The FCC’s Public Safety and Homeland Security Bureau today issued a Public Notice reminding communications service providers that Network Outage Reporting System (“NORS”) filings must be accurate, complete, and sufficiently detailed to allow the Commission and public-safety agencies to understand what happened during a reportable outage.
The guidance focuses on several recurring reporting problems.
First, the FCC expects the “Description of Incident” field to tell the story of the outage in clear, plain language. Providers should describe the sequence of events, steps taken to mitigate and resolve the problem, contributing factors, and the ultimate resolution. Internal codes, technical shorthand, unintelligible ticket notes, or simply stating that an incident remains “under investigation” are not enough.
Second, providers must use the best estimate reasonably available at each filing stage when reporting the number of users potentially affected. The FCC specifically cautions against using an entire subscriber base as a placeholder when more accurate information is available and expects estimates to be updated as better information develops.
Perhaps most significantly, the FCC expressly reminded non-facilities-based resellers, including mobile virtual network operators (“MVNOs”), that they may have NORS reporting obligations. The Commission noted that very few MVNOs currently submit outage reports, even though covered resellers that lease or otherwise utilize facilities to provide service must report qualifying outages.
Finally, providers must conduct a reasonable investigation and select the most specific root cause supported by available information before the Final Report deadline. An outage originating on another provider’s network does not relieve the reporting provider of that responsibility. “Insufficient Data” should be used only in rare cases where a reasonable investigation still does not identify the cause.
What Providers Should Do Now
Communications providers — particularly MVNOs, resellers, interconnected VoIP providers, and companies dependent on underlying carrier networks — should review their NORS procedures now. Confirm who is responsible for identifying reportable outages, obtaining information from upstream providers, estimating affected users, documenting incident details, investigating root cause, and updating filings through the Final Report stage.
The CommLaw Group assists communications providers with FCC Part 4/NORS compliance, outage-reporting procedures, regulatory classification, and remediation of historical compliance gaps. If your organization has assumed that its underlying carrier handles outage reporting — or has never evaluated whether NORS applies to its services — this Public Notice is a timely reason to revisit that conclusion.