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Derecho Report and Recommendations

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Released: January 10, 2013

Impact of the June 2012 Derecho on

Communications Networks and Services

Report and Recommendations

A Report of the Public Safety and Homeland Security Bureau
Federal Communications Commission
January 2013






PSHSB INFORMATION-GATHERING PROCESS ................................................................................................6


OVERVIEW OF THE DERECHO’S IMPACT ON COMMUNICATIONS ................................................................11


THE DERECHO’S EFFECTS ON WIRELINE NETWORKS....................................................................................15

Impact of the June 2012 Derecho on

Communications Networks and Services

Report and Recommendations

A Report of the Public Safety and Homeland Security Bureau
Federal Communications Commission
January 2013






PSHSB INFORMATION-GATHERING PROCESS ................................................................................................6


OVERVIEW OF THE DERECHO’S IMPACT ON COMMUNICATIONS ................................................................11


THE DERECHO’S EFFECTS ON WIRELINE NETWORKS....................................................................................15

BACKUP POWER PROBLEMS .................................................................................................................................15
Backup Power Problems in Virginia .....................................................................................................16
Backup Power Problems in West Virginia............................................................................................ 20
SWITCH EFFECTS................................................................................................................................................ 20
Verizon Switch Effects.......................................................................................................................... 20
Switch Effects in West Virginia ............................................................................................................21
EFFECTS ON TRANSPORT EQUIPMENT..................................................................................................................... 21
PROPOSED CORRECTIVE ACTIONS FROM WIRELINE PROVIDERS ................................................................................... 21
Corrective Actions Proposed by Verizon .............................................................................................. 21
Corrective Actions Proposed by Frontier.............................................................................................. 24
WIRELINE OUTAGES IN OTHER STATES ................................................................................................................... 24

THE DERECHO’S EFFECTS ON PUBLIC SAFETY ANSWERING POINTS .............................................................25

DESCRIPTION OF THE 9-1-1 NETWORK................................................................................................................... 25
NETWORK EFFECTS ON PSAPS ............................................................................................................................. 26
NETWORK EFFECTS ON PSAPS IN VIRGINIA.............................................................................................................27
VIRGINIA PSAPS................................................................................................................................................ 28
Fairfax County......................................................................................................................................28
Prince William County.......................................................................................................................... 30
City of Manassas..................................................................................................................................30
Manassas Park.....................................................................................................................................31
Arlington County..................................................................................................................................31
Other PSAPs in Virginia Supported by Verizon..................................................................................... 32
Albemarle County ................................................................................................................................ 32
EFFECTS ON PSAPS IN WEST VIRGINIA................................................................................................................... 33
EFFECTS ON PSAPS OUTSIDE OF VIRGINIA AND WEST VIRGINIA.................................................................................. 34
Ohio ..................................................................................................................................................... 35
Maryland .............................................................................................................................................35
Other States.........................................................................................................................................36

THE DERECHO’S EFFECTS ON WIRELESS NETWORKS....................................................................................36

HIGH-LEVEL SNAPSHOT OF WIRELESS NETWORK EFFECTS.......................................................................................... 37
CELL SITE BATTERY LIFE.......................................................................................................................................38


RECOMMENDATIONS FOR POSSIBLE COMMISSION ACTION......................................................................................... 39
DILIGENT IMPLEMENTATION OF BEST PRACTICES......................................................................................................41
Actions by CSRIC ..................................................................................................................................42
RECOMMENDATIONS FOR PSAP ACTION ................................................................................................................ 42
PSAP Voluntary Reporting to the FCC ..................................................................................................43
NG9-1-1 IMPLEMENTATION................................................................................................................................ 43




Appendix A: Preliminary Findings by the Virginia State Corporation Commission
Appendix B: Recommendations of the Metropolitan Washington Council of Governments
Appendix C: Recommendations from PSAPs


Figure 1: Number of NORS Reports by Date of Incident .................................................................7
Figure 2: Number of NORS Reports by State...................................................................................7
Figure 3: 9-1-1 Network Architecture ...........................................................................................25
Figure 4: Percent Cell Sites Out by Date........................................................................................38
Figure 5: Reasons Cell Sites Out of Service....................................................................................38


Table 1: Summary of PSAP Effects.................................................................................................27

Executive Summary

In June 2012, portions of the Midwest and Mid-Atlantic regions of the United States
experienced a fast-moving, destructive windstorm called a derecho, resulting in twenty-two
deaths and leaving millions without electrical power. Unlike hurricanes and superstorms, which
are generally well-forecast, derechos are more like earthquakes, tornados, and man-made
events for which there is little-to-no advance notice and opportunity to prepare.
The 2012 derecho severely disrupted 9-1-1-related communications. Seventy-seven 9-1-1 call
centers (also known as “Public Safety Answering Points” or “PSAPs”) serving more than 3.6
million people in six states lost some degree of connectivity, including vital information on the
location of 9-1-1 calls, mostly due to service provider network problems. From isolated
breakdowns in Ohio, New Jersey, Maryland, and Indiana, to systemic failures in northern
Virginia and West Virginia, 9-1-1 systems and services were partially or completely down for up
to several days. Seventeen PSAPs in three states lost service completely, affecting the ability of
more than 2 million people to reach 9-1-1 at all.
Even in the context of a storm like the derecho, a large-scale failure of communications –
particularly 9-1-1-related communications – is unacceptable, and action must be taken to
prevent similar outages in the future. To this end, at the direction of Federal Communications
Commission (“FCC” or “Commission”) Chairman Julius Genachowski, the Public Safety and
Homeland Security Bureau (“PSHSB” or “Bureau”) conducted an inquiry into the causes of the
communications failures that resulted from the derecho and ways to prevent them during
future emergencies so we can make the public safer. The Bureau’s inquiry included extensive
review of confidential outage reports, public comments and related documents, as well as
interviews of many service providers and PSAPs, equipment and backup power vendors, and
public safety and community officials.
The Bureau found that above and beyond any physical destruction by the derecho, 9-1-1
communications were disrupted in large part because of avoidable planning and system
failures, including the lack of functional backup power, notably in central offices. Monitoring
systems also failed, depriving communications providers of visibility into critical network
functions. In most cases, the 9-1-1 and other problems could and would have been avoided if
providers had followed industry best practices and available guidance.
While important aspects of 9-1-1 service are under state and local jurisdiction, the Commission
has a statutory obligation to ensure that our nation’s communications networks “promot[e]
safety of life and property,” and action at the federal level could help prevent similar failures in
the future.
Thus the report recommends areas for the Commission to consider action to ensure the
reliability, resiliency, and availability of 9-1-1 communications networks. These include
ensuring that service providers: conduct periodic audits of 9-1-1 circuits; maintain adequate

backup power at central offices and follow regular maintenance and testing procedures; have
adequate network monitoring links; and have a more specific obligation to notify 9-1-1 call
centers of breakdowns of 9-1-1 communications. The report also notes the relative advantage
in reliability and performance that migration to Next Generation 9-1-1 (“NG9-1-1”), which is
based on Internet-protocol architecture, will bring over “legacy” 9-1-1 systems.
The Bureau’s derecho inquiry gathered information relating to broader issues of network
reliability and resilience that are also important to the ability of consumers to originate
successful calls for help in emergencies, including the availability of wireless networks and of
power for consumers’ devices and equipment. Those issues were raised again when, during the
preparation of this report, the Mid-Atlantic was hit by another devastating weather event:
Superstorm Sandy. Accordingly, we will analyze these issues further, after the conclusion of the
field hearings recently announced by Chairman Genachowski about that event. While
Superstorm Sandy had widespread and severe impacts on communications, this report focuses
on the derecho and, principally, its devastating impact on the networks that connect 9-1-1 call
centers to people who need help.

1. Introduction
On June 29, 2012, a fast-moving, destructive, and deadly storm called a derecho1 developed in
central Iowa, worked its way across Illinois and Indiana, and by late afternoon and early
evening, had moved quickly across Ohio, the central Appalachians, and the Mid-Atlantic states,
continuing into the early morning of June 30. It resulted in twenty-two deaths and widespread
damage, and left millions of citizens without electrical power for periods ranging from less than
an hour to close to two weeks.2 The radar map below shows the derecho’s path over time.3

1 The National Weather Service defines a derecho as “a widespread, long-lived wind storm that is associated with a
band of rapidly moving showers or thunderstorms. Although a derecho can produce destruction similar to that of
tornadoes, the damage typically is directed in one direction along a relatively straight swath. As a result, the term
‘straight-line wind damage’ sometimes is used to describe derecho damage. By definition, if the wind damage
swath extends more than 240 miles (about 400 kilometers) and includes wind gusts of at least 58 mph (93 km/h) or
greater along most of its length, then the event may be classified as a derecho.” See
2 See, e.g., Schwartz, John, Many Areas Still in Dark After Series of Storms, N.Y. TIMES, July 2, 2012; Gresko, Jessica,
Mid-Atlantic Region Hammered by Storms, Too, THE COLUMBUS DISPATCH, July 1, 2012. More than 3.7 million
customers lost power, including approximately 1 million customers each in Ohio and Virginia and roughly 900,000
in Maryland, 632,000 in West Virginia, 68,000 in Washington, D.C., and 32,500 in Pennsylvania.
3 Map by G. Carbin, National Weather Service Storm Prediction Center.

The derecho caused widespread disruptions to communications generally and 9-1-1 services
particularly.4 From isolated breakdowns in Ohio, New Jersey, Maryland, and Indiana, to
systemic failures in northern Virginia and West Virginia, a significant number of 9-1-1 systems
and services were partially or completely down for up to several days. In all, at least seventeen
9-1-1 call centers in three states lost service completely, affecting more than 2 million
residents’ ability to reach 9-1-1. One PSAP alone estimates that it did not receive
approximately 1,900 emergency calls during the time it was down.5 Across the storm’s path, at
least seventy-seven PSAPs serving more than 3.6 million people in six states lost some degree
of connectivity, including vital information on the location of 9-1-1 calls; the overwhelming
majority of these full or partial outages suffered by PSAPs were due to problems in providers’
The public’s inability to reach 9-1-1 and obtain emergency assistance during and after the
derecho was not just a theoretical or abstract concern. Whether, and how quickly, help can be
called and a first responder arrives might make the difference between life and death.6 As The
Washington Post
reported, for example, a young man died after being struck by electrical wires
brought down during the derecho. Bystanders who came to his aid and called 9-1-1 reportedly
were not able to get through, even after calling for more than thirty minutes.7 In another
instance, a woman, just a few hundred feet from her Washington, D.C. apartment, was knocked
off her motorcycle and pinned under a tree, leaving her partially paralyzed. She was saved
when passersby, unable to get through to 9-1-1, flagged down an ambulance that provided
help.8 While it does not appear that the large-scale failures of service providers’ 9-1-1 network
infrastructure were factors in these two events (those failures occurred later), these real-life
situations reinforce the critical importance of the successful completion of calls to 9-1-1.
Congress has given the Commission the responsibility under the Communications Act to ensure
that communications networks of all types “promot[e] safety of life and property.”9 Central to

4 See, e.g., Sullivan, Patricia, 911 Failure Affected 2.3 Million in Northern Virginia, WASH. POST, July 11, 2012.
5 See Comments of Fairfax County, Virginia at 2 (Aug. 17, 2012) (“Fairfax County Comments”). These comments
came in response to the Bureau’s July 18, 2012, Public Notice in Public Safety (PS) Docket No. 11-60 seeking input
on the effects of the storm and potential remedies. See Public Safety and Homeland Security Bureau Seeks
Comment On 9-1-1 Resiliency and Reliability in Wake of June 29, 2012, Derecho Storm in Central, Mid-Atlantic, and
Northeastern United States, Public Notice, 27 FCC Rcd 8131, PS Docket No. 11-60, (PSHSB July 18, 2012) (“Derecho
Public Notice.”).
6 One study of cardiac emergencies in Pennsylvania found that E9-1-1 adoption reduced the risk of mortality within
six hours by 60 percent and the risk of mortality within 48 hours by 35 percent. See Athey, Susan and Stern, Scott,
The Impact of Information Technology on Emergency Health Care Outcomes, January 2002, at 32, available at
7 Sullivan, Patricia, Help Delayed For Electrocuted Man As 911 Calls Backed Up During Storm, WASH. POST, July 19,
8 Ruane, Michael E., D.C. Woman Caught In The Derecho Storm Is Left Paralyzed, But Her Attitude Is Optimistic¸
WASH. POST, Aug. 19, 2012.
9 See 47 U.S.C. § 151.

this important responsibility is promoting the reliability, resiliency, and availability of
communications networks at all times, including in times of emergency or a natural disaster
such as the derecho. To that end, the Commission, through the Bureau, administers rules on
communications outage reporting10 and analyzes those reports to identify various
communications outage trends nationwide, especially regarding 9-1-1 capabilities. We use this
information to assess network reliability and make recommendations for both individual
provider and industry-wide improvements.
The severity of the 9-1-1 outages that resulted from the derecho called for a more intensive
review process for this inquiry. Accordingly, in July 2012, Chairman Genachowski instructed the
Bureau to conduct a comprehensive inquiry into the impact of the derecho on 9-1-1 and other
communications. In addition to reviewing data from more than 500 outage reports from
twenty-two communications providers, the Bureau released a Public Notice seeking comment
on issues including the cause of the outages, their effect on public safety, and the resiliency and
reliability of 9-1-1 networks generally.11 In response to that Public Notice, the Bureau received
forty-five filings, including twelve comments and reply comments from communications
providers and trade associations, thirteen from PSAPs and public safety groups, and twelve
from individuals. The Bureau interviewed representatives of eight communications providers
(some multiple times), twenty-eight PSAPs, three battery manufacturers, one generator
manufacturer, numerous state and county entities, and obtained additional information
through six supplemental data requests. In addition, the Bureau participated in several federal,
state, and local meetings and hearings on the effects of the derecho.12
In this report, we present our findings and recommendations. Section 2 provides an overview
of the Bureau’s information gathering process. Section 3 offers a general description of the
derecho’s impact on communications. Sections 4, 5, and 6 describe the derecho’s impact on
three types of communications, specifically wireline, PSAP, and wireless communications. In
Section 7, we offer our recommendations for addressing the specific problems identified in this
report, as well as other suggestions we believe will promote the reliability of our Nation’s 9-1-1

10 See 47 C.F.R. §§ 4.1-4.13.
11 See Derecho Public Notice, 27 FCC Rcd at 8131.
12 See, e.g., “Resilient Communications: Current Challenges and Future Advancement,” Before the Subcomm. on
Emergency Preparedness, Response, and Communications, House Committee on Homeland Security, 112th Cong.
(Sept. 12, 2012) (statement of David S. Turetsky, Chief, Bureau of Public Safety and Homeland Security); “Reliability
of the District’s 911 Call System,” Before the District of Columbia Council Comm. On the Judiciary (Sept. 20, 2012)
(statement of David S. Turetsky, Chief, Bureau of Public Safety and Homeland Security); Metropolitan Washington
Council of Governments – News Room, “COG to Review 9-1-1 Outages and Other Failures Resulting from
‘Derecho’” (rel. Jul. 11, 2012) available at
13 This report not only provides our own assessments, but also includes in the attached appendices preliminary
findings by the Virginia State Corporation Commission (Appendix A); recommendations by the Metropolitan
Washington Council of Governments (Appendix B); and recommendations from various PSAPs interviewed by the
Bureau (Appendix C).

2. PSHSB Information-Gathering Process

Outage Reporting and Developing the Record

The Bureau first became aware of the derecho’s effects on communications infrastructure
when providers began to submit derecho-related Network Outage Reporting System (“NORS”)
reports on June 29, the day the storm struck.14 Communications providers filed a total of thirty-
five NORS reports on June 29; the tally of NORS reports with outages beginning on June 29
would eventually reach 135. Under FCC rules, these reports are presumed confidential to
protect proprietary information and data with sensitive national security implications. 15
Accordingly, outage report data in this public report is presented in the aggregate unless
otherwise agreed by the source of the information or available through other public sources.16
To the extent that information derived from outage reports or other confidential sources
appears in this report, each provider has waived the presumption of confidentiality with
respect to that information.
Figure 1 below shows the number of NORS reports17 by incident date:

14 NORS is the Commission’s mandatory web-based filing system through which communications providers covered
by the Part 4 outage reporting rules must submit reports to the FCC. This system uses an electronic template to
promote ease of reporting and encryption technology to ensure the security of the information filed. The
Cybersecurity and Communications Reliability Division of the Public Safety and Homeland Security Bureau
administers NORS, monitors the outage reports submitted through NORS, and performs analyses and studies of
the communications disruptions reported. Generally, a NORS report must be filed when the effects of an outage
reach a certain threshold (e.g., lasting at least thirty minutes and potentially affecting 900,000 user-minutes).
Then, the filing party has up to thirty days to supplement the filing with more complete information. The NORS
team aggregates the data in order to identify outage trends. See 47 C.F.R. §4.1 et seq. See also Network Outage
Reporting System (NORS),
15 See 47 C.F.R. § 4.2.
16 See New Part 4 of the Commission’s Rules Concerning Disruptions to Communications, ET Docket No. 04-35,
Report and Order and Further Notice of Proposed Rulemaking, 19 FCC Rcd 16830, 16855 ¶ 46 (2004) (noting that
“the analytical substance of these reports is essential to the development and validation of best practices” and
that “[a]s a consequence, we will also use information from those reports in analyses that will enable us to provide
guidance to [advisory bodies and other organizations] in a way that does not provide sensitive information to
those who might use it for hostile, or competitive, purposes”).
17 We note that providers filed in NORS on a rolling basis, with discrete providers filing multiple times during the

Number of NORS Reports by Date


Incident Date

Figure 1: Number of NORS Reports by Date of Incident

Figure 2 provides a geographic breakdown of outage reports.18 As this chart illustrates, the
effects of the derecho were widespread geographically, from Illinois in the west, to New Jersey
in the east, with West Virginia, Maryland, Virginia and Ohio experiencing the largest impact on

Number of NORS Reports by State





Figure 2: Number of NORS Reports by State

18 There were 534 derecho-related NORS reports from June 29 to July 6, 2012. We included outage reports that
mentioned the storm, or that indicated that the outage was power-related. Most of the outage reports were for
events that occurred on June 29 or June 30. We included outage reports for events through July 6 because we
believe that these reports included residual events from the restoration effort, although some of the reports from
July 1 through July 6 may relate to other storms.

Of the 534 outage reports filed, 111 describe effects to wireline users, 161 describe effects to
wireless users, 249 describe effects to transport facilities, and eight reports describe effects to
cable telephone users. In addition, forty-five reports involve 9-1-1 outages. Although there
were numerous outage reports, most of the reported effects were in Virginia, Maryland, Ohio,
and the District of Columbia. West Virginia had many PSAPs affected but relatively few wireline
or wireless users.19 Other states experienced lesser – but not inconsequential –
communications outages related to the storm. In total, more than 1.2 million wireline
communications customers in twelve states experienced outages (not counting other residents
affected by the inability to reach 9-1-1 on all platforms). In addition more than 30,000 high
capacity transport lines (“DS3s”)20 were affected.
On June 30, 2012, the Commission activated a modified and targeted version of the Disaster
Information Reporting System (“DIRS”).21 DIRS allows service providers in the designated area
to submit reports on the status of their networks to the Commission during emergencies on a
voluntary basis.22 Working with the National Cybersecurity and Communications Integration
Center (“NCCIC”) at the U.S. Department of Homeland Security, the Commission activated this
modified version of DIRS at 4:20 p.m. for the following cities and counties:
West Virginia: Berkeley, Hampshire, Harrison, Jefferson, Kanawha, and Wood counties
Virginia: Alexandria, Manassas Park, Prince William County, Loudoun County, Arlington
County, Falls Church, and Fairfax County
Maryland: Montgomery, Prince George’s, Calvert, Charles, Anne Arundel, and Howard
counties, Baltimore City, and Baltimore County
The District of Columbia

19 We note that the derecho’s effects were widespread and severe across West Virginia, but its impact on
population was greatest in densely-populated northern Virginia.
20 A Digital Signal 3 (“DS3”) line is a digital signal level 3 T-carrier. It may also be referred to as a T3 line. The data
rate for this type of signal is 44.736 Mbit/s. See Digital Signal 3, WIKIPEDIA,
21 DIRS is a voluntary, web-based system that communications companies, including wireless, wireline, broadcast,
and cable providers, can use to report communications infrastructure status and situational awareness information
during times of crisis. See Disaster Information Reporting System (DIRS), Information submitted into DIRS is presumed
confidential but may be shared with federal agencies such as the Department of Homeland Security on a
confidential basis. See The FCC’s Public Safety and Homeland Security Bureau Launches Disaster Information
Reporting System (DIRS), Public Notice, DA 07-3871 (PSHSB 2007).
22 Sometimes a modified version of DIRS is activated, which calls for only certain fields in the system to be
completed and only by certain types of communications providers. During the derecho, for example, the
Commission did not seek DIRS data from companies such as broadcasters, who were generally understood to be
less adversely impacted by this storm.

Overall, the Bureau received DIRS submissions from seven communications providers.

Additional Information from Communications Providers

Shortly after the storm, the Bureau began a series of meetings with cable, wireline, and wireless
providers, particularly those serving Virginia and West Virginia, and issued several follow-up
requests for additional confidential information to supplement the NORS and DIRS data. In
particular, the Bureau asked Verizon Communications, Inc. (“Verizon”) and Frontier
Communications Corporation (“Frontier”), the 9-1-1 service providers23 in the most severely
affected areas, to provide a detailed timeline of events relating to each PSAP in their service
areas affected by the derecho. In addition to information about the cause of each outage, we
asked for a description of the 9-1-1 architecture that supports each PSAP that lost service. The
Bureau also asked the major wireless providers serving the affected areas—Verizon Wireless,
AT&T, Sprint, and T-Mobile—for additional information on the causes of cell site outages during
the storm and for information on cell site battery life. Follow-up requests were made of these
and other providers, who supplied the Bureau with supplemental reports and explanatory e-

Providers generally were cooperative and responsive to our requests for information. One
issue, however, affected the scope and timing of our inquiry. Information originally made
available to the Bureau about whether the generators were in working order just prior to the
storm at Verizon’s Arlington central office, where a loss of power severely affected 9-1-1
service in northern Virginia, differed from later accounts. Verizon indicated to the Bureau and a
number of governmental entities at a meeting of the Metropolitan Washington Council of
Governments (“MWCOG”), and on other occasions in July 2012, as reported by The Washington
, that the critical generators at its Arlington central office had functioned properly during a
maintenance test just days prior to the derecho.25 However, the Bureau learned from the
Virginia State Corporation Commission (“SCC”) Preliminary Staff Report (“Virginia SCC Report”)

23 “9-1-1 service providers” are responsible for routing and delivering 9-1-1 calls to PSAPs. In the current 9-1-1
system, the “provider” of 9-1-1 service and associated network facilities is typically the incumbent local exchange
carrier (“ILEC”) in a given area, which aggregates and delivers all incoming 9-1-1 calls (including those originating
from other providers, such as wireless providers and VoIP providers) to the PSAP via selective routers. Next-
generation technologies such as emergency services Internet protocol networks (“ESInets”), however, may change
that pattern by more easily allowing entities other than ILECs to provide 9-1-1 service.
24 At publication of this report, Verizon supplemented its responses with a series of documents not provided
earlier that the Bureau will review.
25 Verizon’s statements about the generator test were reported in the press. See Sullivan, Patricia, 911 Failure
Affected 2.3 million in Northern Virginia
, WASH. POST, July 11, 2012 (reporting that a Verizon representative told the
MWCOG that “[b]oth generators underwent routine testing three days earlier”); Sullivan, Patricia and Flaherty,
Mary Pat, Verizon, 911 Service Providers Out of Sync on Storm Outage, WASH. POST, July 12, 2012 (reporting that
“one of the [Arlington] generators, which had worked smoothly in a routine test three days before, would not
start”); Flaherty, Mary Pat, Verizon Details Errors in Derecho, Calls Response to 911 Outages ‘Insufficient,” WASH.
POST, August 13, 2012 (repeating Verizon’s public statement that “the generators failed . . . despite having been
tested three days earlier”).

when it was publicly released on September 14, 2012, that the Arlington central office
generator did not pass the test, as confirmed by Verizon’s own maintenance logs.26

Additional Information from PSAPs

In order to gather information regarding PSAP responses to the derecho, the Bureau
interviewed personnel from twenty PSAPs in West Virginia, five PSAPs in Virginia, and three
PSAPs in Ohio. We also considered public comments filed by Fairfax County, Virginia, as well as
reply comments filed by Loudoun County, Virginia, and Montgomery County, Maryland, and an
ex parte letter from Arlington County, Virginia.27 These comments, meetings, and telephone
calls greatly improved our understanding of what happened during the storm and informed the
recommendations we offer in this report to improve and strengthen 9-1-1 infrastructure and

Public Comments in Response to Public Notice

On July 18, 2012, the Bureau released a Public Notice seeking public comment on the
background, causes, and restoration efforts related to communications services and facilities
impacted directly or indirectly by the derecho.28 Specifically, the Bureau sought to develop a
complete and accurate record of all the facts surrounding the outages resulting from the storm
as well as outages resulting from other relevant natural disasters in order to evaluate the
overall resiliency and reliability of the Nation’s 9-1-1 system and services. The Bureau also
sought comment on the impact the outages had on various segments of the public, including
consumers, hospitals and public safety entities.29 In response, the Bureau received forty-five
filings, including twelve comments and reply comments from communications providers and
trade associations, thirteen from PSAPs and public safety groups, and twelve from individuals.30

26 See Virginia State Corporation Commission, In the Matter of Investigating 911 Emergency Call Service Outages
and Problems, Case No. PUC-2012-0042, Staff Report of Preliminary Findings at 8 (Sept. 14, 2012) (“Virginia SCC
Report”) (finding that the generator that failed to start in the Arlington central office did not start during routine
testing two days before the derecho and noting also that “[a] review of the maintenance logs for the backup
generators in the Arlington and Fairfax central offices shows a lack of compliance with Verizon’s maintenance and
testing procedures”). See also Flaherty, Mary Pat, Verizon ‘Failures and Deficiencies’ Blamed in Disruption of 911
Services During June Storm
, WASH. POST, Sept. 14, 2012 (quoting a Verizon spokesman as saying that the company’s
previous statement that the generator started successfully “was based on our knowledge at the time”).
27 See Fairfax County Comments; Reply Comments of Loudoun County, Virginia (Aug. 29, 2012); Reply Comments of
Montgomery County, Maryland (Sept. 4, 2012); Ex parte Letter from Joseph N. Pelton, Chair, Arlington County
(Virginia) Information Technology Advisory Committee, to FCC Chairman Julius Genachowski (Sept. 5, 2012).
28 See Derecho Public Notice, 27 FCC Rcd at 8131.
29 See id.
30 See, e.g., Comments of Dianna Arens, PS Docket No. 11-60 (urging undergrounding of wires and cutting back
trees where undergrounding unfeasible) (Jul. 20, 2012); Comments of Robert F. Duffy, PS Docket No. 11-60 (raising
issues related to battery lifespan) (Aug. 7, 2012); Comments of Phillip Wherry, PS Docket No. 11-60 (suggesting
questions that the Commission ought to address to providers) (Jul. 20, 2012).

Industry Best Practices

The Commission and Bureau have worked with a variety of industry and public safety
organizations to develop voluntary solutions and recommendations to improve the reliability of
emergency communications. In 2011, for example, the Bureau joined with the Alliance for
Telecommunication Industry Solutions (“ATIS”) Network Reliability Steering Committee
(“NRSC”) to develop recommendations to prevent failure of centralized automatic message
accounting (“CAMA”) 9-1-1 trunks during mass call events, such as the spikes in 9-1-1 calling
from natural disasters.31 Similarly, the Communications Security, Reliability, and
Interoperability Council (“CSRIC”)32 is a chartered federal advisory committee tasked with
developing recommendations for the Commission on actions to enhance the security,
reliability, and interoperability of communications systems.33 Many CSRIC recommendations
are voluntary “best practices” that the Bureau and stakeholders within the telecommunications
industry encourage providers to implement at their discretion.34 As such, these best practices
are generally not codified in Commission rules, and the Bureau gauges their implementation
primarily through its review of providers’ mandatory outage reports.
For reasons explained below, communications failures during the derecho revealed that many
providers failed to implement crucial best practices developed by CSRIC that could have
mitigated or prevented many of the storm’s most serious effects on communications networks,
including 9-1-1 service outages. This failure, and the resulting damage, was costly.
3. Overview of the Derecho’s Impact on Communications
The derecho affected communications in eleven states and the District of Columbia, with the
greatest effects felt in Virginia, West Virginia, Maryland, and Ohio. Most significantly, the
derecho disabled 9-1-1 service in counties in Virginia, West Virginia and Ohio, with the greatest
number of people affected living in northern Virginia. Four northern Virginia PSAPs lost 9-1-1
service completely: Fairfax and Prince William Counties, Manassas, and Manassas Park. These

31 See NRSC 9-1-1 CAMA Trunk Throughput Optimization Analysis (ATIS-0100034) (rel. Aug. 2011), available at
32 See FCC Encyclopedia, Communications Security, Reliability, and Interoperability
CSRIC replaces the Network Reliability and Interoperability Council (“NRIC”), which performed a similar role from
1992 until CSRIC’s creation in 2007. Members for each CSRIC have been selected from among commercial
communications entities, public safety agencies, and consumer or community organizations or other non-profit
entities to provide a diverse balance of expertise and viewpoints.
33 See CSRIC Charter,
34 The volume of CSRIC best practices (including those developed by CSRIC’s predecessor organization NRIC) has
grown to several thousand and covers a wide range of issues involved in providing communications services. In
January 2011, CSRIC prioritized these best practices in an effort to help communications providers focus their
application. All of the best practices and the prioritization are available on the Commission’s website. See

9-1-1 communications failures resulted, in significant part, from the loss of commercial power
followed by generator failures in Verizon’s Arlington and Fairfax central offices. Under current
9-1-1 architecture, the networks of incumbent wireline providers typically connect 9-1-1 call
centers to those seeking help, whether the call for assistance originates on a landline or a
wireless phone. Wireline outages, therefore, can have a more sweeping impact on 9-1-1
service than wireless outages. Below is a more detailed summary of our findings.

Most Significant Wireline Service Impacts:

The derecho had significant effects on wireline communications infrastructure and
resulted in partial or complete 9-1-1 service outages lasting up to several days for
customers in large swaths of northern Virginia, West Virginia, and Ohio. The 9-1-1
connections affected by the derecho in Virginia are served by Verizon and CenturyLink.
Frontier serves the affected PSAPs in West Virginia. Ohio’s affected PSAPs are served by
Frontier, CenturyLink, and AT&T.
The greatest service losses occurred in northern Virginia as the result of backup power
failures in Verizon’s Arlington and Fairfax central offices. The service losses included
multiple switches in Virginia that became “SS7 isolated,”35 isolated 9-1-1 switches, and
major transport system failures.
More than a dozen of Verizon’s host switches and more than three dozen remote
switches in Virginia went out of service or were SS7 isolated from the
telecommunications signaling network.
A significant amount of transport equipment failed, according to Verizon, because of
power surges and low voltages in central offices. For example, more than 200 circuit
boards in one of Verizon’s digital cross-connect systems36 failed and had to be replaced.

35 SS7 is a global standard for telecommunications defined by the International Telecommunication Union (“ITU”).
The standard defines the procedures and protocol by which network elements in the public switched telephone
network (“PSTN”) exchange information over a digital signaling network to effect wireless and wireline call setup,
routing and control. See Performance Technologies, Inc., SS7 Tutorial,
tutorial. A switch becomes “SS7 isolated” when it cannot communicate with the rest of the SS7 network, meaning
that interoffice calls cannot be completed. In practical terms, this means that only the most local of calls that
originate and terminate through the same central office will go through.
36 A digital cross-connect system is a piece of circuit-switched network equipment that allows lower-level time-
division multiplexing (“TDM”) bit streams to be rearranged and interconnected among higher-level TDM signals.
These devices can be used for switching traffic from one circuit to another in the event of a network failure,
supporting automated provisioning, and other applications. See Digital Cross Connect System, WIKIPEDIA,

Most Significant Wireless Service Impacts:

Overall, the wireless networks in the path of the derecho were adversely impacted, but
performed better than during other powerful storms that the Bureau has tracked since
establishing NORS, with just about 11 percent of all cell sites in the affected area down
at the peak and a rapid restoration of service from July 2 through July 4. Among the
states affected by the derecho, West Virginia suffered the greatest percentage of cell
sites lost. No mobile switching centers were down during the storm. Failure of cell site
infrastructure was a bigger concern during Superstorm Sandy than in the derecho, and
the Bureau expects to learn considerably more on this issue through upcoming field
hearings and related work.37
The two main reasons reported for cell site outages were loss of power and the
disabling of transport facilities that carry calls from cell sites to mobile switching
centers. Cell sites were as likely to fail because of disruptions to landline backhaul
communications as due to backup power exhaustion in the first days following the
derecho. Still, backup power remains a serious concern for cell sites. The Bureau also
learned that many service providers do not retain and analyze over time data
concerning how long batteries called upon to power cell sites actually last. This
information would seem helpful when making plans to replenish power to sites before
battery power is exhausted.
Even where wireless networks remained operational, data and anecdotal evidence
suggest that many wireless customers still could not reach 9-1-1 or complete calls to
landlines because of coverage or congestion problems in wireless access networks and
disruptions across the PSTN as a whole.38
Less densely-populated West Virginia suffered the greatest percentage of cell sites lost,
making that state susceptible to having sizeable areas in which some residents may not
have had any wireless coverage at all.39 More urban areas, with their higher cell
density, are more likely to get coverage during disasters – although any such service
may suffer from higher network congestion during disasters since the available
resources are shared across more users.

37 See FCC Chairman Genachowski Announces Post-Superstorm Sandy Field Hearings to Examine New Challenges to
Resiliency of U.S. Communications Networks During Natural Disasters & Other Times of Crisis, News Release (Nov.
21, 2012) (“Superstorm Sandy Field Hearings PN”).
38 See, e.g., Sullivan, Patricia, After Storm, 911, Phone Service Remains Spotty, WASH. POST, July 2, 2012 (reporting
that a Washington, D.C., resident’s cell phone “dropped half a dozen calls” and could not receive text messages for
several hours).
39 See Cart, Kallie, Metro 911 Outage Causes Problems at Emergency Operations Center, WCHS EYEWITNESS NEWS,
July 1, 2012 (reporting that “in some areas, cell service is sketchy,” and “the best thing to do is rely on your

Other Communications Issues

The key role broadcasters played during and following the derecho should also be recognized.
As in many times of crisis, broadcasters served as “first informers,” providing the public with
information on the storm’s path, the damage it caused, and its effects on other
communications services.40 Even where citizens affected by the storm lost commercial power,
many could still receive radio and television broadcasts on battery-powered devices.41 PSAPs
and other public safety entities took advantage of this capability by working together with
broadcasters to provide updates on 9-1-1 service and alternate ways of obtaining emergency
assistance.42 For instance, some reports advised residents to call 9-1-1 only for true
emergencies, and provided ten-digit administrative numbers for other questions about cooling
shelters and restoration of power.43
Since the June derecho, other regions of the United States have experienced significant
weather-related disasters. In August 2012, Hurricane Isaac struck the Gulf Coast,44 and in
October 2012, Superstorm Sandy struck the Eastern Seaboard – most destructively in New York
and New Jersey.45 While all three of these events had major impacts on communications, the
aftermath of the derecho stands out for having the most devastating impact on networks
connecting citizens to 9-1-1 call centers. As discussed in depth below, the derecho resulted in
switch failures and massive outages to 9-1-1 communications; the derecho thus revealed
critical 9-1-1 and core backup power issues. In contrast, available data indicates that problems
with 9-1-1 communications networks, including switches, were not as glaring in the regions
impacted by Isaac or Sandy; powerful as those storms were, most of the basic 9-1-1
infrastructure appears to have held, and there were no reports of widespread, prolonged
inability to reach emergency services through 9-1-1 due to network outages. There were,
however, problems receiving location information and other data with some calls, and
individual PSAPs may have had isolated, non-network issues.
Because the derecho was swift and unanticipated, it differed from hurricanes and superstorms,
like Isaac and Sandy, for which there typically is advance warning and an opportunity for
communications providers to prepare by testing equipment, adjusting staffing levels and

40 See Comments of the National Association of Broadcasters, PS Docket No. 11-60, at 1-2 (Aug. 17, 2012).
41 See id.
42 See Fairfax County Comments at 12-13, Exhibit 3 (describing Fairfax County’s efforts to communicate with
residents during the derecho through social and traditional media). But see No Answer at 911, WASH. POST, July 20,
2012 (“Local officials, desperate to get the word out, resorted to traditional and social media – which in turn were
not accessible to many people who lost power and cellphone service.”).
43 See Cart, Kallie, Metro 911 Outage Causes Problems at Emergency Operations Center, WCHS EYEWITNESS NEWS
ONLINE, July 1, 2012 (providing ten-digit numbers for non-emergency questions).
44 See, e.g., Robertson, Campbell and Severson, Kim, Isaac Drenches Gulf Coast and High Water Cuts Off Many, N.Y
TIMES, Aug. 29, 2012.
45 See, e.g., Barron, James, Storm Barrels Through Region, Leaving Destructive Path, N.Y. TIMES, Oct. 29, 2012.

supplementing training over an extended period of time. As noted, the derecho arrived with
very little notice, and in that sense, had more in common with an earthquake, tornado, or man-
made event. Nonetheless, all three events (i.e., the derecho, the hurricane, and the
superstorm) highlighted shortcomings in the reliability and resiliency of communications, and
raised concerns about commercial power and telecommunications providers’ implementation
of procedures to ensure adequate backup power.46 Moreover, such events shed light on the
possible impact of power outages on consumers who rely at their premises on communications
devices that operate on commercial power (as opposed to power through a copper telephone
line) and/or have a limited battery life (e.g., cordless phones, Voice over Internet Protocol
(“VoIP”)47 equipment, and cell phones).48 These and other vital issues will be considered more
fully after the Commission has concluded its field hearings, which will include those topics.
4. The Derecho’s Effects on Wireline Networks
In this section, we review the derecho’s impact on core wireline networks. This impact was
widespread and severe not only for wireline customers, but also for users of other
communications services that rely on the wireline network. Most notably, because certain
wireline infrastructure supports 9-1-1 calls placed from wireless as well as wireline phones, the
failures discussed in this section affected 9-1-1 service for both wireless and wireline
4.1 Backup Power Problems
The derecho exposed significant vulnerabilities in wireline providers’ central-office
infrastructure, specifically backup power systems designed to maintain service during
commercial power outages. Verizon in particular reported a significant number of backup
generator failures, resulting in the failure of key network components and the loss of vital
communications services to customers across much of the Mid-Atlantic region. According to
Verizon, nine out of 136 central-office backup generators in Verizon’s service area affected by

46 See, e.g., Chen, Brian, Cellphone Users Steaming at Hit-or-Miss Service, N.Y. TIMES, November 2, 2012. See also
Press Release, U.S. Senator Charles E. Schumer, Schumer Calls on Federal Communications Commission To Ensure
That Vital Communications Networks Aren’t Cut After Storms or Power Failures
(Nov. 19, 2012) (stating that
“thousands of residents and first responders [were] left without vital cell service in the wake of Sandy, hindering
response and endangering lives,” and calling for a “plan to ensure continuation of cell service in the wake of
47 VoIP can refer to facilities-based services, interconnected services, and services that do not connect to the PSTN.
VoIP technologies generally differ from traditional telephone service in that VoIP operates on commercial power
rather than power from a central office through a copper line. This can have impacts for customers if commercial
power is lost for long periods of time.
48 See Metropolitan Washington Council of Governments 9-1-1 Telecommunications Network Steering Group,
Preliminary Report of 9-1-1 Service Gaps During and Following the Derecho Storm on June 29, 2012 (Nov. 14,
2012) at 16 (“MWCOG Report”) (calling for increased awareness of the “vulnerability of newer technologies that
require battery or backup power”).

the derecho did not operate properly.49 Thus, about 7 percent of Verizon’s generators in
central offices failed to operate properly when needed.
Frontier also reported generator failures in West Virginia and Ohio, causing service disruptions
in those states. Some Frontier remote terminals were not equipped with backup generators,
and the vulnerability of portable generators placed at other sites led to additional difficulties
supplying power to these facilities.
4.1.1 Backup Power Problems in Virginia
Verizon acknowledges that generator failures in its Arlington and Fairfax central offices after
the loss of commercial power were the primary causes of the 9-1-1 network failures in northern
Virginia.50 In addition, these backup power failures caused widespread communications
disruptions across Virginia. For example, critical switching and transport equipment was lost
when the Arlington central office went down, seriously impacting Verizon’s network in northern
Virginia. In Fairfax, loss of transport equipment made inter-switch communications impossible,
which also had broad impacts on customers and PSAPs alike. Together, these problems
resulted in more than a dozen switches being SS7 isolated. Because of their importance, we
discuss the effects at each office separately.

Verizon’s Arlington Central Office

The Arlington central office played an important role in the delivery of 9-1-1 services in much of
northern Virginia, yet it is not clear Verizon understood the extent of this vulnerability until
after the derecho. The failure of backup power at the Arlington central office directly resulted
in the loss of 9-1-1 service to residents in northern Virginia, key switching capabilities, and
virtually all of Verizon’s network monitoring capabilities in the area. These high-impact failures
could have been prevented, or at least mitigated, through the application of CSRIC best
practices and other sound engineering practices.
The specific events leading to the loss of 9-1-1 service are as follows: At 10:55 p.m. on June 29,
the Arlington central office lost commercial power. The backup power system at the Arlington
site includes two generators that must operate in tandem to power the facility, which
contravenes CSRIC best practice 8-7-5281.51 According to Verizon, one of the two generators

49 See Verizon, 911 Service and the June 29, 2012, Derecho at 1, footnote 1 (Aug. 13, 2012) (“Verizon Public
50 See Comments of Verizon and Verizon Wireless at 2 (Aug. 17, 2012) (“Verizon Comments”); Verizon Public
Report at 2.
51 CSRIC Best Practice 8-7-5281 provides that “[n]etwork operators, service providers and property managers with
buildings serviced by more than one emergency generator, should design, install and maintain each generator as a
standalone unit that is not dependent on the operation of another generator for proper functioning, including fuel
supply path.” See

failed to start because air had entered the fuel system.52 Consequently, the second generator
became overloaded and automatically shut down.53 A power technician arrived at 12:28 a.m.
on June 30 but could not start the generator.54 Verizon personnel also attempted to connect a
mobile replacement generator, but commercial power was restored before the portable
generator could be brought online.55 Without any power from backup generators, Verizon’s
Arlington central office ran on battery power for approximately six hours until the batteries ran
out around 5:00 a.m. on June 30.56 According to Verizon, some network equipment is
particularly sensitive to low voltages and failed even before the batteries were completely
exhausted.57 Commercial power was restored to the Arlington central office at 12:45 p.m. on
June 30, about eight hours after the batteries fully depleted.58
Although it contravenes a best practice to rely on two generators in tandem to power an entire
central office, providers should at a minimum develop procedures to power critical equipment
with one generator if the other fails, or to add a third generator, thereby preventing a complete
loss of service. In Arlington, according to Verizon, the procedures for getting the working
generator online were complicated and were not available to the on-site technicians during the
derecho. Verizon has since developed procedures for bringing one generator online and
shedding non-essential electrical loads when the other generator in a pair fails. Verizon also
states that it is adding a third generator backup, and may take steps to make additional backup
generators easier to connect.
Generators are critical equipment needed during disasters, when commercial power often fails.
Here, Verizon’s Arlington generators powered a key central office with critical network
equipment. An important central office such as this should not be left in a vulnerable state in
which a commercial power failure could result in all the equipment in a central office failing.
Worse, Verizon allowed this critical facility to operate with effectively no backup generator
power because one Arlington generator had failed to start during routine testing before the
derecho and a single generator could not power the entire office.
Verizon also stated that actual load testing of the Arlington generators had been suspended
since at least 2011 because of a problem with the uninterruptible power supply (“UPS”) in that
office. Verizon’s standard operating procedures appear to require monthly generator tests

52 See Verizon Public Report at 3-4.
53 See id. at 3.
54 See id.
55 See id.
56 See id.
57 See id.
58 See id.

under actual site load.59 Yet, it does not appear that Verizon corrected the UPS problem at the
Arlington central office to permit actual site load testing of the generators until after the
derecho. That fact means that, for at least several months, Verizon failed to follow its own
maintenance procedures.
Finally, the Arlington office was crucial to Verizon’s ability to use its geographically distributed
network operations centers (“NOCs”) to monitor the status of equipment at thirty-four sites
across its northern Virginia network.60 For example, multiple Verizon NOCs provided visibility
about the operating status of critical assets in northern Virginia, but these NOCs were
interconnected only through the Arlington hub, which Verizon is now in the process of
diversifying. Having a single point of vulnerability that affects monitoring of such a large and
densely populated service area is unwise because communications providers rely heavily on
telemetry data to identify failing equipment, determine staffing levels, and prioritize repairs
during a disaster. Backup power for the monitoring equipment in Arlington was provided by a
UPS that lasts only thirty minutes.61 Thus, thirty minutes after losing commercial and generator
power in Arlington, and shortly after the rest of the Arlington office went on battery power,
Verizon lost the ability to monitor its network in northern Virginia, crippling its repair efforts
and ability to receive alarms that signal additional equipment failures.62 Accurate telemetry is
essential to restoring service effectively after an outage, and leaving network monitoring
equipment solely supported by a thirty-minute UPS, let alone at such a critical point, is not
adequate backup power.

Verizon’s Fairfax Central Office

Like Arlington, Verizon’s Fairfax central office is a major hub for routing calls in northern
Virginia. In addition to housing several switches, the Fairfax central office also hosts a large
collection of transport equipment used to route 9-1-1 calls in the area.
The Fairfax central office has two backup generators, each powering different network
components on different floors.63 When commercial power failed at 10:35 p.m. on June 29, the
generator on the second floor failed to start because of a malfunction in the auto-start
mechanism.64 The second floor of the Fairfax office was powered for several hours by

59 Testing under actual site load means that the office is switched off the commercial power grid onto generator
power. Unlike testing with simulated load banks, this method verifies that the generator can power the office in
an emergency.
60 See Verizon Public Report at 3; Virginia SCC Report at 9.
61 See Virginia SCC Report at 9. The telemetry equipment used to terminate the monitoring links apparently
requires line power, not the direct current (“DC”) power provided by the battery plant typically deployed in central
offices like Arlington.
62 See Verizon Public Report at 3; Virginia SCC Report at 9.
63 See Verizon Public Report at 3.
64 See id. at 4.

batteries. However, by 2:30 a.m. on June 30, the battery voltage had dropped below the level
needed to power some equipment on the second floor, and by 6:15 a.m. on June 30, the
voltage was too low to power any equipment.65 According to Verizon, when a technician
arrived in the office around 7:30 a.m. on June 30, the technician noticed that the generator on
the lower floor was functioning but failed to check the generator on the second floor.66 By
12:15 p.m. on June 30, according to Verizon, the technician noticed the problem and manually
restarted the second generator.67
The error that Verizon describes could – and should – have been prevented through better
internal procedures and training and improved communication with technicians in the field. Of
course, it is not clear that the technician knew about equipment failures in the Fairfax office in
light of Verizon’s inability to monitor its network. For important buildings with more than one
generator, the procedures for determining the effects on power should include verifying that
each generator is functioning.
Furthermore, a miscommunication within Verizon about the severity of the problem in the
Fairfax office appears to have hindered restoration efforts. Although Verizon received a
“battery on discharge” alarm signifying a power failure at the Fairfax office, the alarm was
labeled “major” rather than “critical,” reducing its priority in the maintenance process.68 When
batteries in a central office are draining because of a generator failure, the alarms for these
conditions should be labeled “critical” and resolved urgently.69

Other Verizon Generator Problems

As noted previously, Verizon reported nine generator failures out of 136 central office backup
generators in its impacted service area.70 In addition to the failures mentioned above at the
Arlington and Fairfax central offices, there were generator failures at Verizon facilities in
Virginia and Maryland resulting from factors such as blown fuses, exhausted start batteries, a
faulty voltage regulator, and failure of an auto-refueling mechanism. One generator initially
started but failed to produce adequate power under load until a technician manually shed non-
essential loads. At one location, Verizon personnel were able to connect a portable
replacement generator before commercial power was restored.

65 See id. at 3.
66 See id. at 4.
67 See id.
68 See Virginia SCC Report at 9.
69 It is our understanding that Verizon has committed to do this. See Verizon Comments at 32 (stating that “[w]e
have enhanced our notification and mobilization procedures to trigger activity more quickly when batteries are
activated or when telemetry is lost”).
70 See Verizon Public Report, at 1, footnote 1.

Notably, Verizon could not locate maintenance logs for one of the generators that failed when
the Bureau requested that information. Although Verizon states that its “rigorous network
resiliency and service restoration practices largely worked as designed throughout most of the
area affected by the Derecho,”71 the Bureau has serious concerns regarding Verizon’s actual
repair practices and compliance with its own maintenance policies.
4.1.2 Backup Power Problems in West Virginia
In West Virginia, generator failures also led to disruptions in communications over Frontier’s
network, affecting more than 15,000 wireline customers. Commercial power outages following
the derecho forced 126 of Frontier’s 230 wireline facilities in the state to operate on generator
power.72 Many Frontier remote terminals are not equipped with backup generators due either
to their small size or physical location. In St. Albans, West Virginia, a central-office backup
generator operated for approximately twenty-two hours before failing because of a broken
belt, resulting in telephone service outages to over 8,600 customers for more than three
hours.73 Generator problems in Petersburg and Worthington, West Virginia, affected more
than 3,300 customers, and issues with four smaller generators in remote facilities disrupted
service to another 3,700 customers across the state. Although Frontier deployed mobile
generators in some locations, as many as twenty were stolen from Frontier facilities in the
storm’s aftermath, causing additional backup power failures.74
4.2 Switch Effects
4.2.1 Verizon Switch Effects
During the derecho, more than a dozen Verizon host switches went out of service in areas
ranging from Baltimore, Maryland, to Richmond, Virginia. Ten of these were SS7 isolated75 due
to transport failures in Verizon’s network, and four lost power because of generator failures.
Over three dozen of Verizon’s remote switches also went out of service during the storm. In all,
nearly 1 million wireline customers lost service for durations ranging from two hours to more
than two days.

71 See Verizon Comments at 2.
72 Comments of Frontier Communications Corp. at 2 (Aug. 17, 2012) (“Frontier Comments”).
73 See generally Frontier Comments at 4 (stating that “generator use . . . was not a foolproof solution” and that
“[i]n some instances back-up generators pre-placed in the [c]entral [o]ffices failed, which led to outages while
Frontier replaced those generators”).
74 See Frontier Comments at 5; Workman, Megan, Frontier, Suddenlink Bills Will Be Prorated, THE CHARLESTON
GAZETTE, July 10, 2012 (reporting that “[t]hieves stole generators at multiple Frontier facilities, which affected
service to customers”); Staff Report, Eleven Arrested in Storm Generator Thefts, THE CHARLESTON GAZETTE, July 26,
75 See supra, note 35.

In the Bureau’s view, Verizon could not initially explain the routing of key circuits in its network
when the Bureau inquired how failures in one office could affect communications in other
areas. Based on this uncertainty and the time that passed before we received this information,
it is clear to the Bureau that Verizon was not fully aware of the routing of its own critical circuits
until a considerable time after they failed.
4.2.2 Switch Effects in West Virginia
According to Frontier, the derecho caused five host switches and more than thirty remote
switches to fail or become isolated across West Virginia, impacting more than 50,000 wireline
customers. The major causes of these failures included fiber cuts and extended commercial
power outages leading to drained backup batteries. Not all power-related switch outages
involved generator failures, however, because it is not always feasible to equip smaller
switching hubs with backup generators. Frontier also lost the ability to monitor its network in
West Virginia, preventing it from receiving network alarms and disrupting its ability to reroute
9-1-1 calls. Frontier attributed this problem to a combination of a fiber cut, which caused the
initial outage, and the fact that it had disconnected a backup circuit, which would have
provided needed redundancy, a week prior to the storm. Without functional network
monitoring, Frontier’s NOCs obtained network access through a more time-consuming dial-up
network before they could begin rerouting 9-1-1 calls.
Individual Frontier host switch outages affected between 870 and 8,600 customers each and
lasted from 3.3 hours to more than seven days. Frontier also experienced more than thirty
remote switch outages affecting approximately 31,000 customers. Individual remote switch
outages affected between 127 and 4,800 customers for five hours to nearly ten days and were
caused by loss of commercial power and subsequent exhaustion of backup power, SS7
isolation, and transport network failures.
4.3 Effects on Transport Equipment
The derecho had a significant effect on transport equipment. This equipment supports network
traffic of all kinds, from 9-1-1 calls to everyday communications. For example, more than 600
circuit boards in high-capacity digital cross-connect systems in Verizon’s network were
destroyed, likely by power surges or the low voltage that occurred as batteries drained. With
one digital cross-connect system, approximately 200 circuit packs failed when fuses mounted
on each circuit board blew.

Proposed Corrective Actions from Wireline Providers

4.4.1 Corrective Actions Proposed by Verizon
Since the Bureau began its inquiry, Verizon has submitted materials to the FCC and other
regulatory bodies indicating that it has repaired defective equipment, revised internal policies,

and taken other measures to prevent similar failures in the future. Some of these changes have
already occurred in areas affected by the derecho, while others are planned to be implemented
over time in other service areas.
In July 2012, Verizon and metropolitan Washington PSAPs agreed on a set of immediate
actions, including adoption of the National Incident Management System (“NIMS”) model for
disaster response; use of a Reverse 9-1-1® type system to notify PSAPs of known or suspected
9-1-1 outages; semi-annual 9-1-1 outage drills; and a current contact list of Verizon personnel,
escalating to the vice-president level, that PSAPs can reach directly in the event of an outage.76
Area PSAPs also requested a Verizon representative to be physically present at each
jurisdiction’s operations center during an emergency, although Verizon has said it is exploring
“virtual participation” through electronic communications. As of November 2012, Verizon and
MWCOG reported that these steps are in “various stages of completion.”77
According to filings in PS Docket No. 11-60 and other fora, Verizon also has committed to the
following remedial actions:
Backup power system audits of “mission critical” facilities in the Washington
metropolitan region, including the Arlington and Fairfax central offices.78
A complete review and update of monthly and annual preventative maintenance
requirements for generators, batteries, and rectifiers that supply power at host central
offices. Power technicians will be trained in critical facility “blackout” testing to
simulate total commercial power failure, as well as manual generator start procedures
and “prioritized system load transfer” scenarios to distribute backup power to critical
A redesign of its telemetry network to ensure that it conforms to new diversity
guidelines adopted by Verizon in August 2012, after the derecho. Verizon has
committed to redesigning its E-9-1-1 tandem architecture in Virginia according to these
· Meetings with the Fairfax County, Prince William County, Manassas, and Manassas Park
PSAPs to discuss 9-1-1 trunk diversity improvements specific to each jurisdiction.81

76 See Verizon Public Report at 7-9; MWCOG Report at 9.
77 See MWCOG Report at 9.
78 See Verizon Comments at 5.
79 See Verizon Public Report at 5; Verizon Comments at 5.
80 See Verizon Comments at 5.
81 See Verizon Public Report at 6 (stating that “Verizon will work directly with the specific PSAP partners to decide
on improvements”).

Verizon also notes that its wireline division’s practices for follow-up when a generator fails a
routine test are being incorporated into a standard, company-wide policy. Specifically:
The power technician immediately contacts the supervisor if a power equipment
deficiency is identified that has potential for broader impact on network power or
network reliability, prior to leaving the site.
The power technician and supervisor jointly assess the criticality of the problem and
formulate and implement a multi-solution “action plan.” The action plan can involve
the purchase of new parts, contacting appropriate vendors, procuring a portable
generator, and escalating service restoration with the utility, as appropriate. The
supervisor will provide the area manager with initial notification, and the area manager,
in turn, will communicate the information upward to director-level management and
above as necessary.
The power technician updates the National Power Network Operations Center and e-
mails other members of the local power team, advising them of the abnormal condition
and current action plan. The supervisor and/or vacation coverage supervisor (if
applicable) are copied on the e-mails.
The supervisor updates the area manager with the action plan, and the area manager
will communicate the information upward to director-level management and above as
The supervisor submits a “jeopardy report” (depending on the nature and impact of the
outage) following site stabilization.
The Bureau believes that these actions are appropriate steps, but are not yet sufficient based
on the Bureau’s assessment of the information it has received thus far. Verizon correctly notes
positive changes in its backup power and network diversity policies and progress in
implementing improvements, particularly in the region that includes Virginia, with respect to
the facilities most relevant to the provision of connections vital to 9-1-1 service, even as it
recognizes it has more to accomplish. It also has much more to do nationwide. For example,
we have not received information that would lead us to conclude that Verizon has determined
yet whether it has other generator configurations similar to Arlington across its entire footprint,
although it states that it is working to do so, with a specific budget and timetable, and has
made that determination in some areas. There also are metrics as to which we have not
received information to assess—e.g., whether Verizon has committed to maintain central-office
backup power for any specific length of time or established specific timeframes for generator
repairs. Valuable progress on the auditing of 9-1-1 circuits in some areas has been made, even
as further information is sought about the timetable and budget for completing the task
throughout Verizon’s relevant service areas. Moreover, this inquiry has raised significant
concerns about the extent to which Verizon has followed its stated maintenance procedures in

the past. It would be beneficial if Verizon provided additional clear and specific commitments,
with budgets and specific timetables for implementation of upgrades and improvements.
4.4.2 Corrective Actions Proposed by Frontier
Frontier’s public comments provided the following list of “lessons learned” based on its
investigation into the derecho’s impacts on PSAPs. Generally, the Bureau agrees with Frontier’s
commitments to provide alternate ways to monitor its network, audit 9-1-1 circuits for
diversity, and ensure that backup generators are available in locations affecting PSAPs. These
commitments, however, still require additional specificity, budget, and timetables. Moreover,
the derecho revealed instances where many of these procedures should have been followed
already, and Frontier must demonstrate that it is committed to implementing them in practice
as well as in theory.
Enhancing preventative maintenance plans to include proactively testing its backup
modems monthly.
Performing quarterly checks via dial-up modems on host offices to ensure network
Reviewing Frontier’s network to determine where additional redundancy would be
Adding additional remote access to Points of Presence (“POPs”) to ensure increased
ability to monitor the network.
Prioritizing 9-1-1 center sites and facilities for generator back-up.
Revising and augmenting Frontier’s generator plan.
· Establishing alternate dial-up access to key switches and exploring other backup

Wireline Outages in Other States

More than 300,000 wireline customers in Ohio, Maryland, Illinois, Pennsylvania, Indiana,
Tennessee, New Jersey, and the District of Columbia lost service to some degree during the
derecho, according to an analysis of aggregated NORS data. The bulk of those outages occurred
in Ohio, with more than 170,000 wireline customers affected for periods ranging from one hour
to more than five days, and in Maryland, where roughly 100,000 wireline customers lost service
for as long as six days.

82 See Frontier Comments at 6-7.

Most of the Ohio outages resulted from loss of commercial power followed by failure of backup
power systems, based on an analysis of NORS data. At least two backup generators in Ohio
failed to start, leading to central office outages once backup batteries ran out. Repair crews
attempted to distribute portable generators to remote terminals without dedicated backup
power, but in some cases had to “rotate” available generators between multiple locations until
commercial power was restored. The outages in Maryland were caused by a number of factors,
such as transport and switching failures, in conjunction with loss of commercial power. A lesser
number of reported outages in Maryland resulted from lightning strikes, cable cuts, and storm-
related damage to network infrastructure.
5. The Derecho’s Effects on Public Safety Answering Points

Description of the 9-1-1 Network

The 9-1-1 network, which is shown at a high level as typically configured in Figure 3, was
designed so that anyone dialing 9-1-1 will have his or her call answered by the geographically
appropriate PSAP. The primary function of the 9-1-1 network is to route the call to the PSAP
serving the caller. The calling number and the location of the caller are also sent to the PSAP to
assist in responding to the emergency.

Mobile Switching

Center (MSC)



PSTN (Selective




Figure 3: 9-1-1 Network Architecture

When a caller dials 9-1-1 on a wireline telephone, the call is handled similarly to any other call
and goes to the local switch serving that caller. The local switch then sends the call to an
aggregation point called a selective router, which uses the caller’s phone number and address
to determine to which PSAP the call should be sent. Calls to 9-1-1 from wireless phones flow
through a switch called a mobile switching center before reaching the selective router. For

wireless calls, the sector of the cell tower serving the call provides the approximate location of
the caller and is used to determine to which PSAP the call is sent. To complete the call, a circuit
is set up between the selective router and the appropriate PSAP. If all the usual circuits are
busy or out of service between a selective router and the PSAP, the selective router implements
an alternate path called a reroute.
Once a call reaches the PSAP, the PSAP queries an automatic location information (“ALI”)83
database to determine the location of the caller. For wireline calls, this location is based on the
address associated with the caller’s phone number. For wireless calls, providers use various
technologies to determine the caller’s location based on global positioning system (“GPS”) data
from the caller’s phone and/or other network resources. Because ALI information is passed to
the PSAP along a different path than the one carrying 9-1-1 calls, it is possible for a PSAP to lose
ALI links without losing 9-1-1 service completely.
5.2 Network Effects on PSAPs
Because PSAPs typically rely on the incumbent wireline communications provider’s
infrastructure to receive emergency calls placed from any device, failures in Verizon and
Frontier’s wireline networks also disrupted 9-1-1 service to many PSAPs. While any
communications breakdown raises concerns, disaster-caused breakdowns affecting 9-1-1
service heighten those concerns because they directly affect the public’s ability to call for help
at a time when it is likely that the greatest number of people will need emergency service.
During and after the derecho, at least seventy-seven PSAPs experienced adverse effects ranging
from a complete loss of 9-1-1 service to failures of ALI and/or automatic number information
(“ANI”)84 and other partial disruptions.
The following table shows the location and causes of complete or partial service disruptions to
PSAPs in various states:

83 ALI provides the PSAP with the caller’s telephone number, the address/location of the telephone, and
supplementary emergency services information. See Glossary of Technical Terms: Wireless E 9-1-1,
84 ANI provides only the telephone number associated with the access line from which a 9-1-1 call originates. See
Glossary of Technical Terms: Wireless E 9-1-1,


Completely down

ALI/reroute/9-1-1 circuits

CAMA trunk


West Virginia
New Jersey

Table 1: Summary of PSAP Effects


Network Effects on PSAPs in Virginia

The most significant impact of Verizon’s network problems in northern Virginia was to cause
the total loss of 9-1-1 service connectivity to the Fairfax County, Prince William County, City of
Manassas, and Manassas Park PSAPs. Specifically,
[t]he failure of one of two back-up generators to start at each of
[Verizon’s] Arlington and Fairfax central offices following the loss
of commercial power caused the Northern Virginia 911
disruptions. Multiple failures cascading from these specific
generator problems and damage to the transport network
combined to cause the outages for the four PSAPs. Included
among those failures were systems that enable [Verizon] to
monitor the condition of [its] network facilities in Northern
Virginia, and that loss of visibility over [Verizon’s] network
hindered [its] initial efforts to assess and repair damages.86
PSAPs, lacking information from Verizon, at times arranged reroutes to non-working routes
after the regular route again became operational, or continued to attempt to reroute even
though service could have been restored on the original route.87

85 Centralized Automatic Message Accounting (“CAMA”) trunks are a legacy technology used to route 9-1-1 calls to
PSAPs in many jurisdictions. During times when a PSAP receives a large volume of calls, a timing mismatch
between the selective router and the customer premises equipment (“CPE”) at the PSAP results in trunks being
taken out of service even though these trunks have not failed. Whenever a trunk is taken out of service, the
number of 9-1-1 calls that can be processed is reduced.
86 Verizon Public Report at 2. See also Fairfax County Comments at 14-18 (noting that the 9-1-1 outage was
caused by the failure of Verizon’s backup power sources and equipment failure/damage, and that the outage was
compounded by Verizon’s failure to provide prompt and effective notice to the Fairfax PSAP).
87 See Verizon Public Report at 6 (certain PSAPs “would have been better off [not rerouting calls], but without the
appropriate information, they were unable to make that determination at the time”).


Virginia PSAPs

5.4.1 Fairfax County
Fairfax County has a population of more than 1.1 million people, about 20 percent of the entire
population of the Washington, D.C. metropolitan area.88 Its PSAP, the largest in Virginia and
among the ten largest in the United States, receives approximately 1 million 9-1-1 calls per
year.89 According to Fairfax County’s comments in response to the Bureau’s Public Notice:90
[T]he derecho hit Fairfax County at approximately 10:30 at night
on Friday, June 29, 2012. At 7:36 the next morning, as hundreds
of thousands of County residents awoke to assess the full extent
of the damage in daylight, the phones stopped ringing. Over the
next seven hours, no calls were completed to the County’s 9-1-1
Call Center. On the afternoon of Saturday, June 30, sporadic,
incomplete service was restored. Three additional days passed
before 9-1-1 service was fully restored at 11:30 a.m. on Tuesday,
July 3, 2012.
Fairfax County’s 9-1-1 Call Center operated exactly as it was
designed, intended, and constructed to operate. Verizon has told
the County that the 9-1-1 failure was caused primarily by a loss of
power in two key Verizon central offices (Arlington and Fairfax).
Many other Verizon central offices in the region lost power as
well, which exacerbated the effects of the loss of Verizon’s
Arlington and Fairfax central offices. The 9-1-1 failure affected
several other Northern Virginia jurisdictions in addition to Fairfax
County. The data Verizon has provided the County to date show
that nearly 1,900 calls made to 9-1-1 entered Verizon’s system
but were not routed to the County during the first 29 hours. The
County is awaiting the receipt of additional data from Verizon.91
The Fairfax County PSAP is served by redundant selective routers. However, this redundancy
was compromised as a result of the transport failures caused by the generator failure in
Verizon’s Fairfax central office and other single points of failure in Verizon’s network.
According to Fairfax County:

88 Fairfax County Comments at 3.
89 Id. at 4.
90 See Derecho Public Notice, 27 FCC Rcd at 8131.
91 Fairfax County Comments at 2 (footnotes omitted; emphasis in the original.)

[P]ortions of [Verizon’s] transport network, in effect one of the
“main communications highways” used to complete 9-1-1 calls,
and in many cases even regular phone calls, were not operational
for more than seven hours on [June 30, 2012]. Power equipment
in Verizon’s Fairfax central office also failed, isolating the Fairfax
E9-1-1 tandem switch and preventing the routing of 9-1-1 calls to
the Fairfax County PSAP through the Fairfax network route. The
Alexandria E9-1-1 tandem switch, a secondary route for 9-1-1 call
transport, remained operational but the capability to route 9-1-1
calls to the Fairfax County PSAP failed. Essentially, the Verizon-
provided 9-1-1 telephone switching systems into Fairfax County
facilities were not operating, even though the Fairfax County PSAP
staff and Fairfax County telephone and computer systems were
operational and unaffected by the power outages (Fairfax County
has power-fail systems implemented in its PSAP).92
A diversity audit by Verizon, as called for in CSRIC best practice 8-7-0532,93 might have
identified these single points of failure and prevented the loss of service to the Fairfax County
PSAP through additional redundant connectivity.
According to Fairfax County, Verizon also did not provide adequate notification of the existence
and scope of problems in its network affecting 9-1-1 service. Instead:
Verizon sent a cryptic e-mail to designated Fairfax County staff
saying that the Arlington central office was without power or
backup battery/generator. The references to Arlington suggested
that 9-1-1 service was affected only in Arlington County. Without
a corresponding phone call explaining the situation and the e-
mail, Fairfax County’s PSAP staff continued with their normal
operations, unaware that incoming 9-1-1 call service from Verizon
was about to rapidly deteriorate.94
Fairfax County also identified multiple previous outages where Verizon failures affected PSAPs
in the region.95 It asserts that this outage “was the latest in a series of recent 9-1-1 problems in

92 Fairfax County Comments at 15.
93 CSRIC Best Practice 8-7-0532 provides that “[n]etwork operators should periodically audit the physical and
logical diversity called for by network design and take appropriate measures as needed.” See
94 Fairfax County Comments at 7.
95 See Fairfax County Comments at 18-20. Disruptions to 9-1-1 service availability included during a January 2011
snowstorm in the Washington, D.C., metropolitan area; a February 2011 equipment failure at Verizon’s Fairfax
central office; and a May 2011 power failure in Verizon’s Newark, New Jersey, central office that affected wireless
ALI data for PSAPs in Maryland, Virginia (including parts of Fairfax County), Delaware, and Pennsylvania.

the National Capital Region that demonstrate that the 9-1-1 infrastructure is not as resilient or
as reliable as it needs to be.”96
5.4.2 Prince William County
Prince William County has a population of 420,000. The PSAP is served by redundant selective
routers. In June 2012, before the derecho, the Prince William County PSAP received 15,940
calls to 9-1-1, and 25,698 non-emergency calls. 97
The Prince William County PSAP told the Bureau that by 8:07 a.m. on June 30, PSAP staff had
determined that they were not receiving 9-1-1 calls. The PSAP attempted unsuccessfully to
reroute the calls to backup phones, but found that the only lines working were the area code
703 non-emergency numbers. At that point Prince William County PSAP officials contacted
Verizon to let it know that circuits were down. At the same time, they began to inform the
public via media and alerting systems to use the non-emergency numbers to contact the PSAP.
At about 10:00 a.m., the Virginia Communications Coordinator (“VCC”) contacted the Prince
William PSAP to see if it was having a problem. The VCC then contacted the FCC Operations
Center, which also contacted Prince William County. A half-hour later, at 10:30 a.m., Verizon’s
technical service manager contacted the PSAP to say Verizon was experiencing 9-1-1 problems
and was working on the problems. Verizon tried unsuccessfully to reroute 9-1-1 calls to the
Prince William County PSAP’s administrative lines.
By the afternoon of June 30, the PSAP began receiving intermittent wireless calls, and by early
morning on July 1, it received intermittent wireless and landline calls. Around 11:17 a.m. on
July 1, the PSAP was processing most 9-1-1 calls, albeit without ANI or ALI. By early on July 2,
Verizon had restored ANI and ALI.
5.4.3 City of Manassas
The City of Manassas, Virginia, has a population of approximately 38,000 and is surrounded
completely by Prince William County. The Manassas PSAP is served by redundant selective
routers and normally receives fifty to sixty 9-1-1 calls per day from wireline users. Wireless 9-1-
1 calls generated from Manassas are normally processed by the Prince William County PSAP,
which then routes them to Manassas if the caller needs police. Prince William County
dispatches fire and other emergency personnel.
Representatives of the Manassas PSAP told the Bureau that on June 30 between 6:00 and 6:55
a.m., the Manassas PSAP realized it was not receiving 9-1-1 calls, and contacted Verizon to alert
them to the outage. At about the same time, the Manassas PSAP received an e-mail from

96 Id. at 3.
97 Approximately 60 percent of these calls were wireless, and 40 percent were wireline.

Verizon stating that it was aware of the situation. Despite the 9-1-1 service outage, all non-9-1-
1 landlines within the Manassas PSAP worked.
The Manassas PSAP requested that Verizon reroute 9-1-1 calls to the non-emergency lines,
where they could get ANI but not ALI information. Verizon tried, but was unable to deliver 9-1-
1 calls to the overflow lines or the administrative lines. Normally if there is a problem with
overflow lines, calls to Manassas will reroute to Prince William County. However, Prince
William County’s lines were not restored until July 1. At that time, the Manassas PSAP’s calls
were rerouted to Prince William County. By July 1 between 7:00-8:00 p.m., PSAP trunks were
partially restored at the Manassas PSAP, and by 9:00 a.m. on July 2, the Manassas PSAP was
fully operational.
5.4.4 Manassas Park
Manassas Park has a population of about 15,000. The Manassas Park PSAP receives certain 9-1-
1 calls and others go to or are sent by Manassas Park to PSAPs in either Prince William County
or Fairfax County. The Manassas Park PSAP receives about 900 wireline 9-1-1 calls per month.
The Manassas Park PSAP told the Bureau that it realized that its 9-1-1 lines were not working on
June 30, at 8:00 a.m., and attempted, unsuccessfully, to call Verizon for assistance. It was six
hours before the Manassas Park PSAP finally reached Verizon to report the outage. According
to PSAP officials, Verizon was unaware of the outage but agreed to try to reroute landline 9-1-1
calls to another PSAP. The Manassas Park PSAP informed Verizon that other Virginia PSAPs had
problems as well.
On July 1 at 4:00 p.m., the PSAP rerouted 9-1-1 calls to Prince William County following an e-
mail from Verizon stating that 9-1-1 calls to the Manassas City and Manassas Park PSAPs were
still not getting through. On the afternoon of July 2, the PSAP routed 9-1-1 calls back to
Manassas Park’s administrative lines without ANI or ALI functionality. On July 3 at 12:15 p.m.,
Verizon fully restored 9-1-1 service to the Manassas Park PSAP. By July 6, Verizon confirmed
that the 9-1-1 system was fully functional.
5.4.5 Arlington County
Arlington County has a population of approximately 213,000. The design of the Arlington
County PSAP was based on state-of-the-art concepts, including redundant access “from two
different exchanges, for purposes of diverse routing, to ensure 9-1-1 service even if one access
route were severed or otherwise failed.”98 Consequently, Arlington County is “quite concerned
that Verizon’s commercial service failed despite these precautions and resulted in major
telecom and network facility outages of extended duration.”

98 See Ex parte Letter from Joseph N. Pelton, Chair, Arlington County (Virginia) Information Technology Advisory
Committee, to FCC Chairman Julius Genachowski (Sept. 5, 2012).

The Arlington County PSAP is served by redundant selective routers and has four ALI links to
redundant ALI servers. During the derecho, both links to one ALI server and one of the links to
the other failed. All three of these links passed through transport equipment in one Verizon
central office. The Bureau believes that a diversity audit by Verizon of these ALI links may have
revealed these diversity problems.
The Arlington County PSAP told the Bureau that while it never lost service completely, it
experienced intermittent problems and made multiple test calls to 9-1-1 that did not go
through. PSAP officials stated that on June 30 around 5:00 a.m., three of the PSAP’s four ALI
links and all of its administrative lines failed, although not necessarily simultaneously. Around
9:40 a.m., Verizon’s Fairfax central office had failed, and that failure took down half of the
Arlington County PSAP’s 9-1-1 trunks. At the same time, the 9-1-1 trunks coming from a second
selective router experienced intermittent problems but were always able to deliver some calls
to the PSAP, which did not reroute calls to other jurisdictions. Although ten-digit administrative
lines were back in service by July 1, the Arlington County PSAP could not receive 9-1-1 calls
from Verizon Wireless customers for at least part of July 2. Verizon’s service to the PSAP finally
became stable on July 3.
5.4.6 Other PSAPs in Virginia Supported by Verizon
According to Verizon, in addition to the four PSAPs that experienced total 9-1-1 outages (i.e.,
Fairfax and Prince William Counties, and Manassas City and Manassas Park), and the Arlington
PSAP, which had substantial difficulties but to which 9-1-1 service was not completely lost, 9-1-
1 service to twenty additional PSAPs partially failed. Most of these problems resulted from
service disruptions in Verizon’s network, although some were caused by power or CPE issues at
the PSAP. Twelve of these PSAPs suffered ALI outages, and eight more experienced various
other issues such as failure or partial failure of 9-1-1 trunks, problems with CPE, and power loss.
5.4.7 Albemarle County
The PSAP in Albemarle County, Virginia, which is served by CenturyLink, also was affected by
the derecho. At least some 9-1-1 trunks to the Albemarle County PSAP experienced CAMA
trunk throughput issues99 discussed in a 2011 report by the ATIS/NRSC. 100 Recommendations
in the ATIS/NRSC Report were widely communicated to industry, and CenturyLink was a
member of the industry team that created them. The report provided detailed
recommendations to prevent CAMA trunks from mistakenly being removed from service during
mass call events. CenturyLink adopted the recommendation to provide more active monitoring
of the network to identify service issues, but it chose not to implement the recommendation to
consider changing the trunk busy percentage parameters in its selective router serving the
Albemarle County PSAP to prevent trunks from being removed from service. Based on the

99 See supra, note 85.
100 See supra, note 31 and accompanying text.

experience of other providers that followed both of these recommendations, the Bureau
believes that fewer 9-1-1 trunks would have been taken out of service and more 9-1-1 calls
would have been received by the Albemarle County PSAP had CenturyLink taken additional
actions as included in the ATIS/NRSC report. CenturyLink argues that the Bureau’s conclusion
does not account for the fact that changing the trunk busy percentage parameters increases
the potential for other service-affecting issues to occur.

Effects on PSAPs in West Virginia

Of the fifty PSAPs in West Virginia served by Frontier, twenty-seven experienced adverse effects
from the derecho.101 Eleven West Virginia PSAPs lost 9-1-1 service completely for durations
ranging from less than one hour to more than twelve hours, affecting approximately 400,000
residents. Other PSAPs lost ALI links or had to reroute 9-1-1 calls to administrative lines or
PSAPs in other jurisdictions. In all, storm-related 9-1-1 issues potentially affected
approximately 1.2 million West Virginia residents. Service to most of the affected PSAPs was
fully restored by July 1, two days after the storm; however, two PSAPs had to reroute 9-1-1 calls
for more than three days.
According to Frontier, “[t]he lack of commercial power was the predominant cause of PSAP
interruptions, both because it affected Frontier’s ability to provide communications services,
and also because it affected the ability of the PSAPs to use their own equipment.”102 Problems
with backup power to Frontier’s network after commercial power outages led to service
impacts at twelve West Virginia PSAPs.103 Widespread commercial power outages forced 126
of Frontier’s 230 wireline facilities in the state to run on generator power.104 Frontier
acknowledges, however, that “[g]enerator-use . . . was not a foolproof solution” and that “[i]n
some instances back-up generators pre-placed in the Central Offices failed, which led to
outages while Frontier replaced those generators.”105 Frontier’s other PSAPs were affected by
physical damage to the network, including one PSAP that lost service when a truck struck an
aerial fiber which was hanging low because of the storm. Another PSAP served by Frontier
experienced CAMA trunk throughput problems addressed in the ATIS/NRSC report described
Eight of the twenty-seven affected PSAPs lost service because of issues at the PSAP itself rather
than in Frontier’s network. These issues included loss of power, lightning strikes, and failure of
CPE. Although many PSAPs were able to operate on generator power and continue operations

101 See Frontier Comments at 3-4.
102 Id. at 4.
103 Id. at 5.
104 Id. at 2.
105 Id. at 4.
106 See supra, notes 31, 85, and accompanying text.

despite commercial power failures, backup generators at several PSAPs failed to start. As
power was slowly restored, power surges created problems with CPE at some PSAPs, hindering
Frontier’s ability to reroute traffic. Staff members’ personal cell phones were essential at
several of the PSAPs. However, wireless service in several counties was down or was unreliable
during the storm, adversely affecting the ability to seek 9-1-1 assistance in instances where
customers relied on wireless phones to make emergency calls.
Frontier was delayed in repairing transport failures by a lack of monitoring access to damaged
sites. 107 Frontier’s NOC lost connectivity to a key monitoring circuit, which prevented it from
communicating with the various networks in the area and remotely accessing selective routers
to reroute calls to the PSAPs that were down due to storm damage. This circuit was the only
way Frontier could directly monitor the status of network equipment in West Virginia from its
NOC. Several days before the derecho, as part of a circuit rearrangement, Frontier had
disconnected a redundant circuit that would have provided it an alternate way to monitor the
network equipment in West Virginia. Apparently due to a miscommunication within Frontier,
this circuit was not reconnected prior to the derecho and the only remaining circuit was lost
during the storm, isolating the Frontier NOC from critical network assets in West Virginia. The
NOC management system was fully restored two days after the storm.
Due to the loss of monitoring access, Frontier walked its on-site field technicians through the
restoration process via phone. Where possible, Frontier used a front-end processor, which
collects alarms and allows for remote access into the offices, to access the offices in West
Virginia via dial-up. This technique also allowed Frontier to make the 9-1-1 translation changes
necessary to reroute the calls for the PSAPs. Though this process worked, it was slower and
more difficult to implement than using the direct monitoring that had failed.
Although most PSAPs we contacted have concerns about the overall 9-1-1 architecture in West
Virginia, they generally were pleased with Frontier’s responsiveness during the derecho.
Nevertheless, the majority of the PSAPs made the initial call to Frontier to report their outages
before Frontier initiated contact with the PSAP. This was mainly due to the fact that Frontier
lost the ability to monitor its network in West Virginia, preventing it from seeing network
alarms and disrupting its ability to perform reroutes of the 9-1-1 calls to the PSAPs.

Effects on PSAPs Outside of Virginia and West Virginia

Beyond its effects in Virginia and West Virginia, the derecho also disrupted communications to
PSAPs in Ohio, New Jersey, Maryland, and Indiana, according to state regulators and our
analysis of NORS data.

107 See Frontier Comments at 5 (noting that “disruptions on Frontier’s major transport facilities led to lost visibility
and remote access to some parts of the network, which in turn resulted in communication impacts to some

5.6.1 Ohio
In Ohio, two PSAPs served by Frontier lost 9-1-1 service completely for durations ranging from
three hours to twelve hours, affecting more than 13,000 residents. One PSAP was not receiving
9-1-1 calls because of a transport failure between the PSAP and a Frontier selective router.
Another PSAP lost commercial power within the PSAP and went to battery backup immediately
since it had no generator onsite. When the batteries were exhausted, the PSAP lost
connectivity until commercial power was restored twelve hours later. Later that day,
commercial power was again lost and, since the batteries had not had time to recharge, the
PSAP did not receive 9-1-1 calls for another two hours.
CenturyLink also reported that the Warren County, Ohio, PSAP had CAMA trunk throughput
problems,108 resulting in diminished 9-1-1 call capacity. While CenturyLink adopted the
recommendation to provide more active monitoring of the network to identify service issues, it
chose not to implement the recommendation to change the trunk busy percentage parameters
in the selective router serving the Warren County PSAP to prevent trunks from being removed
from service – had it done so, it may have reduced the impact of that problem without causing
other service-affecting issues.
Four Ohio PSAPs served by AT&T lost ALI for up to four days after commercial power failures
disabled equipment in the network.
5.6.2 Maryland
According to the Maryland Emergency Number Systems Board, several Maryland PSAPs
experienced communications issues during and after the derecho, although none appear to
have impacted the public’s ability to reach 9-1-1.109 In Garrett County, for example, U.S.
Cellular mistakenly routed a cellular trunk to a wireline 9-1-1 trunk, although this had no
immediate impact on ALI or the public’s ability to reach 9-1-1.110 In Caroline County, wireless 9-
1-1 calls were temporarily rerouted to another PSAP.111 In Montgomery County, Verizon
implemented a “mass call mitigation plan” that prevented CAMA trunk issues112 from impacting
9-1-1 service during the derecho. The PSAP later discovered, however, that Verizon failed to
return four 9-1-1 trunks to service for “several days after the storm,”113 a condition that
increased the probability that 9-1-1 calls would be lost. Verizon has since updated its

108 See supra, notes 31, 85, and accompanying text.
109 See Maryland Emergency Number Systems Board, Derecho Storm – Maryland Interim Report (Oct. 23, 2012) at 1
(“Maryland ENSB Report”).
110 Id.
111 Id.
112 See supra, note 85 and accompanying text.
113 Maryland ENSB Report at 2.

procedures to ensure that all trunks are restored following mass call events before closing the
associated trouble ticket.114
5.6.3 Other States
Some PSAPs in Indiana and New Jersey retained at least some 9-1-1 functionality but lost ALI
links or had to reroute calls through other PSAPs. Most of these PSAPs cited commercial power
outages as the cause of their problems, although some ALI equipment also failed. Partial
disruptions in 9-1-1 service ranged from approximately one hour to more than four days. For
example, one PSAP served by Frontier in Indiana lost ALI for almost an hour and a half,
potentially affecting more than 73,000 people. In New Jersey, five PSAPs served by Verizon lost
ALI for periods ranging from two hours to more than two days, while a sixth PSAP lost
commercial power and rerouted calls to another PSAP.
6. The Derecho’s Effects on Wireless Networks
Commercial wireless networks generally withstood the derecho much better than their wireline
counterparts. Cell site outage rates during and after the storm varied by provider and
jurisdiction, but were modest both in number and duration in comparison to other superstorms
or hurricanes. That being said, wireless customers reported service problems and lost calls
immediately after the storm,115 and many likely suffered from cascading effects of wireline
service outages. Yet, compared with our observations in other events of similar magnitude,
impacts on service were not nearly as pervasive as might have been expected, and most
outages were rectified relatively quickly.
Issues arose throughout the affected region as cell towers began to lose all sources of power
(commercial, battery, generator) in the hours and days after the storm had dissipated.
Generally, cell cites operate on batteries charged either by commercial power or, in some cases
when commercial power fails, a backup generator. When commercial power fails and no
generator is available, cell site operation depends on the life of the site’s batteries as a backup
power source. Depending on their battery and generator configurations, some wireless
providers reported a majority of cell site outages caused by power failures at the site, while
others reported more outages due to transport failures between cell sites and the rest of the
network. In general, increased deployment of generators at cell sites reduces the probability of
outages due to power loss.
The major wireless providers that serve the area most affected by the storm are the nation’s
four largest: Verizon Wireless, AT&T, Sprint, and T-Mobile. The Bureau sought information

114 Id.
115 See Sullivan, Patricia, After Storm, 911, Phone Service Remains Spotty, WASH. POST, July 2, 2012 (reporting that a
Washington, D.C., resident’s cell phone “dropped half a dozen calls” and could not receive text messages for
several hours).

from each of these providers on the performance of their networks during and immediately
after the storm, including information on battery backup systems implemented at cell sites.
Our analysis of the information we received shows that outages were most extensive on June
30, when roughly 10.8 percent of cell sites were out of service in the affected reporting area.116
Hurricane Isaac, which hit the gulf coast in August, resulted in 21.8 percent of area cell sites out
of service, and during Hurricane Gustav in 2008 that figure was 28.9 percent—with outages
comparable to the worst of the derecho still lingering even four days after restoration efforts
had begun. By contrast, only roughly 2 percent of cell sites in the derecho’s affected area
remained out of service as of July 3.
The comparatively favorable performance of wireless networks during the derecho as
compared to other major storms, and the severe impacts of the wireline network issues on the
basic functionality of 9-1-1 service, has led the Bureau to focus most (but not all) of its
recommendations in this report on wireline network enhancements and other efforts to
improve 9-1-1 service reliability. But the Commission’s examination of the resiliency of wireless
networks in the face of major storms will continue through field hearings planned for early
2013117 and a series of other activities planned by the Bureau. As the Bureau collects
information through these mechanisms, the Bureau may, as appropriate, recommend
additional areas for the Commission to consider.

High-Level Snapshot of Wireless Network Effects

As previously noted, the percentage of cell sites unable to provide service as a result of the
derecho reached 10.8 percent on June 30 but declined steadily thereafter. The most heavily
affected jurisdictions were portions of West Virginia and Virginia, the jurisdictions that also
experienced the most extensive wireline and 9-1-1 service disruptions.

116 See supra, Section 2. The Bureau collected data from an area including six counties in West Virginia, seven
jurisdictions in Virginia, eight jurisdictions in Maryland, and the District of Columbia.
117 See Superstorm Sandy Field Hearings PN.

Percent of All Cell Sites Out by Date


Figure 4: Percent Cell Sites Out by Date

Loss of power and failure of transport (i.e., backhaul) facilities each accounted for
approximately one-half of the overall site outages in the first days; physical damage to cell sites
was a minimal factor.

Figure 5: Reasons Cell Sites Out of Service118


Cell Site Battery Life

Batteries provide a critical source of backup power for cell sites. In the event that commercial
power is unavailable, providers rely on other forms of power (generators and batteries) to keep

118 This graph reflects the most common causes of cell site outages in the area affected by the derecho. In some
cases, cell sites experienced unspecified problems or more than one problem simultaneously (e.g. power and
transport failures). Thus, some daily percentages may be greater or less than 100 percent.

their systems operating. We note that most cell towers have backup battery power, ranging
from several hours to a few days.
It appears that most of the major wireless providers do not retain records of or analyze the
actual lifespan of their cell site batteries when they support the site during a loss of commercial
or generator power, and thus were unable to provide the Bureau with usable data on battery
life during the derecho. We understand that actual battery life depends on a number of
factors, including the specifications of the battery, its age, whether it has been used previously
without commercial or generator power, the extent of usage of the site it supports, and other
factors. This collection and review of actual performance information as a tool in assessing how
long batteries will likely last during a storm when relied on as the sole source of power for a cell
site would be useful to know. But providers appear to lack this relevant data and cannot
statistically analyze the information to estimate battery life and guide their maintenance
strategies. It seems that providers should collect and analyze this information. The Bureau
recommends further research, both within the Commission and by wireless providers, to better
understand the many issues related to the lifespan of these vital batteries.
7. Recommendations
For many years, the Commission has worked with industry stakeholders to promote the
implementation of industry-led best practices to ensure the availability and reliability of 9-1-1
communications. As a result of our inquiry following the derecho, it became apparent that
service providers’ implementation of best practices was neither as diligent nor consistent as
needed, and the result was costly for 9-1-1 service. Consequently, in this section, the Bureau
recommends consideration of specific action by the Commission to supplement the current
best-practice approach in key areas. We also emphasize the need for providers to implement
established best practices, and suggest how the Bureau can promote improved engineering
through additional best practices to address apparent shortfalls. Finally, we encourage the
continued implementation of NG9-1-1, which could lessen a future storm’s impact on
emergency communications.

Recommendations for Possible Commission Action

The Bureau recommends that the Commission consider action to ensure improved 9-1-1 circuit
auditing, central office backup power, and diversity of monitor and control links. Each of these
areas has already been addressed in vital CSRIC best practices, but it appears that service
providers have not consistently or fully implemented those practices, and problems have
resulted.119 Consequently, the areas we suggest to the Commission include:

119 In addition to information learned through this inquiry, the Bureau had already issued public notices that
emphasized the need for compliance after it received information suggesting that providers may not have been
following some relevant best practices. See, e.g., FCC’s Public Safety and Homeland Security Bureau Reminds
Telecommunications Service Providers of Importance of Implementing Established 9-1-1 and Enhanced 9-1-1
Services Best Practices, Public Notice, DA 12-891, 27 FCC Rcd 6085 (PSHSB rel. June 6, 2012) (“June 2012 Best

9-1-1 Circuit Auditing: Auditing should lead to fewer 9-1-1 outages and enhance the
reliability of 9-1-1 communications. If providers do not regularly audit the physical routes of
9-1-1 circuits and ALI links, they will be ill-equipped to verify diversity and understand,
avoid, or address instances where a single failure causes loss of all E9-1-1 circuits or all ALI
links for a PSAP. The derecho and other experiences in recent years120 call into question the
extent to which providers are implementing these important audits. We believe the
benefits of this recommendation will likely outweigh the costs, given the large numbers of
customers that can be served successfully in emergencies by circuits that are diverse, and
the harms that could result from avoidable failures. The burden would be modest because
this obligation would apply only to a limited number of high-priority circuits rather than to
the entire commercial wireline network. Nor would auditing necessarily encompass a
requirement that providers diversify all circuits in areas that are particularly expensive.

Central Office Backup Power:

The derecho experience makes clear how important it is for
the provision of emergency service and reliable and resilient communications to ensure that
providers maintain robust, resilient backup power in central offices, supported by
appropriate testing, maintenance, and records retention. As the Commission has
recognized previously,121 reliable central office backup power is essential for
communications during large-scale emergencies. Failure of central office backup power
during a commercial power outage can disable wireline communications for a community,
including emergency communications. It is likely that the benefits of this recommendation
will outweigh the costs, given the significant public-safety concerns and the limited number
of central offices; moreover, providers most likely can comply affordably given that much of
the needed infrastructure may already be in place.

Diversity of Monitor and Control Links:

The derecho makes clear how vital it is for a
provider’s network operations center to have diverse monitor and control links and
capabilities throughout the network to ensure network reliability, resiliency, and rapid
recovery. We believe the benefits of this recommendation will likely outweigh the costs
due to the relatively small set of links involved in network monitoring and control, and the
potentially serious impacts of a loss of these links. Some points at which these monitoring
networks gain access to the equipment they monitor can become single points of failure,

Practices Public Notice”) (reminding telecommunications service providers of the “importance of providing
diversity and redundancy in the provisioning of 9-1-1/E9-1-1 services”). See also FCC’s Public Safety and Homeland
Security Bureau Reminds Telecommunications Service Providers of Importance of Implementing Advisory
Committee 9-1-1 and Enhanced 9-1-1 Services Best Practices, Public Notice, DA 10-494, 25 FCC Rcd 2805 (PSHSB
rel. March 24, 2010) (“March 2010 Best Practices Public Notice”) (noting that “the Bureau has observed a
significant number of 911/E911 service outages caused by a lack of diversity that could have been avoided at little
expense to the service provider”).
120 See June 2012 Best Practices Public Notice; March 2010 Best Practices Public Notice.
121 See, e.g., In the Matter of Reliability and Continuity of Communications Networks, Including Broadband
Technologies, et al., Notice of Inquiry, PS Docket No. 11-60, et al., 26 FCC Rcd 5614 (2011).

but many can be fortified at modest cost. Only modest, but important, changes from
existing practices may be required.

Revised PSAP Notification Rule:

Section 4.9 of the Commission’s rules122 requires that
providers suffering an outage of facilities that potentially affect a PSAP must notify the PSAP
as soon as possible. The Commission should consider stating what is expected of providers
with more specificity, including, for example, methods of notification and a minimum level
of detail in the information provided to PSAPs. Such clarification may improve compliance
and result in greater situational awareness for PSAPs.
7.2 Diligent Implementation of Best Practices
Over the years, the FCC has worked with industry stakeholders to promote development and
implementation of best practices, and we expect this process to continue. The CSRIC best
practices have been developed on the basis of widespread industry participation. This creates a
strong presumption that providers would be inclined to implement them—particularly those
recommendations that are deemed most vital. Still, many providers failed to implement crucial
best practices throughout the area affected by the derecho, which includes the densely
populated National Capital Region. We call on providers again to review and implement CSRIC
and other best practices and emphasize the importance of doing so.

The proper
implementation of CSRIC best practices could have prevented many of the derecho’s most
serious effects on communications networks, including 9-1-1 service outages.

The Bureau’s inquiry revealed multiple failures to implement CSRIC best practices including:
Network operators, service providers and property managers with buildings serviced by
more than one emergency generator, should design, install and maintain each generator
as a standalone unit that is not dependent on the operation of another generator for
proper functioning, including fuel supply path. (

CSRIC best practice 8-7-5281)

· Network operators, service providers and property managers should exercise power
generators on a routine schedule in accordance with manufacturer’s specifications. For
example, a monthly one-hour engine run on load, and a five-hour annual run. (CSRIC
best practice 8-7-0662)

· Network operators, service providers and property managers should design standby
generator systems for fully automatic operation and for ease of manual operation,
when required. (CSRIC best practice 8-7-0657)
· Network operators, service providers, equipment suppliers and property managers
should ensure that all critical infrastructure facilities, including the security equipment,

122 See 47 C.F.R. § 4.9.

devices and appliances protecting it, are supported by backup power systems (e.g.,
batteries, generators, fuel cells). (CSRIC best practice 8-7-5058)
Network operators should periodically audit the physical and logical diversity called for
by network design and take appropriate measures as needed. (CSRIC best practice 8-7-

7.2.1 Actions by CSRIC
The Bureau recommends charging CSRIC with the development and modification of solutions
with respect to certain issues, such as low voltage effects, that are addressed in this report but
are not covered by the Bureau’s recommendations for consideration of Commission action.
The Bureau also recommends that CSRIC consider adopting additional best practices consistent
with sound engineering practices identified in this report. Finally, the Bureau may discuss with
CSRIC ways to increase the adoption and effective implementation of best practices. As a result
of the information already available in the aftermath of the derecho, the Bureau recommends
asking CSRIC to address these issues at the earliest opportunity.

Recommendations for PSAP Action

Our meetings with PSAPs also produced constructive recommendations to ensure 9-1-1
remains in service during future storms. Although PSAPs were not responsible for the
widespread breakdown of emergency communications during the derecho,123 the Bureau
recommends that to the extent not already done, they take this opportunity to consider several
proactive improvements.



PSAPs should have several different means of communication available, such as
mobile phones from different providers, to provide as many alternate means as
possible of communicating during an emergency.

Some PSAPs may already follow this
recommendation, and others that do not could implement it immediately.

As many do already, PSAPs should have multiple means of backup power, such as

multiple generators, and run periodic tests under actual load. Where not already in
place, PSAPs should consider installing a simple disconnect switch to permit taking out
one generator and installing another.

123 See MWCOG Report at 19 (finding that “[b]y all indications during this event, the systems and processes in place
by the public safety agencies in the COG region, operated as designed, and the 9-1-1 centers were fully prepared
to provide service to the public,” but encouraging PSAPs “to perform a full assessment of their current 9-1-1
systems and operations to assure reliability and continuity of 9-1-1 service”).


Several PSAPs left reroutes in place for longer than necessary after the derecho.

124 In
some cases, after the E9-1-1 trunks into a PSAP fail, the PSAP will attempt to activate a
reroute, only to discover that the backup route is also out of service. In such instances it
is impossible to predict whether the provider will restore the original route or the
backup route first. When the provider restores either route, it should notify the PSAP;
however, in some cases the provider may not notify the PSAP and may not even realize
that it has restored a route used for emergency calls. In other instances the provider
may believe that it has restored a route even though problems remain on that route.

Therefore, even if the PSAP is not notified, after a few hours, it should consider
deactivating the reroute, then reactivate it a few hours later, and repeat until service
is restored or until it is notified about a working route by the provider.

recommendation could be implemented immediately whenever reroutes are necessary.
7.3.1 PSAP Voluntary Reporting to the FCC
Under NORS and DIRS, the Commission currently is informed by network providers of outages
meeting specified criteria that adversely impact PSAPs. The Bureau also has frequently
engaged in outreach to PSAPs in disasters, particularly PSAPs identified as having been
adversely impacted, to hear directly about their status. In some instances, including after the
derecho, PSAPS have contacted the Bureau directly to advise us of issues that they are facing.
There currently is no specific channel or template for PSAPs who may voluntarily wish to report
information to the Commission, and thus provide a direct source of information on their status.
We are consulting with public safety organizations, and plan to work on a voluntary basis with
PSAPs to establish a standardized format and channel that they can use, if they choose, to
report network concerns directly to the Commission.

NG9-1-1 Implementation

NG9-1-1 relies on IP-based architecture rather than the PSTN-based architecture of legacy 9-1-1
to provide an expanded array of emergency communications services that encompasses both
the core functionalities of legacy 9-1-1 and additional functionalities that take advantage of the
enhanced capabilities of IP-based devices and networks.125 While this report focuses on
recommendations for improving the reliability of existing E9-1-1 systems, we note that NG 9-1-
1 architecture offers certain advantages over legacy technologies, including greater redundancy
and reliability,126 the ability to provide more useful information for first responders, wider

124 See Verizon Public Report at 6 (noting that certain PSAPs “would have been better off [not rerouting calls], but
without the appropriate information, they were unable to make that determination at the time”).
125 For an overview of NG9-1-1 architecture, see Framework for Next Generation 911 Deployment, PS Docket No.
10-255, Notice of Inquiry, 25 FCC Rcd 17869, 17877-80, ¶¶ 18-26 (2010) (“NG9-1-1 NOI”).
126 As described in the NG9-1-1 NOI, NG9-1-1’s use of IP-based architecture provides far more routing options than
legacy circuit-switched architecture because it is not constrained by the location of the caller or the nearest PSAP
to the caller. For example, in circuit-switched networks, selective routers must be relatively close to the PSAPs
they serve, whereas in NG9-1-1, 9-1-1 traffic can be easily rerouted to servers and locations outside the affected

public accessibility (including to those with disabilities), and enhanced capabilities for sharing
data and resources among emergency responders.127 Had these NG9-1-1 architectures and
capabilities been in place in the affected areas, they likely could have significantly lessened the
derecho’s impact on emergency communications. Below, we summarize some of the most
notable potential benefits of implementing NG9-1-1. The Commission should encourage
jurisdictions that implement NG9-1-1 to take advantage of these and other capabilities.
NG9-1-1 routers are being designed to handle fail-over automatically, which would
eliminate the need for manually activating and sometimes manually de-activating
reroutes. While NG9-1-1 has yet to be widely implemented, its ultimate deployment
would likely have helped to avoid or mitigate some derecho-related issues at PSAPs that
lost connectivity.
With E9-1-1, the PSAP generally needs to rely on E9-1-1 trunks and ALI links provided by
the ILEC. With NG9-1-1, the PSAP can obtain and combine links from a variety of
providers. Typically, at least five diverse IP access link options are available at most
PSAP locations: ILEC services; DOCSIS-based128 services provided by the local multiple
systems operator; fixed wireless or line-of-sight laser to large institutions, such as a
university, hospital, other government agency or multi-tenant office building, located
within about a two-mile radius; one or more 4G (LTE) offerings; and satellite. Large
PSAPs can also add their own dark fiber providers for additional physical diversity. Thus,
it is generally possible for PSAPs to improve access reliability. We encourage PSAPs to
take advantage of increased access diversity opportunities when they implement NG9-
1-1; we note that we also have seen NG9-1-1 designs where PSAPs fail to do this and
instead depend on just one access link from the ILEC rather than diverse links from
diverse providers.
Calls on NG9-1-1 systems can be rerouted, both partially and completely, to any number
of backup PSAPs, including out-of-area PSAPs.
· NG9-1-1 service logic (e.g., call routing, databases) can be housed in professionally-
managed data centers which may be more reliable than ILEC central offices and/or data

area, providing more resiliency and redundancy in disaster situations. See NG9-1-1 NOI, 25 FCC Rcd at 17880-81,
¶¶ 26, 29.
127 See id., 25 FCC Rcd at 17878-79, ¶¶ 21-25.
128 Data Over Cable Service Interface Specification (“DOCSIS”) is an international telecommunications standard that
permits the addition of high-speed data transfer to an existing cable TV system. It is employed by many cable
television operators to provide Internet access over existing hybrid fiber-coaxial infrastructure. See DOCSIS,

With NG9-1-1, wireless, VoIP and landline providers can connect their 9-1-1 systems to
several networks, at multiple locations, rather than all going through the ILEC selective
router as with the current system. This would improve reliability for customers and
PSAPs that today depend on only one selective router or one route between the PSAP
and both routers.
With NG9-1-1, network monitoring becomes easier and less subject to single points of
failure. For example, servers can “ping” other servers and “traceroute” can identify out-
of-order network segments.
8. Conclusion
The June 2012 derecho that affected so much of the central and Mid-Atlantic regions of the
United States was unusual in that it hit with very little warning, leaving both communications
providers and the public little time to prepare. As such, the storm tested the readiness and
day-to-day reliability of a large portion of the Nation’s critical communications infrastructure.
The effects of the storm revealed considerable flaws in system design, personnel management,
policies, and procedures of the primary providers of the 9-1-1 networks in the affected region.
The storm also revealed that the major wireline providers serving the affected region had not
fully implemented best practices and industry-developed solutions relating to backup power, 9-
1-1 circuit diversity, and 9-1-1 trunk design – issues with a direct link to the loss of 9-1-1 service
after the Derecho. Accordingly, the Bureau recommends that the Commission, while
continuing to promote use of vital best practices, consider taking additional action to ensure
the reliability of the communications infrastructure, especially with respect to 9-1-1 service.

Appendix A: Preliminary Findings from Virginia State Corporation Commission

The Virginia State Corporation Commission Staff Report of Preliminary Findings released
September 14, 2012, announced numerous findings consistent with this report and helpful to
the Bureau in its inquiry. Below, we include selected findings by the SCC regarding 9-1-1
failures in Virginia:129
Verizon was the only LEC in Virginia that experienced
significant 9-1-1 service problems following the June 29
The total loss of 9-1-1 capabilities to the Prince William
County, Fairfax County, Manassas, and Manassas Park PSAPs
was an extremely serious event and it is very fortunate that
there were not catastrophic consequences to any citizens in
Northern Virginia.
The Prince William County, Fairfax County, Manassas, and
Manassas Park PSAPs were fully prepared to respond to the
June 29 Derecho and were not responsible for the 9-1-1 -
service failures.
The cause of the 9-1-1 service outages in Northern Virginia
from the June 29 Derecho began with the failure of two
backup generators that did not start automatically when
commercial power was lost. Specifically, a generator in each of
Verizon’s Arlington and Fairfax central offices did not start.
A review of the maintenance logs for the backup generators in
the Arlington and Fairfax central offices shows a lack of
compliance with Verizon’s maintenance and testing
· The generator that failed to start in the Arlington office did
not start during routine testing conducted two days before
the June 29 Derecho. The maintenance log indicated that
work to the generator was needed. Verizon confirmed with
the FCC that this information is correct; the generator did fail
the test two days before the storm.

129 See Virginia SCC Report at 7-10.

· A total of nine generators (out of 136) failed to operate
properly during the commercial power outages from the June
29 Derecho in Verizon’s Mid-Atlantic region.
The scope of 9-1-1 problems went well beyond the calling
areas served by the Arlington and Fairfax central offices.
ALI is an important component of 9-1-1 service. The lack of
delivery of ALI to many PSAPs could have put citizens across
Virginia at greater risk.
The initial battery on discharge (“BOD”) alarm 13 for the
Fairfax central office was sent to the National Power Network
Operation Center (“NPNOC”) at 10:29 PM on June 29, 2012
when the one generator failed to start. Under Verizon’s
procedures, any BOD alarm should have been seen as a critical
power alarm requiring immediate action. However, according
to Verizon, this alarm was incorrectly categorized as a major
power alarm condition when sent to the NPNOC.
The Regional Network Center (“RNC”) received a repair ticket
(identified as a major alarm as mentioned above) from the
NPNOC for the Fairfax central office at 10:32 PM on June 29,
2012. At that time, and on the morning of June 30, the RNC
was only working critical alarms and a power technician was
not dispatched to the office until after the backup batteries
had drained completely.
The telemetry system (alarm monitoring) in the Arlington
central office was only supported by the Uninterruptible
Power Supply (“UPS”) (i.e., battery power source) which was
designed with a 30 minute reserve. The UPS failed at 11:23
PM on June 29, 2012.
· The very early failure of the telemetry system resulted in
Verizon being unable to receive further alarms and remotely
access its switches to monitor, test, or reroute traffic to 34
sites in the area. Verizon’s inability to monitor its facilities and
network in the Northern Virginia area significantly impacted
the restoral process from the June 29 Derecho.
· The delay in identifying and repairing the critical conditions in
the Fairfax and Arlington offices resulted in unnecessary

damage to Verizon’s network and extended the 9-1-1 problems
and outages. There were hundreds of damaged or impacted
pieces of equipment in those two offices (i.e., circuit cards and
digital cross connects).
The loss of the transport systems in the Arlington and Fairfax
central offices was profound and collectively resulted in 17
switches becoming SS7 isolated, and therefore incapable of
completing (originating or terminating) any interoffice local,
long distance, or 9-1-1 emergency calls. The loss of those
transport systems was also responsible for the loss of ALI to
the PSAPs. 9 Verizon did not activate its emergency Area
Control Center located in Maryland until 10 AM on June 30,
Verizon did not always provide sufficient, accurate, or timely
communications to the affected PSAPs regarding its 9-1-1
problems and outages following the June 29 Derecho.
Some battery reserves supporting major equipment systems
in the Arlington (other than telemetry) and Fairfax central
offices were depleted within approximately 3 to 5 hours. In
addition, some equipment in those offices failed even before
the batteries exhausted because of sensitivity to low voltage
In many instances, Verizon’s workforce was not timely
dispatched, prepared, or trained to recognize or correct the
critical conditions from the June 29 Derecho.
· Verizon is making progress in implementing its corrective
action plan, however, at this time, not all items have been
fully defined or timelines determined.

Appendix B: Recommendations of the Metropolitan Washington Council

of Governments
In July 2012, 9-1-1 directors in the MWCOG region (including City of Alexandria, Arlington
County, Fairfax County, Prince William County and Stafford County) agreed on five immediate
recommendations to Verizon based on their experience during the derecho. All of these
recommendations, which are listed below, have been accepted by Verizon and are in “various
stages of completion,” according to MWCOG.130
1. Verizon adopt, embrace, instruct, train and utilize the National
Incident Management System (NIMS) model, to address and
mitigate any and all significant events/incidents impacting
providing 9-1-1 service to the aforementioned jurisdictions.
2. Verizon obtain and utilize a Reverse 9-1-1® type system to
notify, via voice and text, those persons identified by the
above jurisdictions, as soon it is known or suspected by
Verizon that there is or may be an interruption of 9-1-1 service
to any or all of the above jurisdictions. The immediately
transmitted voice and text message should contain, in plain
language, the nature of the problem, current or potential
impact of the problem, what Verizon is doing to address the
problem, recommend actions the impacted 9-1-1 center(s)
should take and other appropriate information and include
the name of the sender and the telephone number (business
and mobile) at which the sender can be reached, and their
email address.
3. Verizon work with the jurisdictions to develop, by no later
than December 31, 2012, a method to semi-annually, conduct
a drill/exercise with each jurisdiction on actions to be taken by
Verizon and the impacted jurisdiction(s) in the event of a
potential or actual 9-1-1 outage.
4. Verizon provide the above jurisdictions, during the first week
of each month, a current contact list; beginning with the name
and contact information (email, business telephone number,
business mobile telephone number and any other appropriate
information) for the Verizon account manager assigned to the
jurisdiction and four immediately escalating Verizon personnel
up to a Vice President level.

130 See MWCOG Report at 18.

5. Verizon, if/when requested by any of the above jurisdictions,
have a Verizon representative with authority to act/react;
respond to and to be present at the jurisdictions Emergency
Operations Center (EOC), to provide current accurate
information concerning 9-1-1 service and outages, other
telephone service, etc. and liaison with other parties staffing
the EOC, when the EOC is activated.
On November 14, 2012, MWCOG released a preliminary report of its own findings and
recommendations regarding 9-1-1 failures during the derecho. In addition to the initial
recommendations noted above, the MWCOG Report calls for the following actions:131
1. Federal and State Regulatory Authorities should strongly
encourage Verizon and other 9-1-1service providers to
perform a comprehensive independent audit of the entire
infrastructure, processes and procedures that support 9-1-1
service and related systems, to assure the reliability and
continuity of 9-1-1 service under any circumstance. Based on
the results of these audits, comprehensive plans and
strategies should be developed to immediately resolve any
findings. The results of these audits and resolution plans
should be made available to the 9-1-1stakeholders.
2. It is highly recommended, that Verizon and other 9-1-1 service
providers should provide subject matter expertise and make
recommendations to the 9-1-1 centers and their stakeholders
to assure reliability and continuity of 9-1-1 service. This should
include, but not be limited to, network redundancy, 9-1-1
center equipment and systems, and best practices and
3. It is critical, that Verizon review their communications and
public notification plans with each 9-1-1 center’s
communicators and/or Public Information Officers (PIO)
regarding the dissemination of emergency messages (using
both traditional and social media) to the public during 9-1-1
outages and update as needed. This process should also
explore alternative methods to communicate with the public
in case of widespread power and telephone outages. Verizon
should coordinate with National Capital Region

131 See id. at 17-19.

communicators/PIOs during any future outages, to inform and
keep the public updated, and amplify the 9-1-1 center-specific
public messages and information.
4. Verizon should keep the public informed of any service issues,
the extent of the outage and time for resolution.
5. Federal and State Regulatory Authorities should evaluate the
steps and actions of Verizon, related to this event, and the
above audits, to ensure Verizon has adequately resolved all
issues and continues to improve their processes and
infrastructure to ensure reliability and continuity of 9-1-1
6. COG members and localities should work with their State and
Federal regulatory authorities and Legislators, as needed, to
assure, through proper oversight, best practices and
procedures by establishing service level agreements to ensure
reliability and continuity of 9-1-1 service.
7. It is recommended that there be further investigation by State
and Federal Regulators, on whether the 9-1-1 supporting
infrastructure of other telecommunications providers other
than Verizon, was also impacted by the Derecho. As an
example, AT&T Wireless in their comments to FCC PS Docket
No. 11-60, indicated there was some impact to their
infrastructure during and after the Derecho.
The MWCOG Report noted that “[b]y all indications during this event, the systems and
processes in place by the public safety agencies in the COG region, operated as designed, and
the 9-1-1 centers were fully prepared to provide service to the public.”132 It did, however,
make the following recommendations to state and local governments:133
1. State and local 9-1-1 authorities should be encouraged to
perform a full assessment of their current 9-1-1 systems and
operations to assure reliability and continuity of 9-1-1 service.
2. It is recommended that State and Federal regulatory
authorities, review current laws and regulations related to
9-1-1 service, to assure it places emphasis and favors public

132 Id. at 19.
133 Id.

safety versus the 9-1-1 service providers or
telecommunications providers. The interest of the public and
public safety should come first over the interest of commercial
3. State and local 9-1-1 authorities should work with their
Legislators to ensure that the funding required to support the
current 9-1-1 services and future Next Generation 9-1-1 are
adequate and available, and that the fees and funds collected
from the citizens of their States for 9-1-1 services are
dedicated and used solely for the purpose as intended for the
implementation, operation and maintenance of 9-1-1
emergency telephone services as required by the Enhance911
Act of 2004 (Pub. Law 108-494). In addition, the fees collected
should be fairly and equally distributed to the 9-1-1

Appendix C: Recommendations from PSAPs

During the preparation of this report, the Bureau interviewed personnel from twenty-eight
PSAPs and considered public comments filed by several jurisdictions affected by the derecho.
Several recurring themes emerged from these conversations, which are consistent with the
Bureau’s conclusions and recommendations in this report. Although PSAPs often suggested
actions by communications providers to improve the reliability of the 9-1-1 network, they also
identified areas for proactive action by PSAPs themselves. Below is a summary of the
recommendations we received from PSAPs:
Multiple Virginia PSAPs commented that Verizon needs to improve the circuit diversity
and redundancy in its network to eliminate single points of failure. They also stated that
Verizon should have more reliable backup power, including central-office backup
generators that are properly maintained and tested regularly. Some PSAPs stated that
Verizon should consider additional backup generators at critical points in the network,
and that employees must be trained to manually restore critical equipment when
automated systems fail. Fairfax County in particular asserted that Verizon could have
avoided failures during the derecho by implementing CSRIC best practices and should
perform an audit of its own operating procedures in relation to those best practices. 134
West Virginia PSAPs also called for improved redundancy and circuit diversity in
Frontier’s network. Some PSAPs asserted that Frontier should have backup generators
at all points in the network affecting 9-1-1 service, or at least more portable generators
available for remote locations.
Several PSAPs recommended that PSAPs themselves should have redundant backup
generators with enough fuel to last through a prolonged failure of commercial power.
PSAPs in some locations recommended that staff members should maintain at least one
traditional copper telephone connection and cell phones from a variety of wireless
providers to ensure that some devices remain operational if other networks fail.
· PSAPs in both states requested better notification and communication from Verizon and
Frontier when problems in their networks have a current or potential effect on 9-1-1
service. PSAPs stated that they should be informed directly of outages, including the
specific areas affected, rather than having to infer problems from reroutes or changes in
call patterns. They also suggested that providers should use a variety of
communications platforms (e.g. telephone, text, e-mail) to ensure that PSAP personnel
actually receive notifications. Some PSAPs also requested help from providers when
notifying the public of 9-1-1 outages, including alternative numbers they can call for
assistance until 9-1-1- is restored.

134 See Fairfax County Comments at 22-23.

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