best Practice Number 7-7-1029 provides that network operators and service providers should periodically review their portable power generator needs to address changes to the business. There are 98 Best Practices related to power for all segments of the telecommunications industry (wireline, wireless, cable, satellite, and equipment providers).
To determine whether the Best Practices have been implemented, a questionnaire was prepared and sent to California wireline, wireless, and cable providers. The questionnaire was aimed at collecting statistical information on the level of implementation, the effectiveness of the Best Practices, and the costs of implementation.
The questionnaires were distributed on August 27, 2007. Eleven providers responded (two large LECs, four small LECs, three wireless and two cable). One of the small LEC responses was a joint response from 14 small LECs. The FAR finds that the responses received adequately represent such providers so that conclusions can be drawn from the results.
Based on the responses, the FAR finds that implementation rates for the Best Practices are 98% for large LECs, 73% for small LECs, 91% for wireless and 93% for cable. For the Best Practices related only to backup generator deployment, the implementation rates are 98% for large LECs, 70% for small LECs, 90% for wireless and 90% for cable. As to effectiveness, the great majority of the Best Practices are considered by the providers to be effective to some degree while almost half of the responses indicate they are very effective. Regarding relative cost, most providers consider them to be costly to implement. The responses also indicate that the responding service providers have less understanding of the cost of implementing the Best Practices than they do of their effectiveness or the extent of their implementation.
The difficulty that smaller LECs have in implementing the Best Practices seems to be rooted in the capital costs associated with additional batteries, generators, and other backup hardware.
8.2. FAR Options/Recommendations
The FAR recommends the Commission encourage small LECs to implement the Best Practices and continue participating in FCC and industry sponsored forums for Best Practices. Another option is the use of incentive mechanisms to encourage improvements in backup capacity and contingency planning.
8.3. Discussion
The FAR indicates substantial implementation of the Best Practices. However there is some room for improvement by the small LECs. As recommended in the FAR, we encourage their implementation. In addition, we require CD to further investigate small LEC implementation, including any reasons for non-implementation, and report the results to the Commission along with recommendations for further action if appropriate. As to incentive mechanisms, it is not clear that they are needed and we decline to offer them at this time. Staff should, however, make recommendations, and explain why, if an incentive mechanism may be warranted in some circumstances.
28 Network Reliability and Interoperability Council (NRIC) VII, Focus Group 1C, "Analysis of the Effectiveness of Best Practices Aimed at E-911 and Public Safety, F Report," December 2005. NRIC is a federal advisory committee to the FCC operating on two-year cycles. The purpose of NRIC-VII was to provide recommendations to the FCC that, if implemented, would ensure the reliability and interoperability of wireless, wireline, satellite, cable and public data networks, including emergency communications.
