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FCC Needs to Improve its Internal 911 and IPv6 Compliance

by: Michael O'Rielly, FCC Commissioner

June 2, 2014

The Federal Communications Commission (FCC) sets communications rules and policies, as directed by the Congress, and works with providers and organizations as they develop and implement industry standards.  To remain relevant, the agency must stay on top of current technologies and serve as a model both for industry and other federal agencies.  The FCC loses credibility when it seeks to impose rules or standards on the private sector but does not adhere to the same or similar commitments in its own operations.

To this end, I suggest that two important areas are ripe for improvement. 

Direct access to 911.  As has been highlighted in recent regulatory actions, the FCC is responsible for promoting safety of life, via communications technologies and we take that responsibility very seriously.  For instance, the agency has advanced numerous policies to improve the effectiveness of the 911 system with the hopes that one day wireless callers—especially those with hearing or speech disabilities—will be able text their emergencies to First Responders.  In fact, the FCC acted three months in a row to adopt changes to the current 911 capabilities of wireless carriers, comparing the cost of these regulations to the cost of a life or lives. 

Now, the tables are turned as a new public safety issue has surfaced that requires our leadership.  Buildings that use multi-line telephone systems (MLTS) require people to dial an extra number (typically 9) to get an outside line.  To dial 911 in an emergency, then, requires that the dialer know and remember that he or she must first dial that extra number.  As my colleague Commissioner Pai has highlighted, this extra step can delay emergency personnel and even cost lives.  I commend him for working with the American Hotel and Lodging Association (AH&LA) to find a voluntary remedy for this issue in hotels and motels. 

Unfortunately, the FCC’s system currently suffers from the same flaw.  Our employees and any visitors must dial 9-911 to reach help in an emergency.  I asked that the agency look into options for fixing this problem.  Since then, we have learned how simple reprogramming our telephone system would be.  While the new dialing procedures may require some minor education of staff, this can be done relatively quickly.  Also, we should hold ourselves to the same cost-benefit standards that we apply to regulatees. 

And once we have our house in order, we should be in a position to assist other federal agencies with similar updates.  This potential life-saving fix is especially important because in addition to hosting employees and visitors, many of our Federal buildings have day care centers with infants and young children on site. 

Transitioning to IPv6.  The latest Internet protocol version 6, IPv6, was launched in 2012 to expand the number of available IP addresses, which are necessary to connect devices over the Internet and enable it to grow.  Since that time, companies have been transitioning from IPv4 (the old standard) to IPv6 and have been phasing out old software and equipment, including routers and servers, that do not support IPv6.  To most people, the transition has gone unnoticed.  That’s because the two protocols have been running in parallel, ISPs provide access to both IPv4 and IPv6 sites, and most operating systems have supported the new standard for years.  The simple truth is the entire Internet community needs to make this conversion because we are running out of IPv4 numbers.  Moreover, IPv6 is not backwards compatible, so as new users and devices come online, they are only accessible via the new standard.  That is why it is essential for all websites to transition to IPv6.

So where is the FCC in its transition?  Well, it issued a consumer guide on IPv6 in 2012 to encourage the private sector to quickly move to the new standard.  But the agency itself has a ways to go.  In fact, only 12% of its linked subdomains are IPv6 operational.  For an agency that just proposed rules and questions that aim to micromanage the way the Internet works, this is seems ironic.  I am hopeful that as the FCC modernizes its website and IT infrastructure, it will also quickly complete the transition to IPv6.   

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