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April 29, 2006

If You Liked FEMA, You’ll Love BellSouth

BellSouth doesn’t want to be required to provide voicemail and/or call forwarding to its customers in the next disaster. Disappointing but not surprising.  Apparently they think the steps they took after Katrina were adequate.  Apparently they learned nothing from the tragedies of their customers who were cut off from normal communication, from the agonies of families who couldn’t reunite, from the precious time wasted and lives risked by rescue workers looking for people who had safely evacuated but were missing because they were unreachable.

BellSouth’s attorneys responded to the petition that Jeff Pulver and I filed with the FCC in an attempt to avoid a rerun of last fall during the next disaster.  They’re against it.  OK, let’s take a look at their reasons.

“It is nonsensical to impose additional requirements on communications providers following a disaster or other catastrophic event,” say said attorneys.  Right.  That’s why the petition asks that they be required to prepare NOW, not wait for the next disaster. They weren’t adequately prepared last time; they need to be next time.  If we wait for the next disaster, it’ll be too late again.

They go on to argue that implementing voice mail during an emergency would interfere with the work of the people who are working mightily to restore service.  Two things wrong with this argument but let me stop for a minute to say I have nothing but respect for the linesmen and other field workers – including those from BellSouth – who work heroically after every emergency.  The problem is at headquarters, not out on the streets.

Of course, they should implement emergency voice mail now, not during a catastrophe – then just turn it on in an emergency for those who weren’t wealthy enough to subscribe to this “premium” service. But they’re missing another point: restoring service to areas which are under evacuation orders and homes that are under water doesn’t help reconnect the PEOPLE who are in shelters somewhere else.  These people won’t be reachable on their old phone lines – some still aren’t. 

The whole point of the petition is to make them reachable on their old phone NUMBERS – the numbers that their family and friends know.  People who had mobile phones, VoIP, or did have voicemail accounts were reachable even though they weren’t in their homes.  But those who were too poor to have these amenities were unreachable.  This doesn’t have to happen again. 

Much of the failure of emergency services after Katrina was because most aid providers – and most people – assume that emergencies are very short-lived and people will come home again after a week.  Usually true.  Not in Katrina.  Not in the most serious of disasters.  Modern technology – actually not even very modern technology – means that phone numbers are not attached to physical phone lines.  This has been true ever since digital switches replaced mechanical ones.  Carriers like BellSouth need to use this technology to make sure their subscribers can be kept in communication during an extended disaster even if their phone lines are drowned or otherwise unreachable.

BellSouth also objects because “there is a possibility that an emergency voicemail service would not be available or could be adversely affected if network facilities are damaged.In other words, we shouldn’t make any preparation for an emergency which isn’t foolproof. (my interpretation of their statement). 

They have a point here, though.  I think they ought to tell their engineers to get working right away to make sure that either voicemail can be switched from an out-of-service central office to a working one or, at least, that voicemail is always stored or provided somewhere other than very near the subscriber to avoid both primary service and voicemail being taken out by the same disaster.  I’m sure they can figure out how to use their own networks to do this.  If not, there are plenty of competent outsourced voicemail providers who’d be glad to do it for them.  Distance is largely irrelevant in communication today.

The petition requires that carriers who do not provide voicemail and/or call forwarding in an emergency – even after having certified that they are able to do so – transfer affected numbers to any provider the subscriber chooses in order to maintain service and do this within two hours.  During Katrina, there were providers who volunteered to provide voicemail free for the duration of the emergency but the numbers were stuck with BellSouth.  It’s the two hour requirement which really frosts them.  “Under existing rules, ports involving wireline carriers must be completed within four days,” they say although they do concede that wireless carriers voluntarily do these ports in two and a half hours.

Transferring (porting, in technical jargon) a number from one carrier to another means a change in a database.  That’s it; nobody moves any wires.  The four days are for bureaucracy.  Sometimes you have to dispense with bureaucracy in a disaster.  By the way, this database is national so workers in the affected areas would NOT have to be tied up doing the porting.

Of course they object that there will be extra costs.  They say that they will have to license additional software and provide additional storage.  Sure, these things’ll cost something – but not very much.  Evidence?  Google and others can afford free storage for email; voicemail providers offered free voicemail during Katrina; storage is only needed for those actually affected by an emergency; and storage is cheap these days.  But the FCC should examine the costs and who should pay them during hearings.  It should also look at the costs imposed because so many people were unreachable.

They say that transferring numbers can result in billing foulups.  Gee, let’s just not have any service.  That’s a good way to avoid billing problems.

BellSouth objects that every emergency is different.  To some extent it IS true that you always plan for the last emergency.  That’s called learning.  Shame on us if we don’t.

BellSouth does want to learn.  “The Commission should allow the Independent Panel reviewing the impact of Hurricane Katrina to complete its task and publish a report with its recommendations.”  Of course, then it’ll be too late to do anything for this hurricane season but let’s not rush.  In the next sentence BellSouth requests immediate relief from some regulations that they don’t like – for some reason this doesn’t have to wait for a committee report.

I had a secret hope that BellSouth and the other carriers would say “don’t regulate us; we’re going to do this sensible stuff anyway.”  That would have been a good answer and demonstrated concern for their customers.  Instead they’ve thrown up a smokescreen of spurious objections and excuses.  That’s why monopolies need to be regulated.

BTW, just in case you thought BellSouth might come to its senses if its pending acquisition by at&t happens, don’t hold your breath.  at&t objects to the petition as well.

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