Hogan Lovells 2024 Election Impact and Congressional Outlook Report
The Federal Register has published FCC network resiliency rule change proposals that may add reporting obligations for satellite operators. Comments are due on or before April 29, 2024, and reply comments are due on or before May 28, 2024.
Satellite providers are already required to file network outage reporting system (NORS) reports for key system elements outages lasting more than 30 minutes. Providers may file disaster information reporting system reports (DIRS) on a voluntary basis. A DIRS report often precedes anticipated service degradations, such as in advance of (or after) a hurricane, and requests related assistance. The Commission noted that satellite providers have submitted a “very small number” of NORS reports and very few DIRS reports.
The Commission seeks comment on its view that public safety benefits overweigh the costs of extending these requirements in the satellite field. Thus, it asks –
should these requirements extend to direct broadcast satellite, satellite digital audio radio service, fixed-satellite service, and mobile-satellite service providers?
what information should such filings include?
should reporting extend to terrestrial facilities (many of which the satellite operators have no control over) and should reporting include only specific terrestrial network components?
should reporting outage thresholds be modified, e.g., extending DIRS to outages lasting more than 120 minutes?
would the new requirements cost more than $545,000 per year (with the FCC estimating that 18 satellite providers would be subject to the DIRS reporting mandate).
The Commission’s DIRS User Guide offers additional background on the current rules.
Authored by Gerry Oberst and George John.