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Post-Disaster Communications Petition

Recently, FCC placed on public review a petition filed by Evslin Consulting and pulver.com. The petition grew out of the experiences felt during a breakdown in communications network caused by Hurricane Katrina. As you may recall, whole communities were evacuated in the Gulf coast and many families were separated because they ended in different cities. Added to the trauma, many of these evacuees found it difficult to contact and communicate with each other. But those who have VoIP service and those who subscribe to premium features on their PSTN lines were better off because their services were able to forward the calls to the new location. The petition further notes that low income people were affected disproportionately during this period. The petition suggests ways to handle such disasters in the future and requests FCC to adopt their suggestions.

Evslin and pulver feel that most of the affected would have been satisfied to exchange information about their whereabouts and their safety. After all that is exactly what they tried to do via multitude of helter-skelter volunteer locator boards. Accordingly they suggest that when an area is generally affected or evacuated, then the local service providers must automatically terminate the calls to ALL of their customers, in a voice mail system. This will give a dependable place for people to leave and retrieve messages.

They go on to suggest that FCC require of those service providers who do not offer this emergency voice mail service to immediately port the affected customers’ numbers to an alternate service provider selected by individual subscribers, with the geographical limitations imposed by the prevailing LNP ruling. I don’t think this is a punitive requirement because the porting could be revoked once the emergency has cleared.

These two suggestions taken together are beneficial for the society at large; state clearly when it could be invoked and the effective period; do not adversely impact any business prospects for the service providers. For these reasons, the petition should receive wide support and all of us should urge FCC to consider it favorably.

The petition grants via a footnote that setting up such a voice mail system may involve capital expenditures and also require extensive logistics. They suggest that these expenses could be subsidized by Universal Service Fund or other funding sources. I am of the opinion that this expense will be small and can be spread to multiple willing contributors. The anticipated storage requirement can be offset if the voice mail system converts the voice mail into an email, instead of storing it in the voice mail server. The advantage is that the email server could be hosted by the service provider itself or could be hosted by a willing third party. Since many email providers operate on the assumption that storage is effectively free, there will be multiple volunteers during an emergency. Even the PIN management can be handled efficiently. For example, Red Cross can b given free access to such email servers from designated computers and its volunteers can assign PINs to affected public as and when needed. So I urge you not to consider the cost or logistical difficulties—they can be effectively contained, if not mitigated.

I have one final observation. Given the background of the individuals behind this proposal—Tom Evslin and Jeff Pulver - it is possible that some may construe this petition to favor IP Communications industry. I submit that it is indeed the other way. For a long time, people have expected VoIP technology to eclipse PSTN. But at least till now, the market place seems to suggest that they are at par. This petition dilutes, if not totally eliminate the inherent advantage IP networks have during a disaster.

You can get more information from Jeff and Tom and also the full text of the filing. If you are interested in adding your voice to this topic, you can add your comments by visiting FCC’s site. Please keep in mind that the petition reference number is RM-11327.

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