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The Failure of a Regulatory Threshold and a Carrier Standard in Recognizing Significant Communication Loss

This paper investigates a regulatory reporting threshold dealing with telecommunication outages, and the use of a carrier industry standard in measuring the significance, or impact, of outage events. The FCC reporting requirement investigated is the 30,000/30 minute threshold, wherein any outage potentially affecting at least 30,000 customers for at least 30 minutes is an FCC-Reportable outage event. As outages below the threshold are censored, the natural question is whether a threshold is masking important events and impact? As local wire- line telecommunication switch outages are also reported in ARMIS for any local switch outage lasting 2- minutes or more, we have the opportunity to investigate communications loss above and below the FCC mandated threshold, at least for local switch outages. Although outages are due to failures in transmission facilities, signaling, tandem switching, and local switching, ARMIS reported local switch outages offer a proxy that provides insights into the relevancy of the current threshold. Over 18,000 local switch outage events are examined in this work. Impact for those local switch outages above and below the threshold are computed two ways (1) use of an ANSI accredited Standards Committee T1 metric called the Outage Index, and (2) use of a benchmark metric defined here, called Prime Lost Line-Hours. Key findings are that the current regulatory threshold masks serious communications loss, and that the industry communications loss metric (Outage Index) distorts impact above and below the regulatory threshold. This point is demonstrated by further considering five 9-11 switch outages in New York City. The appropriateness of the threshold and the industry metric are called into question, and further research is indicated, including economic research into threshold optimality.