Accessible Version

INTERNET 

PROTOCOL

TRANSITION

FCC Should 

Strengthen Its Data 

Collection Efforts to 

Assess the Transition's 

Effects

Report to Congressional Requesters

December 2015

GAO-16-167

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-167, a report to

congressional requesters

December 2015

INTERNET PROTOCOL TRANSITION

FCC Should Strengthen Its Data Collection Efforts to 

Assess the Transition’s Effects

Why GAO Did This Study

The communications sector is 

essential to the nation’s economy and 

government operations and for the 

delivery of public safety services, 

especially during emergencies. As the 

sector transitions from legacy networks 

to IP-based networks, consumer and 

public safety groups and others have 

raised concerns about how the 

communications networks will function 

during times of crisis. 

GAO was asked to examine the 

reliability of the nation’s 

communications network in an IP 

environment during times of crisis. 

GAO examined (1) the potential

challenges affecting IP networks in 

times of crisis and how the challenges 

may affect end users, and (2) the 

actions FCC, DHS, and other 

stakeholders have taken to ensure the 

reliability of IP communications. GAO 

reviewed FCC and DHS documents as 

well as FCC proceedings and 

comments filed with FCC on the IP 

transition and emergency 

communications. GAO assessed 

FCC’s efforts to collect data on the 

effect of the IP transition. GAO 

interviewed officials from FCC and 

DHS, and representatives from the 

three largest telecommunications 

carriers, industry associations, and 

public interest and consumer advocacy 

groups. 

What GAO Recommends

FCC should strengthen its data 

collection efforts to assess the IP 

transition’s effects. FCC did not agree 

or disagree with the recommendation 

and stated it has a strategy in place to 

oversee the IP transition. However, 

GAO continues to believe FCC should 

strengthen its data collection efforts.

What GAO Found

As the nation’s telecommunications systems transition from legacy telephone 

networks to Internet Protocol (IP)-based networks, telecommunications carriers 

can face challenges during times of crisis that affect end users’ ability to call 911 

and receive emergency communications. These challenges include (1) 

preserving consumer service and (2) supporting existing emergency 

communications services and equipment. For example, during power outages, 

consumers with service provided over IP networks and without backup power 

can lose service. The Federal Communications Commission (FCC) is working to 

address this issue by adopting rules that will require carriers to provide 

information to consumers on backup power sources, among other things. 

Another challenge is that IP networks may not support existing 

telecommunications “priority” services, which allow key government and publicsafety officials to communicate during times of crisis. 

FCC, the Department of Homeland Security (DHS), and telecommunications 

carriers have taken various steps to ensure the reliability of IP communications, 

for example:

· FCC proposed criteria—such as support for 911 services, network security, 

and access for people with disabilities—to evaluate carriers’ replacement of 

legacy services when carriers seek to discontinue existing service. 

· DHS coordinated the development of the Communications Sector Specific 

Plan to help protect the nation’s communications infrastructure. 

· Carriers told GAO they build resiliency and reliability into their IP networks as 

part of business operations and emergency planning.

FCC is also collecting data on the IP transition, but FCC could do more to ensure 

it has the information it needs to make data-driven decisions about the transition. 

FCC has emphasized that one of its statutory responsibilities is to ensure that its 

core values, including public safety capabilities and consumer protection, endure 

as the nation transitions to modernized networks. FCC stated that fulfilling this 

responsibility requires learning more about how the transition affects consumers. 

FCC plans on collecting data on the IP transition primarily through voluntary 

experiments proposed and run by telecommunications carriers. However, it is 

unclear if FCC will be able to make data-driven decisions about the IP transition 

because of the limited number and scale of the proposed experiments. In 

particular, there are only three proposed experiments that cover a very limited 

number of consumers; none of the experiments covers consumer services in 

high-density urban areas or includes critical national-security or public-safety 

locations. FCC also sought comment on how to supplement its data-gathering 

process; however, soliciting comments may not necessarily result in a change in 

FCC’s existing policies. GAO found FCC lacks a detailed strategy that outlines 

how it will address its remaining information needs. Developing a strategy for 

collecting information about how the IP transition affects public safety and 

consumers would help FCC make data-driven decisions and address areas of 

uncertainty as it oversees the IP transition. 

View GAO-16-167. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

GoldsteinM@gao.gov.
Letter 1

Page i GAO-16-167 Internet Protocol Transition

Background 4

Agencies and Stakeholders Have Taken Steps to Ensure IP 

Networks Are Reliable, but FCC Has Little Information to 

Assess the Effect of the IP Transition 17

Conclusions 29

Recommendation for Agency Action 29

Agency Comments and Our Evaluation 29

Appendix I: Objectives, Scope, and Methodology 32

Appendix II: Comments from the Federal Communications Commission 36

Appendix III: GAO Contact and Staff Acknowledgments 42

Appendix IV: Accessible Data 43

Agency Comment Letter 43

Related GAO Products 53

Tables

Table 1: Government Emergency Telecommunications Service (GETS) 

Performance during Select Crises 15

Table 2: Additional Organizations Interviewed 34

Figures

Figure 1: Legacy Copper Network versus IP Network without Backup 

Power during Power Outages 5

Figure 2: Government Emergency Telecommunications Service (GETS) 

Users, as of November 2015 14

Figure 3: Proposed Service-Based Experiments for the Internet Protocol 

(IP)Transition, as of October 2015 26

Contents
Page ii GAO-16-167 Internet Protocol Transition

Abbreviations 

APCO Association of Public Safety Communications

Officials International 

ATIS Alliance for Telecommunications Industry

Solutions 

Communications Act Communications Act of 1934, as amended 

CSRIC Communications Security, Reliability, and

Interoperability Council 

DHS Department of Homeland Security 

DIRS Disaster Information Reporting System 

FCC Federal Communications Commission 

GETS Government Emergency Telecommunications

Service 

IP Internet Protocol 

NORS Network Outage Reporting System

TDM time-division multiplexed 

VoIP Voice over Internet Protocol

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-167 Internet Protocol Transition

441 G St. N.W.

Washington, DC 20548

December 16, 2015

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Frank Pallone, Jr.

Ranking Member 

Committee on Energy and Commerce 

House of Representatives

The communications sector is essential to the nation’s economy, public 

safety, and government operations. As part of the nation’s critical 

infrastructure, communications networks are especially important due to 

the enabling functions they provide across all critical infrastructure 

sectors; the loss of communications facilities could have cascading 

effects on other critical infrastructures due to interdependencies among 

sectors.1 Furthermore, communications services play an essential role in 

the delivery of public safety services, especially during emergencies. The 

communications sector is transitioning from legacy networks to an allInternet Protocol (IP) environment, leading consumer and public safety 

groups, among others, to question how reliably the nation’s 

communications networks will function during times of crisis, such as 

natural and man-made disasters. While the private sector owns and 

operates the nation’s communications networks and is primarily in charge 

of managing and protecting these assets, federal law and policy establish 

regulatory and support roles for the federal government related to 

communications networks. In particular, the Federal Communications 

Commission (FCC) and Department of Homeland Security (DHS) have 

roles in enhancing the cyber and physical security of the communications 

infrastructure that is essential to national security and public health and 

safety.

 

1According to Executive Order 13636, critical infrastructure consists of the assets and systems, 

whether physical or virtual, so vital to the United States that their incapacitation or destruction 

would have a debilitating effect on security, national economic security, national public 

health or safety, or any combination thereof. 78 Fed. Reg. 11739 (Feb. 19, 2013).

Letter
The communications sector’s infrastructure is in the midst of a significant 

change, which FCC refers to as a series of technology transitions from 

legacy networks built for one specific purpose (e.g., telephone calls) to IPbased networks built for a variety of purposes (e.g., broadband, video, 

data, voice, etc.).

Page 2 GAO-16-167 Internet Protocol Transition

2 According to FCC, modernizing communications 

networks through this and other means can dramatically reduce network 

costs and broaden access to new technologies, allowing 

telecommunications carriers to serve customers with increased 

efficiencies that can lead to improved and innovative product offerings 

and lower prices. The IP transition, however, is a gradual shift; thus, it will 

take many years to complete and has no specific end date. In 2014, FCC 

established a framework for telecommunications carriers to conduct 

voluntary “service-based” experiments, whereby carriers could substitute 

new communications technologies, such as fiber and cable for the 

services that they currently provide to customers over legacy copper 

lines.3 According to FCC, these voluntary service-based experiments will 

examine the effects of replacing existing customer services with IP-based 

alternatives.

You asked us to review issues related to the reliability of the nation’s 

communications network in an IP environment during times of crisis, 

which could include weather events (e.g., hurricanes or flooding); manmade disasters (e.g., vandalism or terrorist attacks); and unintentional 

man-made outages (e.g., a backhoe cutting a communication line). This 

report examines (1) the potential challenges affecting IP networks in 

times of crisis and how the challenges affect end users, and (2) the 

actions FCC, DHS, and other stakeholders have taken to ensure the 

reliability of IP communications during times of crisis.

To address these objectives, we reviewed relevant FCC and DHS 

documents including orders, notices of proposed rulemakings, reports, 

and risk assessments, as well as relevant statutes and regulations. We 

reviewed comments filed with FCC regarding the IP transition and 

emergency communications. To ensure we reviewed a broad range of 

comments, we selected comments by stakeholders that represented a 

variety of interests, including public interest groups, industry and trade 

associations, and state and local authorities. To identify information on 

 

2

In this report, we refer to this change as the IP transition. 

3

79 Fed. Reg. 11327 (Feb. 28, 2014).
the proposed IP transition service-based experiments, we reviewed three 

experiment proposals submitted by telecommunications carriers, 

stakeholder comments to FCC on these proposals, and other documents 

related to the service-based experiments.

Page 3 GAO-16-167 Internet Protocol Transition

4 We assessed FCC’s efforts to 

collect data on the effect of the IP transition against criteria established in 

the federal Standards for Internal Control.5 We reviewed relevant DHS 

documents including the 2013 National Infrastructure Protection Plan, the 

2010 Communications Sector Specific Plan, and the 2012 Risk 

Assessment Report for Communications. We interviewed state and local 

officials and other stakeholders in six states—New York, New Jersey, 

Arizona, California, Florida, and Alabama—to obtain additional 

information on the challenges facing IP networks and how these 

challenges affect end users, and to obtain information on state efforts to 

ensure reliability. We selected these locations because they represent a 

mix of communities that have experienced a major communications 

outage since 2012 or that contain an area with a proposed IP transition 

experiment. These communities also contain a mix of rural, suburban, 

and urban communities, and demographics including economic 

differences and average age of residents. We also interviewed officials 

from FCC, DHS, and representatives from selected stakeholder groups 

including public-interest and consumer-advocacy groups, industry 

associations, the three largest telecommunications companies, and other 

stakeholders. We identified stakeholders to interview based on our review 

of comments filed in FCC’s Technology Transitions proceeding, as well 

as based on recommendations from other organizations we interviewed. 

More details about our scope and methodology can be found in appendix 

I.

We conducted this performance audit from December 2014 to December 

2015 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

 

4At the time of our review, FCC had received three service-based experiment proposals, two of 

which were submitted by AT&T and one by CenturyLink. 

5GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). The most recent version of these standards was 

issued in September 2014 and becomes effective October 1, 2015. GAO, Standards for 

Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 10, 

2014). We did not use the new standards to assess FCC’s efforts to collect data on the 

effect of the IP transition because the new standards were not in effect at the time of our 

review.
obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The communications sector’s infrastructure is a complex system of 

systems that incorporates multiple technologies and services. The 

infrastructure includes wireline, wireless, satellite, cable, and 

broadcasting capabilities, and includes the transport networks that 

support the Internet and other key information systems. Historically, 

networks based on time-division multiplexed (TDM) circuit-switches

Page 4 GAO-16-167 Internet Protocol Transition

6

running on copper loops provided voice service for consumers. In a 2015 

report and order, FCC noted that for over 100 years customers could rely 

upon telecommunications carriers for backup power for their residential 

landline phones during power outages7 because power is provided over 

traditional copper telephone lines. In other words, telephones served by 

copper networks continue to work during commercial power outages as 

long as the telephones do not need to be plugged into an electrical outlet 

to function.8 On the other hand, the physical infrastructure for IP-based 

networks, such as fiber and co-axial cable, does not carry power, which 

means telephones connected to IP networks may not work during 

commercial power outages (see fig.1).

 

6 TDM is a method by which multiple subscribers can share a common transmission medium.

7

In the Matter of Technology Transitions; Policies and Rules Governing Retirement Of 

Copper Loops by Incumbent Local Exchange Carriers; Special Access for Price Cap Local

Exchange Carriers; AT&T Corporation Petition for Rulemaking to Reform Regulation of 

Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, 30 FCC 

Rcd 9372, August 7, 2015, Released, August 6, 2015, Adopted.

8

For the traditional copper landline phone to continue to work during electric outages, the 

carrier’s central office must maintain power and supply that power through an all-copper 

network, meaning copper has not been replaced by fiber at any point in the network 

between the central office and the consumer’s landline phone.

Background
Figure 1: Legacy Copper Network versus IP Network without Backup Power during Power Outages

Page 5 GAO-16-167 Internet Protocol Transition

According to FCC, networks other than copper and services not based on 

TDM may not support data-based services such as credit card readers, 

home alarms, and medical alert monitors. The Alarm Industry 

Communications Committee noted in comments filed with FCC that the 

traditional TDM-based telephone service meets the standards necessary 

for fire protection and other life and safety applications, such as line 

seizure, the detection of a loss in communications path, and the proper 

encoding and decoding of tone messages sent by the alarm panel.9 The 

committee stressed that as networks transition to IP-based networks, 

these traits must be preserved.

 

9The Alarm Industry Communications Committee is composed of representatives of the Central 

Station Alarm Association International, the Electronic Security Association, the Security Industry 

Association, and major alarm companies and manufacturers.
FCC notes that there are a number of distinct but related kinds of 

technology transitions, including: (1) changes in network facilities and in 

particular retirement of copper facilities, and (2) changes that involve the 

discontinuance, impairment, or reduction of legacy services, irrespective 

of the network facility used to deliver those services. In the case of retiring 

copper facilities, the Communications Act of 1934, as amended 

(Communications Act), and FCC rules thereunder allow 

telecommunications carriers to transition to new facilities without needing 

FCC approval as long as the change of technology does not discontinue, 

reduce, or impair the services provided.

Page 6 GAO-16-167 Internet Protocol Transition

10 FCC rules do require incumbent 

telecommunications carriers to give notice to interconnecting carriers of 

planned copper retirements, and new FCC rules require incumbent 

carriers to give notice to retail customers of such planned copper 

retirements when such retirements remove copper to the customers’

premises without consumer consent, along with particular consumer 

protection measures.11 Such consumer protections include explanations 

of how consumers may seek more information from carriers about the 

copper retirement process and its possible impact on consumers’ service, 

and links for the FCC’s consumer complaint portal. With respect to 

service discontinuance, under the Communications Act, 

telecommunications carriers must obtain FCC approval before they 

discontinue, reduce, or impair service to a community or part of a 

community.12 FCC regulations include procedures for carriers to 

discontinue, reduce, or impair service. The regulations state that to 

discontinue telecommunications service, carriers must notify customers of 

this intent and file an application with FCC. Once an application is 

received, FCC issues a public notice and considers these applications on 

a case-by-case basis and also accepts and reviews comments on 

proposed discontinuations, reductions, or impairments of 

 

1047 U.S.C. §§ 214, 251(c)(5); 47 C.F.R. §§ 51.325-51.335.

1147 C.F.R. § 51.332 (as amended by In the Matter of Technology Transitions, Policies and Rules 

Governing Retirement of Copper Loops by Incumbent Local Exchange Carriers, Special Access 

for Price Cap Local Exchange Carriers, and AT&T Corporation Petition for Rulemaking to 

Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special 

Access Services, 30 FCC Rcd 9372, August 7, 2015, Released, August 6, 2015, Adopted, 

at App’x A). The updated copper retirement rules adopted in August 2015 contain 

information collection requirements that must be approved by the Office of Management 

and Budget. FCC will publish a document in the Federal Register announcing the effective 

date.

1247 U.S.C. § 214(a).
telecommunications service.

Page 7 GAO-16-167 Internet Protocol Transition

13 According to the order, FCC will normally 

authorize the discontinuance, reduction, or impairment of service unless it is 

shown that to do so would adversely affect the public convenience and 

necessity, with regard to which FCC considers, among other things, 

whether customers would be unable to receive service or a reasonable 

substitute from another carrier.

FCC officials told us that there is no forcing action or requirement for 

telecommunications carriers to transition to IP by a certain date and that 

the technology transitions are organic processes without a single starting 

or stopping point. In an August 2015 order, FCC noted that recent data 

indicate 30 percent of all residential customers choose IP-based voice 

services from cable, fiber, and other carriers as alternatives to legacy 

voice services. Furthermore, an additional 44 percent of households were 

“wireless-only” meaning these households only have wireless telephones. 

The August 2015 order also states that overall, almost 75 percent of U.S. 

residential customers (approximately 88-million households) no longer 

receive telephone service over traditional copper facilities because they 

rely on IP-based voice services or wireless phone service.14

Both FCC and DHS play a role in regulating the transition to IP and 

ensuring public safety communications are not at risk.

· Pursuant to the Communications Act, FCC is charged with regulating 

interstate and international communications by radio, television, wire, 

satellite, and cable throughout the United States.15 FCC officials 

stated that FCC is to promote the reliability, resiliency, and availability 

of the nation’s communications networks at all times, including in 

times of emergency or natural disaster. Further, FCC has the authority 

to adopt, administer, and enforce rules related to communications 

 

1347 C.F.R. § 63.71(a).

14In the Matter of Technology Transitions, Policies and Rules Governing Retirement of Copper 

Loops by Incumbent Local Exchange Carriers, Special Access for Price Cap Local Exchange 

Carriers, and AT&T Corporation Petition for Rulemaking to Reform Regulation of 

Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, 30 FCC 

Rcd 9372, August 7, 2015, Released, August 6, 2015, Adopted.

1547 U.S.C. § 151 et seq.
reliability and security,

Page 8 GAO-16-167 Internet Protocol Transition

16 911,17 and emergency alerting.18 FCC’s 

regulations include requirements for certain telecommunications 

carriers to report on the reliability and security of communications 

infrastructures, specifically reporting on network outages. FCC also 

asks carriers to report voluntarily on the status of the restoration of 

communications in the event of a large scale disaster.

· DHS is the principal federal agency to lead, integrate, and coordinate 

the implementation of efforts to protect communications infrastructure. 

DHS’s role in critical infrastructure protection is established by law 

and policy. The Homeland Security Act of 2002,19 Homeland Security 

Presidential Directive 7,20 and the National Infrastructure Protection 

Plan21 establish an approach for protecting the nation’s critical 

infrastructure sectors— including communications—that focuses on 

the development of public private partnerships and establishment of a 

risk management framework. These policies establish critical 

 

16See, e.g., 47 U.S.C. §§ 151,154(o), 222,303(b), 303(g), and 551.

17See, e.g., 47 U.S.C. §§ 151, 152(a), 154(i)-(j), 157, 160, 201, 214, 222, 251(e), 301, 

302, 303(b), (g) and (r), 251(e)(3), 307, 307(a), 309, 309(j)(3), 316, 316(a), 332, 615 note, 

615, 615a, 615a-1, 615b, and 615c(g).

18See, e.g., 47 U.S.C §§ 151, 152, 154(i), 154(o), 301, 303(b), (g) and (r), 303(v), 307, 

309, 335, 403, 544(g), 606, 613, 615 and 1302; The Warning, Alert and Response 

Network (WARN) Act, Title VI of the Security and Accountability for Every Port Act of 

2006, Pub. L. No. 109-347, §§ 602(a), (b), (c), (d), (f), 603, 604, and 606, 120 Stat. 1884 

(2006) (the “WARN Act”); Twenty-First Century Communications and Video Accessibility 

Act of 2010, Pub. L. No. 111-260 and Pub. L. No. 111-265.

19Homeland Security Act of 2002, Pub. L. No. 107-296, 116 Stat. 2135 (Nov. 25, 2002). Among 

other things, the act assigned DHS responsibility for protecting critical infrastructure.

20The White House, Homeland Security Presidential Directive 7 (Washington, D.C.: Dec.17, 

2003). The directive assigned responsibilities for DHS and other federal agencies focused 

on specific critical infrastructure sectors. These sector-specific agencies are responsible 

for identifying, prioritizing, and coordinating the protection of critical infrastructure to 

prevent, deter, and mitigate the effects of attacks. As of February 12, 2013, Presidential 

Policy Directive 21 revoked Homeland Security Presidential Directive 7. However, 

Presidential Policy Directive 21continues to assign agencies to specific sectors and states 

that plans developed pursuant to Homeland Security Presidential Directive 7 shall remain 

in effect until specifically revoked or superseded. 

21National Infrastructure Protection Plan, Partnering for Critical Infrastructure Security and 

Resilience (Washington, D.C.: 2013). This plan is intended to guide efforts to manage 

risks to the nation’s critical infrastructure by identifying national priorities; articulating clear 

goals; mitigating risk; measuring progress; and adapting based on feedback and the 

changing environment.
infrastructure sectors, including the communications sector; assign 

agencies to each sector (sector-specific agencies), including DHS as

the sector lead for the communications and information technology 

sectors; and encourage private sector involvement. Pursuant to 

Presidential Policy Directive 21, DHS is to coordinate the overall 

federal effort to promote the security and resilience of the nation’s 

critical infrastructure from all-hazards.

Page 9 GAO-16-167 Internet Protocol Transition

22

As the nation’s telecommunications systems transition to IP networks, 

carriers can face challenges during times of crisis that affect end users’

ability to call 911 and receive emergency communications. These 

challenges include (1) preserving consumer service and (2) supporting 

existing emergency communications services and equipment. FCC, DHS, 

and other stakeholders have taken steps to help address these 

challenges, but some persist.

Providers face challenges in preserving service during times of crisis such 

as natural disasters or outages caused by malicious acts and accidents. 

For example, weather events, such as hurricanes and tornados, can 

damage telecommunications infrastructure and the power sources 

communications systems rely on to provide service. A 2012 DHS report 

entitled 2012 Risk Assessment Report for Communications identified

risks to communication networks from violent weather that include fuel not 

being available for generators during a commercial power outage; aerial 

infrastructure unable to withstand high winds; utility poles unable to 

withstand high winds; and underground infrastructure unable to withstand 

flooding. Destruction of communications infrastructure by storms can 

affect both legacy copper wire and IP networks. For example, in talking 

with officials from New York and New Jersey about Hurricane Sandy, the 

officials told us the storm damaged both copper lines and fiber optic 

cable. However, as explained previously, in general, consumers with 

basic telephones and service provided over copper lines can still operate 

during a commercial power outage, as long as the carrier’s central office 

maintains power and keeps supplying line power through an all-copper 

network. In contrast, consumers with service provided over IP networks 

require a backup power source, such as a battery, since IP network 

infrastructure does not carry electrical power for the purpose of powering 

 

22Presidential Policy Directive/PPD-21—Critical Infrastructure Security and Resilience 

(Washington, D.C.: Feb. 12, 2013).

Carriers Face Challenges 

Preserving Services on IP 

Networks during Times of 

Crisis

Preserving Consumer Service
end devices, such as telephones. Officials we contacted from four state 

agencies, and representatives from four trade and industry organizations 

and consumer groups emphasized the importance of backup power for 

communications during emergencies.

To address backup power requirements during a commercial power 

outage, FCC issued rules addressing 911 reliability and the reliability and 

continuity of communications networks for both carriers’ central office 

facilities and consumers’ homes. Specifically, in 2013, FCC issued new 

rules on central office backup power certification requirements for certain 

911 service providers.

Page 10 GAO-16-167 Internet Protocol Transition

23 In an August 2015 order, FCC noted that many 

consumers remained unaware they needed to take action to ensure their 

landline telephone service remained available in the event of a 

commercial power outage. FCC concluded that the transition to all-IP 

networks had the potential to create a widespread public safety issue if 

unaddressed. Therefore, FCC adopted rules to help ensure consumers 

have the information and tools necessary to maintain landline home 

telephone service during emergencies. When these rules become 

effective, FCC will require that telecommunications carriers communicate 

information to consumers regarding backup power, such as the 

availability of backup power sources, service limitations with and without 

backup power, and purchase options. FCC will also require 

telecommunications carriers to give consumers the option to purchase a 

backup power device with at least 8 hours of standby power during a 

commercial power outage enabling calls, including those to 911. 

Furthermore, FCC will require carriers to offer consumers the option to 

purchase 24 hours of backup power within 3 years.24

In addition to weather events, telecommunication network outages can 

occur through malicious acts, such as vandalism and cyber attacks, and 

by accidental cable cuts and software coding errors. For example, a fiber 

 

23This order addresses, among other things, annual audits of critical circuit diversity, 911 network 

monitoring, and specific time limits for outage notifications to 911 call centers. In the 

Matter of Improving 911 Reliability; Reliability and Continuity of Communications 

Networks, Including Broadband Technologies, Report and Order, FCC 13-158, 28 FCC 

Rcd. 17476 (2013). And In the Matters of Improving 911 Reliability and Reliability and 

Continuity of Communications Networks Including Broadband Technologies. Order on 

Reconsideration, 30 FCC Rcd 8650, July 30, 2015, Released, July 29, 2015, Adopted. 

(2015). 

24In the Matter of Ensuring Continuity of 911 Communications, FCC 15-98, 30 FCC Rcd 8677,

August 7, 2015, Released, August 6, 2015, Adopted.
optic cable north of Phoenix was vandalized in February 2015, causing 

large-scale telephone and Internet outages across much of Northern 

Arizona. According to local officials we contacted, the outage lasted about 

a day and included Flagstaff, Sedona, Prescott, and surrounding areas 

potentially affecting more than 300,000 people. Officials told us that the 

Flagstaff police department’s 911 lines were down, so they sent staff to a 

backup site at the Arizona Department of Public Safety to answer calls; 

the police department also lost all Internet, a loss that prevented it from 

checking for warrants and driver’s licenses. Additionally, officials told us 

that some businesses closed because they could not process credit card 

transactions, that ATMs did not work, and that Northern Arizona 

University lost Internet service. According to a Flagstaff official, the 

telecommunications carrier is now building, and expects to complete by 

2016, an additional fiber optic cable that will improve resiliency and 

redundancy.

Cyber attacks can also challenge both IP networks and traditional legacy 

networks; however, DHS officials told us that IP networks are more prone 

to cyber attacks than legacy networks, because legacy networks are 

closed systems that are less vulnerable to cyber attacks. Under the terms 

of a 2013 executive order and a related presidential policy directive, it is 

the policy of the United States to strengthen the security and resilience of 

its critical infrastructure against both physical and cyber threats.

Page 11 GAO-16-167 Internet Protocol Transition

25 In a 

2015 report, the Communications Security, Reliability and Interoperability 

Council (CSRIC)26 identified cybersecurity threats to Voice over IP 

(VoIP)27 and voice services that include disrupting network availability, 

 

25On February 12, 2013, the President signed Executive Order 13636 and issued Presidential 

Policy Directive 21 to improve critical infrastructure cybersecurity and advance efforts to 

strengthen and maintain secure, functioning, and resilient critical infrastructure, 

respectively. The executive order, which was published in the Federal Register at 78 Fed. 

Reg. 11739 (Feb.19, 2013), prescribes actions to be taken by federal agencies, including 

the Departments of Defense, Homeland Security, and Commerce (including the National 

Institute of Standards and Technology), related to enhancing cybersecurity. In addition, 

the directive details responsibilities of federal agencies related to critical infrastructure 

security and resilience, including those of FCC and the Department of Commerce.

26CSRIC is one of FCC’s federal advisory committees and is composed of experts from the 

private sector, consumer or community organizations or other non-profit entities, and 

representatives from federal and other government agencies. 

27VoIP is the routing of voice conversations over the Internet or any other IP network.
compromising confidentiality, and spoofing a caller’s identity.

Page 12 GAO-16-167 Internet Protocol Transition

28 According 

to FCC officials, CSRIC is developing recommendations to support the 

real-time sharing of cyber threat information among private sector entities. 

For our recent products related to cybersecurity and information security, 

see related GAO products listed at the end of this report.

As with legacy copper networks, accidents also cause IP network outages 

affecting communication capabilities. For example, a truck accident in 

2014 took out 400 feet of aerial fiber optic cable along a rural road in 

Mendocino County, California. According to a local incident report, 

telephone, Internet, cellular, and 911 services went down for thousands of 

residents, and Internet service was out almost completely along a 40-mile 

corridor for approximately 45 hours. According to local officials we 

contacted, 911 services were unavailable, and the county sheriff 

estimated that 20 percent of county residents lost vital services. Alert 

notifications through phone calls were unavailable for residents waiting to 

receive evacuation notices just as a nearby wildfire was growing.29

According to an incident report, health care providers could not be 

reached; banks and supermarkets closed because they were unable to 

function without Internet, telephone, and ATM services; and electronic 

food stamp benefits were unavailable.

IP network outages caused by human error, such as software coding 

errors, can affect large numbers of people over wide geographic areas. 

Such outages are sometimes referred to as “sunny day” outages. For 

example, in April 2014, a 911 call-routing facility in Colorado stopped 

directing emergency calls to 911 call centers in 7 states.30 The outage 

was caused by a coding error and resulted in a loss of 911 services for 

more than 11-million people for up to 6 hours. Unlike legacy copper 

networks, IP networks permit call control to be distributed among just a 

few large servers nationwide, meaning each server can serve millions, or 

 

28CSRIC Working Group 4, Cybersecurity Risk Management and Best Practices: Final 

Report, (Washington, D.C.: March 2015).

29According to the California Public Utilities Commission, reverse calling alert notification 

(commonly referred to as Reverse 911) is used in California to inform residents and give 

emergency instructions during fires, flooding, extreme weather, or any other kind of 

emergency.

30According to FCC, over 6,600 calls to 911 did not reach the appropriate call center across seven 

states including Washington, North Carolina, South Carolina, Pennsylvania, California, 

Minnesota, and Florida.
even tens of millions, of customers, according to FCC. State officials from 

New York and California told us that IP networks allow for increased 

consolidation of equipment and facilities, which means that when an 

outage does occur, it can potentially last longer and affect more people 

across a wider area than legacy networks. An FCC investigation into a 

multistate 911 outage in 2014 found that this geographical consolidation 

of critical 911 capabilities may increase the risk of a large “sunny day”

outage caused by software failures rather than disasters or weather 

conditions.

Page 13 GAO-16-167 Internet Protocol Transition

31 According to this investigation, large-scale outages may

result when IP networks do not include appropriate safeguards. In 2013, 

FCC adopted rules requiring 911 service providers to certify annually that 

they comply with industry-backed best practices or implement alternative 

measures that are reasonably sufficient to assure reliable 911 service.32

IP networks may not support existing communication services that key 

government officials and others rely on during times of crisis. 

Communications networks can become congested during emergencies, 

preventing government officials and other national security and 

emergency preparedness personnel from communicating with one 

another. To overcome this congestion, DHS maintains priority 

telecommunications services, such as the Government Emergency 

Telecommunications Service (GETS) that provide priority calling 

capabilities to authorized users. GETS was initially designed in the 1990s 

to operate with legacy networks during times of congestion. DHS officials 

told us that over the past 5 years similar priority features have been 

implemented in the core IP networks of select U.S. nationwide longdistance service providers. DHS officials told us congestion, caused by 

high-call volume and potentially as a result of cyber attack, will continue 

to be a challenge in an IP environment. FCC officials told us that although 

congestion may not be as likely in IP networks as it was in legacy 

networks, it will still occur. As shown in figure 2, numerous government 

 

31FCC, Public Safety & Homeland Security Bureau, April 2014 Multistate 911 Outage: Cause and 

Impact, PS Docket No. 14-72, PSHSB Case File Nos. 14-CCR-0001-0007 (October 2014).

32In the Matter of Improving 911 Reliability; Reliability and Continuity of Communications 

Networks, Including Broadband Technologies, Report and Order 28 FCC Rcd 17476, December 

12,2013, Released, December 12,2013, Adopted.

Supporting Existing 

Emergency Communication 

Services and Equipment
officials and non-government organizations in critical positions rely on 

GETS when networks become congested during times of crisis.

Page 14 GAO-16-167 Internet Protocol Transition

33

Figure 2: Government Emergency Telecommunications Service (GETS) Users, as of November 2015

The value of priority telecommunications service when compared to 

regular network performance becomes apparent during times of crisis. 

For example, according to DHS, during Hurricane Sandy and the 

immediate aftermath, networks were congested due to damage and high 

call volume into and out of the storm-damaged area. Likewise, according 

 

33In addition, tribal and territorial government officials, critical infrastructure sectors in 

industry, and non-governmental organizations performing their national security and 

emergency preparedness missions are eligible to use GETS.
to DHS officials and a DHS report on the Boston Marathon bombing, as 

news of the bombs spread, cell phone networks became congested with 

users and were largely unavailable for about 90 minutes.

Page 15 GAO-16-167 Internet Protocol Transition

34 As shown in 

table 1, GETS had high call-completion rates during recent times of crisis.

Table 1: Government Emergency Telecommunications Service (GETS) Performance 

during Select Crises

Event GETS calls GETS completion rate

Hurricane Sandy, October 2012 18,347 99.4%

Boston Marathon bombing, April 2013 291 97.3%

Oklahoma tornadoes, May 2013 636 95.8%

California wildfires, May 2014 1,629 98%

Source: Department of Homeland Security. | GAO-16-167

DHS officials told us that the current GETS will likely lose some 

functionality during the transition to an all-IP environment.

35 The officials 

said they are planning a project that will provide priority for IP wireline 

access, but the project has not yet received approval for acquisition. In 

2015, a multi-agency executive committee reported that the national 

security and emergency preparedness community must be able to rely on 

these priority services to complete their mission-essential 

communications in the IP environment.36 DHS is working on a program 

that is aimed at enabling users to have priority voice, data, and video 

communications as networks evolve, but according to DHS officials, data 

and video capabilities will not be available for several years. In the 

meantime, as telecommunications carriers transition from legacy 

networks to IP networks, key national security and emergency 

preparedness personnel might not be able to complete important GETS 

calls during times of crisis. CSRIC is currently assessing how priority 

 

34Specific data on call completion rates for callers not using GETS was not available.

35Under legacy systems, each GETS call is routed with priority through three networks—an access 

network, a long-distance network, and an egress network. In an IP system, a GETS call currently 

receives priority on the long-distance core network but not on the access or egress 

networks, according to DHS.

36The National Security Emergency Preparedness Communications Executive Committee is an 

interagency forum to address such communication matters for the nation. Its members represent 

the Departments of State, Defense, Justice, Commerce, and Homeland Security, the 

Office of the Director of National Intelligence, the General Services Administration, and 

FCC. 
services programs can take advantage of IP technologies and intends to 

recommend protocols that can be used to ensure priority communications 

upon the retirement of legacy services. As CSRIC noted, this is important 

since the federal government is losing priority capabilities that rely on 

networks that will eventually be replaced by IP-based infrastructure. 

According to FCC officials, CSRIC estimates that the recommendations 

on protocols and standards that can support the delivery of priority 

communications for first responders and national security personnel over 

IP networks will be complete in March 2017.

New IP networks may no longer support other government and consumer 

public safety services and equipment that work in the existing legacy 

network. Examples of such items include alarm systems and 911 call 

center systems. According to the Alarm Industry Communications 

Committee, telecommunications carriers installing new IP services may 

prevent alarm signals from being transmitted, and some IP services may 

improperly encode alarm signals. In comments submitted to FCC, the 

Association of Public Safety Communications Officials International 

(APCO) noted that alarm systems and medical alert monitors need to be 

provided for under new IP networks. APCO commented that alarms and 

alerts are a critical part of the input into 911 call centers and any identified 

shortfalls or anomalies should be identified to ensure that any effect to the 

public or public safety is known well ahead of time. APCO also 

commented that copper replacements in the foreseeable future must 

accommodate existing 911 call centers in the relevant service area, 

including those that have not yet transitioned to IP-based systems. As 

discussed, that transition will not be immediate and continuity of 

operations with existing 911 systems is vital for public safety.

Page 16 GAO-16-167 Internet Protocol Transition
Page 17 GAO-16-167 Internet Protocol Transition

In addition to addressing the specific challenges affecting IP networks 

during times of crisis described above, FCC has taken a variety of other 

actions to help ensure the overall reliability of IP networks, including the 

following:

· Proposed criteria in August 2015 to evaluate and compare the 

replacement of legacy services. FCC had not previously codified any 

specific criteria by which it evaluated the adequacy of substitute 

services, but proposed changes to the process in a further notice of 

proposed rulemaking.37 Specifically, FCC proposed that to be eligible 

for automatic grant of authority under FCC’s rules, a

telecommunications carrier seeking to discontinue an existing retail 

service must demonstrate that any substitute service meet criteria 

related to (1) interoperability with devices and services, such as alarm 

services and medical monitoring; (2) support for 911 services and call 

centers; (3) network capacity and reliability; (4) quality of both voice 

service and Internet access; (5) access for people with disabilities, 

including compatibility with assistive technologies; (6) network security 

 

37In the Matter of Technology Transitions, Policies and Rules Governing Retirement of Copper 

Loops by Incumbent Local Exchange Carriers, Special Access for Price Cap Local 

Exchange Carriers, and AT&T Corporation Petition for Rulemaking to Reform Regulation 

of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, 30 

FCC Rcd 9372, August 7, 2015, Released, August 6, 2015, Adopted.

Agencies and 

Stakeholders Have 

Taken Steps to 

Ensure IP Networks 

Are Reliable, but FCC 

Has Little Information 

to Assess the Effect 

of the IP Transition

Efforts to Ensure the 

Reliability of IP Networks

FCC Efforts
in an IP-supported network; (7) service functionality; and (8) coverage 

throughout the service area. In addition, FCC proposed to require that 

part of the evaluation to discontinue a legacy retail service should 

include whether the carrier has an adequate consumer education and 

outreach plan. FCC noted it believes establishing these criteria will 

benefit industry and consumers alike and will minimize complications 

when carriers seek approval for large scale discontinuances. It also 

noted that having clear criteria in place will better allow carriers to 

know how they can obtain approval for discontinuing legacy service 

once they are ready to do so. According to representatives from 

Public Knowledge, this organization had urged FCC to establish 

metrics to compare the services that carriers are discontinuing with 

replacement services.

Page 18 GAO-16-167 Internet Protocol Transition

38 The organization’s representatives noted that 

without ensuring new services are actually substitutes for the services 

being phased out, there is a risk that entire communities could lose 

critical functionality in their communications networks. In the further 

notice of proposed rulemaking, FCC tentatively concluded that several 

of the criteria proposed by Public Knowledge are the appropriate 

criteria.

· Updated copper retirement rules and definitions to help ensure the 

public has the information needed to adapt to an evolving 

communications environment. FCC issued new rules in an August 

2015 report and order that, among other things, require incumbent 

carriers to directly notify consumers of plans to retire copper networks 

to the customer’s premises without customer consent. In this report 

and order, FCC also updated its definition of copper retirement due to 

the frequency and scope of copper network retirement. Included in 

this definition is de facto retirement, i.e., the failure to maintain these 

copper lines that is the functional equivalent of removal or disabling. 

FCC noted that it made these changes in rules and definitions since 

the record developed in that proceeding reflects numerous instances 

in which notice of copper retirement has been lacking, leading to 

 

38Public Knowledge represents the public interest on a variety of issues including 

telecommunications and consumer rights.
consumer confusion, and therefore consumers need direct notice for 

these important network changes that may directly affect them.

Page 19 GAO-16-167 Internet Protocol Transition

39

· Collected and analyzed network outage data, looking for trends, and 

communicated with telecommunications carriers. FCC developed and 

maintains the Network Outage Reporting System (NORS) for 

collecting confidential outage information from telecommunications 

carriers. These carriers are required to report information about 

disruptions or outages to their communications systems that meet 

specified thresholds.40 According to FCC, engineers on its staff 

monitor and analyze the outage reports in real time looking for trends 

in outages, communicate with carriers about outages, and produce a 

high-level network outage report. FCC officials told us that even 

though the outage information is not publicly reported, they believe 

the act of reporting helps network providers correct problems and that 

by combining multiple reports, FCC gains insight on network reliability 

and working with carriers cooperatively leads to better outcomes with 

fewer, less severe outages.41 FCC shares NORS reports with DHS’s 

Office of Emergency Communications, which may provide information 

from those reports to such other governmental authorities as it may 

deem to be appropriate.42 Otherwise, reports filed in NORS are 

presumed confidential and are thus withheld from routine public

inspection.43 However, in March 2015, FCC proposed, among other 

 

39In the Matter of Technology Transitions, Policies and Rules Governing Retirement of 

Copper Loops by Incumbent Local Exchange Carriers, Special Access for Price Cap Local 

Exchange Carriers, and AT&T Corporation Petition for Rulemaking to Reform Regulation 

of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, 30 

FCC Rcd 9372, August 7, 2015, Released, August 6, 2015, Adopted. According to FCC 

officials, most of the copper retirement rules adopted in this order contain information 

collection requirements that must be approved by the Office of Management and Budget.

4047 C.F.R. § 4.5. Such outages are defined as those that meet a minimum threshold of 

900,000 user minutes, which are calculated by multiplying the number of affected users by 

the length of the outage. For example, an outage that affected 30,000 users for a 

minimum of 30 minutes would meet the threshold of 900,000 user minutes.

41We did not obtain NORS data because we would not be able to report publicly on the 

confidential outage data.

42In the Matter of New Part 4 of the Commission’s Rules Concerning Disruptions to 

Communications, 19 FCC Rcd 16830 (2004), August 19, 2004, Released, August 4, 

2004,Adopted.

4347 C.F.R. § 4.2.
things, granting states read-only access to those portions of the 

NORS database that pertain to communications outages in their 

respective states to advance compelling state interests in protecting 

public health and safety.

Page 20 GAO-16-167 Internet Protocol Transition

44 Representatives from two state agencies 

and two consumer organizations we contacted told us that granting 

states access to outage reports would improve the overall reliability of 

communications networks by giving them additional information.

· Tracked the status of the restoration of communications in the event 

of a large scale disaster. FCC developed and maintains the Disaster 

Information Reporting System (DIRS), a voluntary system used by 

members of the communications sector intended to provide 

information on the status of restoration efforts to FCC and DHS. DIRS 

reports include information on major equipment failures and the 

service and geographic area affected. According to FCC officials, 

DIRS is only activated during major disasters, and since these 

incidents are unique, the system is not designed to track trends. For 

example, the officials said that DIRS is often activated during 

hurricanes, but because of differences in wind speed, direction, and 

other challenges, outages from one hurricane do not necessarily 

indicate infrastructure will be affected the same way in another 

hurricane.

· Chartered CSRIC to provide FCC with recommendations on ways to 

improve security, reliability, and interoperability of communications 

systems. FCC officials told us CSRIC has not specifically looked at 

ways to improve reliability of IP networks; however, there have been a 

number of working groups that aim to improve the overall reliability of 

telecommunications networks. Specifically, in September 2014, 

CSRIC issued a report and series of best practices for providing 

backup power to customers relying on IP networks and on consumer 

notification.45

 

44In the Matter of Amendments to Part 4 of the Commission’s Rules Concerning 

Disruptions to Communications; New Part 4 of the Commission’s Rules Concerning 

Disruptions to Communications, 30 FCC Rcd 3206, March 30, 2015, Released, March 27, 

2015, Adopted. FCC also sought comment on proposals to revise network outage 

reporting rules, including raising the threshold for reporting major outages, partial 911 

outages, new metrics to measure congestion during emergencies, and reducing the time 

to resolve certain events.

45CSRIC Working Group 10B, CPE Powering – Best Practices: Final Report (Washington, D.C.: 

September 2014).
DHS has also taken the following actions to help ensure the reliability of 

IP networks during times of crisis:

· Coordinated with other federal government agencies, owners and 

operators of communications networks, and state, local, tribal, and 

territorial governments. As the Sector Specific Agency for the 

communications sector, DHS manages the industry-government 

relationship, encourages private sector involvement through the 

involvement of the sector-coordinating councils, and maintains the 

Communications Sector Specific Plan. According to representatives of 

the Communications Sector Coordinating Council, the Council works 

closely with DHS, and they noted DHS is helpful in providing 

assistance for educational and outreach programs, including ensuring 

training opportunities occur when needed. DHS also coordinates with 

stakeholders by participating in CSRIC and by coordinating and 

serving as the Executive Secretariat support to the President’s 

National Security Telecommunications Advisory Committee—a 

presidential advisory group comprised of chief executives from major 

telecommunications companies, network service providers, and the 

information technology, and aerospace industries.

Page 21 GAO-16-167 Internet Protocol Transition

46 Additionally, 

DHS’s Office of Emergency Communications provides coordination 

support by offering training, coordination, and tools to stakeholders.

· Coordinated the development and implementation of the 2010 

Communications Sector Specific Plan and is currently working on an 

updated plan.

47 The sector specific plan was developed by DHS, the 

Communications Sector Coordinating Council, and the Government 

Communications Coordinating Council and is intended to ensure the 

sector effectively coordinates with sector partners, other sectors, and 

DHS. According to representatives of the Communications Sector 

Coordinating Council, they met regularly with DHS to update the 

sector specific plan. The plan provides a framework for industry and 

government partners to establish a coordinated strategy to protect the 

nation’s critical communications infrastructure. Part of this framework 

includes conducting national risk assessments. With respect to 

 

46The group aims to develop recommendations to the President to assure vital telecommunications 

links through any event or crisis and to help the U.S. government maintain a reliable, secure, and 

resilient national communications posture. 

47DHS, Communications Sector-Specific Plan: An Annex to the National Infrastructure 

Protection Plan (2010).

DHS Efforts
communications, DHS issued a report entitled 2012 Risk Assessment 

Report for Communications, which according to the report, represents 

the culmination of a 2-year period during which 29 government and 32 

industry sector partners assessed physical, cyber, and human risks of 

concern that could potentially affect local, regional, and national 

communications. According to DHS officials, the Communications 

Sector Coordinating Council and Government Communications 

Coordinating Council determined an updated risk assessment was not 

needed because details of the changing risk environment will be 

discussed and updated in other sector documents, such as the sector 

specific plan. DHS officials also told us the new plan should be 

completed in 2015 and will be updated to include the communications 

sector’s transition to IP networks and will include more focus on 

cybersecurity-related content. We did not evaluate the 2010 plan 

because it was being updated and did not evaluate the 2015 plan 

because it was not issued at the time of our review.

· Coordinated the development of the 2014 National Emergency 

Communications Plan.

Page 22 GAO-16-167 Internet Protocol Transition

48 This plan aims to enhance emergency 

communications capabilities at all levels of government in 

coordination with the private sector, nongovernmental organizations, 

and communities. DHS developed recommendations to help meet the 

plan’s five broad goals related to (1) governance and leadership, (2) 

planning and procedures, (3) training and exercises, (4) operational 

coordination, and (5) research and development. According to the 

plan, DHS’s Office of Emergency Communications intends to 

coordinate with public safety agencies and emergency responders 

and will identify strategies and timelines to accomplish the plan’s 

goals, objectives, and recommendations and measure progress 

nationwide.49

In the private sector, telecommunications carriers have also worked to 

ensure their IP networks are functional during times of crisis in the 

following ways:

· Built resiliency and reliability into IP networks as part of business 

operations and planning for emergencies. According to DHS, as the 

owners and operators of the majority of the nation’s communications 

 

48DHS, National Emergency Communications Plan (Washington, D.C.: November 2014).

49The plan includes recommendations on updating the priority service programs (including 

GETS) to help them successfully migrate to IP enabled fixed and mobile broadband 

networks.

Telecommunications Carrier’s 

Efforts
networks, private sector entities are responsible for protecting key 

commercial communications assets, as well as ensuring the resiliency 

and reliability of communications during day-to-day operations and 

emergency response and recovery efforts. In addition, commercial 

communications carriers have a primary role in network restoration 

during outages and service failures and support reconstitution for 

emergency response and recovery operations. Representatives of the 

three largest telecommunication carriers told us they are taking action 

at the company level to improve reliability because building reliability 

and resilience into networks are part of normal business operations. 

For example, these carriers have developed emergency 

preparedness plans for events such as hurricanes, to help ensure 

network reliability. These plans included pole replacement, decreased 

dependency on aerial facilities, and adding additional generators. 

Officials from one major carrier told us that customers expect the 

phone to work when they pick it up to make a call and that the 

company risks losing customers if it cannot provide reliable service.

· Participate in a variety of groups intended to provide information and 

improve the overall reliability of communications networks. For 

example, in addition to groups like CSRIC and the Communications 

Sector Coordinating Council described above, telecommunications 

carriers participate in other organizations such as the Alliance for 

Telecommunications Industry Solutions (ATIS).

Page 23 GAO-16-167 Internet Protocol Transition

50 ATIS’s Network 

Reliability Steering Committee advises the communications industry 

through developing and issuing standards, technical requirements and 

reports, best practices, and annual reports. ATIS also launched a task 

force looking at how the IP transition affects public safety 

communications infrastructure.

State authorities from three public utility agencies told us that they have 

taken action to ensure the reliability of IP networks. These actions include 

collecting consumer complaints, levying fines, reviewing outage data, and 

making recommendations for improvement. For example, officials at one 

state agency told us that they receive and investigate complaints and if an 

issue is identified levy fines or open a rulemaking proceeding. Officials at 

another state agency told us they review outage data and make 

recommendations for improvements based on lessons learned. According 

to the DHS’s 2010 Sector Specific Plan, the state Public Utility 

 

50ATIS is a technical planning and standards organization with members from communications 

companies working to develop and promote technical and operational standards. 

Selected State Agency Efforts
Commission is the primary authority for implementing regulations, and 

individual telecommunications carriers work directly with state authorities 

regularly to address regulatory issues. However, according to the 

National Regulatory Research Institute, more than half the states have 

made changes to their regulatory authority that reduced or eliminated 

retail telecommunications regulation.

Page 24 GAO-16-167 Internet Protocol Transition

51 For example, one state agency 

told us that although the commission previously had a role in ensuring the 

reliability and robustness of the communications network, it no longer has 

that authority.

FCC is collecting data on the IP transition and sought comment on 

collecting additional data on the transition’s effect on consumers, but 

could do more to ensure it has the information it needs to make datadriven decisions about the IP transition.52 The primary way FCC intends 

to gather information about the IP transition is through service-based 

experiments. In particular, FCC established a framework in January 2014 

within which carriers can conduct voluntary service-based experiments.53

These voluntary experiments would allow telecommunications carriers to 

substitute new communications technologies for the legacy services over 

copper lines that they are currently providing to customers and to test a 

variety of approaches to resolving operational challenges that result from 

transitioning to new technology and that may affect users. According to 

FCC, these experiments are not intended to test technologies or resolve 

legal or policy debates.

FCC established technical parameters for each experiment, including 

requiring each proposal to provide sufficiently detailed information about 

 

51The National Regulatory Research Institute is the research arm of National Association of 

Regulatory Utility Commissioners. National Regulatory Research Institute, Telecommunications 

Legislation 2014: Completing the Process, Report No. 14-07 (Silver Spring, MD: June 2014).

52In January 2014, FCC sought comment on how it could supplement its data-gathering 

process on the IP transition, with comments due in March 2014 and reply comments due 

in April 2014. According to FCC officials, while the formal comment period has closed, 

FCC was still accepting filings at the time of our review.

53In the Matter of Technology Transitions; AT&T Petition to Launch a Proceeding 

Concerning the TDM-to-IP Transition; Connect America Fund; Structure and Practices of 

the Video Relay Service Program; Telecommunications Relay Services And Speech-toSpeech Services for Individuals with Hearing and Speech Disabilities; Numbering Policies 

for Modern Communications: 29 FCC Rcd 1433, January 31, 2014, Released, January 30, 

2014, Adopted.

Although FCC Has Data 

Collection Efforts Under 

Way, It Has Limited 

Information about the 

Effect of the IP Transition
how the experiments will be designed to allow meaningful public 

comment and thorough evaluation of the proposed experiment. 

Specifically, each experiment proposal must include other information 

such as: the purpose and proposed metrics for measuring success; the 

scope of the experiment (geography, product, or service offering); the 

technical parameters including a description of any physical or network 

changes and how the experiment will affect customers and other 

providers and product or service offerings; and timelines. FCC noted it 

would find useful experiments that collect and provide data on key 

attributes of IP-based services, such as network capacity, 911 services 

and call centers, and cybersecurity. According to FCC officials, the 

voluntary experiments can begin without FCC approval; however, carriers 

planning to discontinue service have to seek permission from FCC prior 

to doing so. At the time of our review, the experiments were still in the 

early stages, and FCC had not approved the discontinuation of any 

existing services.

As shown in figure 3, at the time of our review, AT&T proposed 

experiments in two locations and CenturyLink proposed one location.

Page 25 GAO-16-167 Internet Protocol Transition
Figure 3: Proposed Service-Based Experiments for the Internet Protocol 

Page 26 GAO-16-167 Internet Protocol Transition

(IP)Transition, as of October 2015

According to AT&T documents, initially AT&T plans to encourage 

voluntary migration to IP-based services for existing customers through 

outreach and education. Subsequently, AT&T plans to seek FCC 

approval to “grandfather” existing customers and offer only wireless and 

wireline IP-based services for new orders. The documents also note that 

eventually, those existing customers will also have to transition to such 

alternatives, but not until FCC has evaluated the results and approved 

AT&T to discontinue legacy service and move forward to the full IP 

transition. As part of the trials, AT&T plans on collecting and reporting to 

FCC information including data on the progress of the experiment, 

customer complaints, network performance, call quality, and issues 

relating to access by persons with disabilities. According to FCC officials, 
FCC intends to contract with a major research organization to collect and 

analyze data from the AT&T experiment locations. At the time of our 

review, FCC officials told us this data collection is expected to begin in 

several months.

Unlike the AT&T experiments, CenturyLink submitted a proposal that 

does not directly affect consumers. Instead this experiment focuses on 

business end users and service providers, and according to CenturyLink’s 

own proposal, the experiment would be very narrow in scope. 

CenturyLink also noted that it was not seeking to discontinue any services 

or requesting a waiver of any FCC rules, even for the purposes of the 

experiment.

FCC is taking and plans to take additional steps to collect information on 

how consumers are experiencing the IP transition. FCC officials said they 

have begun taking action to improve consumer complaint data and make 

them more transparent, including launching a new consumer help center 

intended to collect additional consumer complaint data and working with 

various groups to share this and other data. FCC also plans to work with 

state, local, and tribal governments to leverage existing data-collection 

efforts and develop common definitions, categories, and a metric that will 

allow for comparison of consumer experiences in different parts of the 

country and help create a more comprehensive picture of the consumer 

experience as networks transition. FCC sought comment on how it could 

supplement its data-gathering process on the effects of technology 

transitions beyond consumer complaints and inquiries.

In light of the scale of the IP transition and the potential for disruptions to 

consumers and public safety, FCC recognizes it will need information on 

the effects of the transition to ensure IP communications networks are 

reliable. Federal standards for internal control, which provide the overall 

framework for identifying and addressing major performance and 

management challenges, stress the importance of obtaining information 

from external sources that may have a significant impact on an agency 

achieving its goals.

Page 27 GAO-16-167 Internet Protocol Transition

54 Furthermore, in its January 2014 order, FCC noted 

that one of its statutory responsibilities is to ensure that its core values, 

including public safety and consumer protection, endure as the nation 

 

54GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
transitions to modernized communications networks.

Page 28 GAO-16-167 Internet Protocol Transition

55 In the order, FCC 

noted that fulfilling this responsibility requires that FCC learn more about 

how the modernization of communications networks affects consumers. 

The order also states that FCC intends to collect data through the 

service-based experiments that would permit the making of data-driven 

decisions about the IP transition. However, it is unclear if FCC will be able 

to make data-driven decisions about the IP transition because of the 

limited number and scale of the proposed experiments. For example, one 

major carrier did not propose any experiments. Furthermore, as some 

organizations have commented, AT&T’s experiments have limitations 

including the small number of experiments; a lack of geographic 

dispersion; and a lack of diverse population densities, demographics, and 

climates. These experiments, as planned, will affect less than 55,000 

living units combined, which according to Public Knowledge, likely 

represent approximately 0.07 percent of AT&T’s wireline customers. 

Additionally, the proposed experiments do not include high-density urban 

areas; areas with colder climates or mountainous terrains; or areas that 

encompass diverse populations. Finally, none of the proposed 

experimental areas includes critical national security or public safety 

locations, such as those serving Department of Defense or Federal 

Aviation Administration facilities.

FCC’s other efforts related to data collection on the IP transition include 

enhancing consumer complaint data, leveraging existing data collection 

efforts at the state and local level, and seeking comments on how FCC 

could supplement its data-gathering process. However, it remains unclear 

if FCC can meet its information needs through these efforts. For example, 

as noted above, DHS officials expressed concerns about the priority 

services that national security and emergency preparedness personnel 

rely on during times of crisis, such as GETS, losing functionality in an IP 

environment. FCC may need additional information to help ensure that 

such personnel can continue to make important calls during times of 

crisis. Another area of uncertainty with the IP transition is the availability 

of 911 services and compatibility with medical devices and other 

 

55In the Matter of Technology Transitions; AT&T Petition to Launch a Proceeding Concerning 

the TDM-to-IP Transition; Connect America Fund; Structure and Practices of the Video 

Relay Service Program; Telecommunications Relay Services And Speech-to-Speech 

Services for Individuals with Hearing and Speech Disabilities; Numbering Policies for 

Modern Communications: 29 FCC Rcd 1433, January 31, 2014, Released, January 30, 

2014, Adopted.
equipment. In particular, according to AT&T, in its proposed experimental 

areas, approximately a third of customers who chose not to migrate to 

wireless service expressed concerns regarding 911 calls and 

compatibility with medical devices and other equipment. Furthermore, 

FCC’s solicitation of comments about the data-gathering process may not 

necessarily result in a change in FCC’s existing policies. Although FCC’s 

efforts to collect data represent a good start, we found FCC lacks a 

detailed strategy that outlines how it will address its remaining information 

needs, including determining what information from states and localities is 

available to be leveraged, a methodology for obtaining that information, 

and the resources required. As a result, FCC cannot ensure that it has 

the information necessary to make data-driven decisions about the IP 

transition.

FCC has recognized the importance of collecting data that would enable it 

to make data-driven decisions about the IP transition and has sought 

comment on how it could supplement its data-gathering process. 

Nevertheless, at the time of our review, FCC had little information on the 

effect of the transition, namely because the service-based experiments—

FCC’s primary method for collecting data on the transition—were very 

limited in number and scale, did not cover consumer services in urban 

areas, and did not include critical national security or public safety 

locations. Although FCC has other data collection efforts under way, it is 

unclear whether FCC’s efforts will address its remaining information 

needs, especially those related to the functionality of priority services and 

911 availability. Developing a strategy for collecting information about 

how the IP transition affects public safety and consumers would help FCC 

address these areas of uncertainty as it oversees the IP transition and 

enable FCC to make data-driven decisions.

To strengthen FCC’s data collection efforts, the Chairman of FCC should 

develop a strategy to gather additional information on the IP transition to 

assess the transition’s potential effects on public safety and consumers.

We provided a draft of this report to FCC and DHS for their review and 

comment. FCC provided written comments, reproduced in appendix II 

and technical comments, which we incorporated as appropriate. DHS 

provided technical comments, which we incorporated as appropriate. 

Page 29 GAO-16-167 Internet Protocol Transition

Conclusions

Recommendation for 

Agency Action

Agency Comments

and Our Evaluation
In written comments, FCC did not state whether it agreed or disagreed 

with our recommendation that it develop a strategy to gather additional 

information on the IP transition to assess the transition’s potential effects 

on public safety and consumers. FCC stated that it agreed with us about 

the importance of ensuring an informed, data-driven process for 

determining which services can be seamlessly supported during the IP 

transition, which services will need to be transformed, and which services 

will no longer be supported in an IP world, while preserving FCC’s core 

functions of public safety, universal service, competition, and consumer 

protection. FCC noted that it is essential that it have sufficient information 

to make informed decisions and further stated that it has a 

comprehensive data strategy in place to oversee the IP transition.

Page 30 GAO-16-167 Internet Protocol Transition

56

According to FCC, its strategy for overseeing the transition combines 

traditional regulatory approaches with innovative methods that match the 

dynamism of the communications environment. FCC stated that the 

service-based experiments are by no means the sole means by which 

FCC is overseeing the IP transition and provided examples of actions it 

has taken to oversee the transition. For example, FCC stated that it took 

the following actions, which we had already highlighted in our report: 

· enhanced its notification process for retirement of copper facilities;

· provided clear direction to industry concerning the circumstances 

in which approval must be sought before removing a service from 

the marketplace; 

· collected NORS disruption data; and 

· engaged with the private sector and other relevant stakeholders 

through FCC’s federal advisory committees, including CSRIC. 

In the letter, FCC also stated that it had taken action on some issues that 

were outside the scope of our review, including revising information it 

obtains from states on the states’ collection and use of 911 fees and 

maintaining a “Text-to-911 Registry.”

 

56As noted in our report, the communications sector’s infrastructure is in the midst of a significant 

change, which FCC refers to as a series of technology transitions. In this report, we refer to this 

change as the IP transition.
While these actions are useful for FCC to oversee the IP transition, we 

continue to believe that FCC needs to develop a strategy to gather 

additional information on the potential effects of the IP transition. 

Especially with respect to the priority services that national security and 

emergency preparedness personnel rely on during times of crisis, by 

having a strategy to collect additional information on the IP transition, 

FCC could help ensure that such personnel can continue to make 

important calls during times of crisis. Furthermore, as AT&T noted, some 

residential customers have expressed concerns regarding 911 availability 

and compatibility with medical devices and other equipment in an IP 

environment. Developing a strategy to collect additional information on 

the transition’s effects could help FCC address these areas of 

uncertainty.

We are sending copies of this report to the Chairman of FCC, the 

Secretary of Homeland Security, and appropriate congressional 

committees. In addition, the report is available at no charge on GAO’s 

website at http://www.gao.gov. 

If you or members of your staff have any questions about this report, 

please contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. Major contributors to this report 

are listed in appendix III.

Mark L. Goldstein

Director, Physical Infrastructure Issues

Page 31 GAO-16-167 Internet Protocol Transition
Appendix I: Objectives, Scope, and 

Methodology

This report examines the reliability of the nation’s communications 

networks in an Internet Protocol (IP) environment. Specifically, we 

reviewed (1) the potential challenges affecting IP networks during times of 

crisis and how the challenges affect end users, and (2) the actions FCC, 

DHS, and other stakeholders have taken to ensure the reliability of IP 

communications during times of crisis.

To identify challenges affecting IP networks and how the challenges 

affect end users, we reviewed relevant documents from the Federal 

Communications Commission (FCC) and Department of Homeland 

Security (DHS) including orders, notices and proposed rulemakings, 

reports, and risk assessments, as well as relevant statutes and 

regulations. We reviewed comments filed with FCC regarding the IP 

transition and emergency communications. To ensure we reviewed a 

broad range of comments, we selected comments by stakeholders that 

represented a variety of interests, including public interest groups, 

industry and trade associations, and state and local authorities. We 

reviewed reports and best practices from federal advisory committees, 

trade associations, and consumer groups. We reviewed our prior 

recommendations, as well as those made by DHS, the Communications 

Security, Reliability, and Interoperability Council, and the National 

Security Telecommunications Advisory Committee related to priority 

telecommunications services. We also searched various Web-based 

databases to identify existing articles, peer-reviewed journals, trade and 

industry articles, government reports, and conference papers.

Page 32 GAO-16-167 Internet Protocol Transition

1 We 

identified articles from 2010 to 2015. We examined summary-level information 

about the literature identified in our search that we believed to be germane 

to our report. It is possible that we may not have identified all of the 

reports with findings relevant to our objective, and there may be other 

challenges affecting IP networks during times of crisis that we did not 

present.

To determine the actions taken by FCC, DHS, and other stakeholders to 

ensure the reliability of IP communications during times of crisis, we 

reviewed relevant FCC proceedings, reports, and documents. 

Specifically, we reviewed FCC proceedings related to technology 

transitions and ensuring consumer backup power for continuity of 

 

1

For example, databases we searched included ProQuest, Ei Compendex, Copper Technical 

Reference Library, SciSearch: A Cited Reference Science Database, and NTIS: National 

Technical Information Service. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

communications, reports on disruptions to communications reports on 

major disruptions to 911-related communications,

Page 33 GAO-16-167 Internet Protocol Transition

2

and documents related to 

outage-reporting information. To identify information on the proposed IP 

transition experiments, we reviewed AT&T and CenturyLink’s proposals, 

stakeholder comments submitted to FCC on these proposals, and other 

documents related to the experiments. We assessed FCC’s efforts to 

collect data on the effect of the IP transition against criteria established in 

the federal Standards for Internal Control.3 We reviewed relevant DHS 

documents including the 2013 National Infrastructure Protection Plan,

4

the 2010 

Communications Sector Specific Plan,

5

and the 2012 Risk Assessment Report 

for Communications.

6 We also reviewed reports and best practices from the 

Communications Security, Reliability, and Interoperability Council and the 

Alliance for Telecommunications Industry Solutions.

To obtain additional information on the challenges affecting IP networks 

and how these challenges affect end users, and to obtain information on 

state efforts to ensure reliability we selected locations in six states—New 

York, New Jersey, Arizona, California, Florida, and Alabama—to provide 

additional details. We selected these locations because they represent a 

mix of communities that experienced a major communications outage 

since 2012 or contain an area with a proposed IP transition experiment. 

These regions also contain a mix of rural, suburban, and urban 

communities, and demographics including economic differences and 

average age of residents. We reviewed documents such as reports, 

comments to FCC, and comments to state agencies. We interviewed 

officials from state Public Utility Commissions or similar agencies 

including the New York Department of Public Service, New Jersey Board 

of Public Utilities, California Public Utilities Commission, and Florida 

 

2

FCC, Impact of the June 2012 Derecho on Communications Networks and Services (January 

2013) and FCC, April 2014 Multistate 911 Outage: Cause and Impact (October 2014)

3GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

4DHS, National Infrastructure Protection Plan, Partnering for Critical Infrastructure Security and 

Resilience (Washington, D.C.: 2013).

5DHS, Communications Sector-Specific Plan: An Annex to the National Infrastructure Protection 

Plan (Washington, D.C.: 2010).

6DHS, Risk Assessment Report for Communications (Washington, D.C.: September 2012).
Appendix I: Objectives, Scope, and 

Methodology

Public Service Commission.

Page 34 GAO-16-167 Internet Protocol Transition

7 We interviewed representatives from other 

organizations that had experienced the effects of outages or were 

involved with the proposed IP transition experiments including the City of 

Flagstaff, the Arizona Telecommunications and Information Council, the 

Broadband Alliance of Mendocino County, and the Communications 

Workers of America. We interviewed officials from FCC and DHS and 

representatives from AT&T, Verizon, and CenturyLink. We also 

interviewed representatives from selected stakeholder groups including 

trade and industry associations and consumer and public interest groups, 

as shown in table 2. We identified stakeholders to interview based on our 

review of comments filed in FCC’s Technology Transitions proceeding, as 

well as based on recommendations from other organizations we 

interviewed.

Table 2: Additional Organizations Interviewed

Organization Representation

Trade and 

industry 

associations

Association of Public-Safety Communications 

Officials-International (APCO)

Represents public safety communications professionals. 

Competitive Communications Association 

(COMPTEL)

Represents competitive communications service providers 

and their supplier partners.

Independent Telephone and Telecommunications 

Alliance (ITTA)

Represents mid-size communications companies.

National Association of Regulatory Utility 

Commissioners (NARUC)

Represents state public service commissions that regulate 

utility services.

National Association of State Utility Consumer 

Advocates (NASUCA)

Represents the interests of utility consumers.

National Cable & Telecommunications Association Represents U.S. cable industry.

United States Telecom Association (USTelecom) Represents telecommunications service providers and 

suppliers, with members ranging from large publically traded 

communications corporations to small companies and 

cooperatives.

Consumer 

groups (or public 

interest groups)

Consumer Action Represents public interest of low- and moderate income, 

limited English-speaking and other underrepresented 

consumers.

New America Foundation Represents the public interest on a variety of issues, 

including technology and communications networks.

Public Knowledge Represents the public interest on a variety of issues 

including telecommunications and consumer rights.

 

7Officials from the Alabama Public Service Commission and the Arizona Corporation 

Commission did not respond to our requests for an interview.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-16-167 Internet Protocol Transition

Organization Representation

Other Communications Workers of America Represents communications workers, including 

telecommunications.

Source: GAO and organization information. | GAO-16-167
Appendix II: Comments from the Federal 

Communications Commission

Page 36 GAO-16-167 Internet Protocol Transition

Appendix II: Comments from the Federal 

Communications Commission
Appendix II: Comments from the Federal 

Communications Commission

Page 37 GAO-16-167 Internet Protocol Transition
Appendix II: Comments from the Federal 

Communications Commission

Page 38 GAO-16-167 Internet Protocol Transition
Appendix II: Comments from the Federal 

Communications Commission

Page 39 GAO-16-167 Internet Protocol Transition
Appendix II: Comments from the Federal 

Communications Commission

Page 40 GAO-16-167 Internet Protocol Transition
Appendix II: Comments from the Federal

Communications Commission

Page 41 GAO-16-167 Internet Protocol Transition
Appendix III: GAO Contact and Staff 

Acknowledgments

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov

In addition to the individual named above, Sally Moino (Assistant 

Director), Richard Calhoon, David Hooper, Michael Kaeser, Aaron 

Kaminsky, Malika Rice, Amy Rosewarne, and Andrew Stavisky made key 

contributions to this report.

Page 42 GAO-16-167 Internet Protocol Transition

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact 

Staff 

Acknowledgments
Appendix IV: Accessible Data

Page 43 GAO-16-167 Internet Protocol Transition

Federal Communications Commission

Washington, D.C. 20554

December 08, 2015

Mr. Mark L. Goldstein

Director, Physical Infrastructure Issues

Government Accountability Office

441 G Street NW

Washington, DC 20548

Dear Mr. Goldstein:

Thank you for the opportunity to review and comment on the Government 

Accountability Office's (GAO) draft report titled, Internet Protocol 

Transition - FCC Should Strengthen Its Data Collection Efforts to Assess 

the Transition's Effects ("Draft Report"). We agree with GAO that the 

Federal Communications Commission (FCC or Commission) has a critical 

role "in enhancing the cyber and physical security of the communications 

infrastructure that is essential to national security and public health and 

safety."1 Accordingly, the transition from legacy to modem IP-based 

 

1 Draft Report at 1.

Appendix IV: Accessible Data

Agency Comment 

Letter

Text of Appendix II: 

Comments from the 

Federal Communications 

Commission

Page 1
Appendix IV: Accessible Data

networks raises important questions for the Commission about how to 

provide network and service resiliency and reliability assurance to the 

nation; it is essential that the Commission has sufficient information to 

make informed decisions. The Commission has in place a comprehensive 

data strategy, using the Commission's currently available resources and 

information technology, to oversee the Nation's technology transitions 

based on our enduring values.

Page 44 GAO-16-167 Internet Protocol Transition

2 This strategy, however, could be 

strengthened through the provision of additional resources to leverage big 

data analytics capability. We agree with GAO's implicit recognition that 

optimal strategic management or oversight of the technology transition 

would involve robust data analytics ability.

The Commission Has a Strategy for Technology Transitions Oversight

GAO recommends that: "[t]o strengthen FCC's data collection efforts, the 

Chairman of FCC should develop a strategy to gather additional 

information on the IP transition to assess the transition's potential effects 

on public safety and consumers." The report notes the Commission's 

January 2014 Technology Transitions Order and other ongoing 

Commission efforts but concludes that the Commission has "little 

information on the effect of the transition."3 At the outset, in the Technology 

Transitions Order, the Commission identified our focus on "three key technology 

transitions that significantly affect

customers," changes that "are ongoing and will continue for years."4 The 

speculative horizon of these multiple transitions makes any attempt to quantify 

the effects difficult at best. This is unlike the DTV transition, for example, which 

involved one defined transition with a definitive endpoint. And unlike the DTV 

transition, which was statutorily-driven, the technology transitions are 

 

2 Technology Transitions et al., GN Docket No. 13-5 et al., Order, Report and Order and Further 

Notice of Proposed Rulemaking, Report and Order, Order and Further Notice of Proposed 

Rulemaking, Proposal for Ongoing Data Initiative, 29 FCC Red 1433, 1441, para. 23 

(2014) (noting the importance that "four enduring values that have always informed 

communications law -public safety, universal service, competition, and consumer 

protection" - endure throughout this transition.") (Technology Transitions Order).

3 Draft Report at 26

4 Technology Transitions Order, 29 FCC Red at 1440, para. 16.

Page 2
Appendix IV: Accessible Data

"market-driven"

Page 45 GAO-16-167 Internet Protocol Transition

5

and "organic processes without a single starting or stopping 

point."6

Today, the Commission uses data and information provided by carriers to 

monitor and ameliorate any potential negative effects of the transition. All of 

our efforts with respect to technology transitions are underpinned by work 

the Commission does on a daily basis in evaluating and processing 

network change disclosures filed pursuant to section 251(c)(5) of the 

Communications Act of 1934, as amended (the Act), and discontinuance 

applications filed pursuant to section 214 of the Act. Through these 

mechanisms, the Commission ensures that carriers comply with the 

statute and our rules, including consumer notification and protection 

requirements, in implementing their network and service transitions.

Indeed, the Commission recently strengthened its rules implementing 

sections 214 and 251(c)(5), including by enhancing our network change 

notification process for retirements of copper facilities to ensure that 

competitive carriers and retail customers receive sufficient time and 

information to accommodate network transitions and make informed 

decisions regarding their ongoing service.7 The Commission also provided 

clear direction to industry concerning the circumstances in which approval 

must be sought before removing a service from the marketplace. The 

Commission will continue to develop additional data requirements if and 

when necessary to enhance these roles.

Also, the Commission is continuing to evaluate information supplied on 

the record in the proceedings that produced the Emerging Wireline 

Report and Order. This material, highly germane to the technology 

transitions, was extensive and informative. For example, we have sought 

and received substantial input on our proposal to establish specific criteria 

for the Commission to use in evaluating the adequacy of modem 

replacements for legacy services in section 214 discontinuance 

proceedings. Among other things, these proposed standards would take 

account of a carrier's consumer education and outreach plan in 

 

5

Id. at 1435, para. 1.

6 Technology Transitions et al., GN Docket No. 13-5 et al., Report and Order, Order on 

Reconsideration, and Further Notice of Proposed Rulemaking, 30 FCC Red 9372, 9374, 

para. 3 (2015) (Emerging Wireline Report and Order).

7

Id. at 9375, para. 5.
Appendix IV: Accessible Data

determining whether to allow removal of a legacy service from the 

marketplace. These criteria could serve to provide certainty to both 

carriers and consumers and to ensure that critical functionalities are not 

lost during the transitions. This work is bolstered by the data that the 

Commission recently received as part of the comprehensive special 

access data collection and evaluation, which "will enable us to address 

critical long-term questions about the state of competition for business 

data connections," an essential element in the technology transitions.

Page 46 GAO-16-167 Internet Protocol Transition

8

In 

short, while carriers' voluntary experiments can provide useful data - and, for 

example, the Commission continues to work closely with AT&T on its 

proposed experiments, to ensure that if AT&T proceeds and the 

Commission grants approval, useful data is produced - experiments are 

by no means the sole mean by which the Commission is overseeing 

technology transitions to ensure the protection of consumers throughout 

the process.

Targeted Data Collections are Enabling Public Safety in a Transitioning 

Environment

The purpose of the GAO Report is to address "the reliability of the 

nation's communications network in an IP environment during times of 

crises...."

9 Although the Draft Report focuses on information collected through 

the Commission's service-based experiments, the Commission has modified 

several of its information collection initiatives to provide data on the reliability 

and resiliency of IP-based networks nationwide. 10

As described in the Draft Report, the Commission's Network Outage Reporting 

System (NORS) collects detailed information about major disruptions to voice 

communications on both TDM and IP- based networks. 11The NORS 

 

8

Id. at 9377, para. 6.

9 Draft Report at 2.

10 In addition to its own technology transitions data collection efforts, the Commission also 

presented to Congress a plan proposing "potential steps for Congress to take to create a legal and 

regulatory environment that will assist states, PSAPs, service providers and other stakeholders 

in accelerating the nationwide transition from legacy 911 to NG91 l." Federal 

Communications Commission, Legal and Regulatory Framework for Next Generation 911 

Services, Report to Congress and Recommendations at§ 2 (2013),

https://apps.fcc.gov/edocs public/attachmatch/DOC-319165A 1.pdf

11 Draft Report at 17.

Page 3
Appendix IV: Accessible Data

disruption report data allow the Commission to analyze the reliability of 

communications infrastructure, and facilitate development of communications 

industry best practices that have enhanced network resiliency and reliability.

Page 47 GAO-16-167 Internet Protocol Transition

12

Among other continuing developments related to NORS, and in recognition of 

the critical role undersea cable plays in the nation's global IP-based connectivity 

and key economic and national security communications, the Commission 

recently issued a Notice of Proposed Rulemaking to ensure that undersea 

cable outage data is reported by cable licensees in NORS. This data, 

would provide further network health assurance in the technology 

transitions and beyond.13 These NORS proceedings are ongoing, and reflect 

the FCC's consideration of the need to extend its network assurance data 

collection efforts to the IP environment under an appropriate framework.

The GAO Report also observes that the FCC gathers information on the 

reliability and resiliency of the nation's 911 networks through an annual 

ce11ification process adopted in 2013.14 The first such certifications were 

filed in October 2015 and have provided the FCC with a wealth of information

 

12 While the foundations of NORS were laid before the current technology transitions, the FCC in 

2012 responded to the increasing popularity of interconnected voice over Internet Protocol 

(VoIP) services by requiring interconnected VoIP providers to report major service 

disruptions, including disruptions in 911 service. The Proposed Extension of Part 4 of the 

Commission's Rules Regarding Outage Reporting to Interconnected Voice Over Internet 

Protocol Service Providers and Broadband Internet Service Providers, Report and Order, 

27 FCC Red 2650 (2012) (VoIP Part 4 Order). In the same proceeding the Commission 

established a record on broadband network disruption reporting though it has deferred 

action on that topic. Id. at 2651, para. 1. Congress also assigned the Commission a role in 

promoting IP-911 services. See New and Emerging Technologies 911 Improvement Act of 

2008 (NET 911 Improvement Act), PL 110-283, 122 Stat 2620 (2008), The Commission 

specifically required interconnected VoIP providers to file plans detailing their compliance 

with E91 l obligations. 47C.F.R. § 9.5(f).

13 See generally VoIP Part 4 Order, 27 FCC Red 2650; Improving Outage Reporting for Submarine

Cables and Enhancing Submarine Cable Outage Data, Notice of Proposed Rulemaking, 

30 FCC Red 10492 (2015).

14 See Reliability and Continuity of Communications Networks, Including Broadband 

Technologies, Report and Order, 28 FCC Red 17476 (2013).
Appendix IV: Accessible Data

regarding the network architectures, backup power strategies,

Page 48 GAO-16-167 Internet Protocol Transition

15 and network 

monitoring capabilities employed by hundreds of 911 service providers 

nationwide, representing both urban and rural service areas. Furthermore, the 

FCC requested comment in 2014 on additional proposals to improve 911 

governance and accountability, including a proposal to include topics such 

as software and database testing and maintenance as part of the 911 

reliability certification.16 Irrespective of any 911 reliability challenges revealed 

through the service-based experiments, this annual certification process 

provides the FCC with comprehensive information about the reliability of 

the nation's 911 networks throughout the technology transitions.

The Commission is also acting to collect technology transitions data in 

other communications segments that collectively provide the Commission 

with a greater understanding of the effect of the on public safety. Last 

year, the Commission revised its questionnaire for the annual 911 Fee 

Report, regarding the collection and use of state 911 fees, in order to get 

better information about how states are investing in Next Generation 

911.17 This year's report will be the first time the Commission will analyze this 

data.18 In the broadcast segment, the Commission updated the Emergency Alert 

System (EAS) test system to create the Emergency Test Reporting System 

(ETRS) database, recognizing that"[o]ur rules governing these alerts must 

continue to evolve as legacy networks and services transition to next 

generation technologies." 19This data source will serve as a "practical, 

 

15 15 Indeed, the backup power info1mation gathered by the FCC over time has led to 

the development and adoption of specific rules requiring service providers to make 

available to their customers certain backup power solutions, and to inform them of those 

options at points of sale. See Ensuring Continuity of91I Communications, Report and 

Order, 30 FCC Red 8677(2015). This was driven entirely by the technology transitions 

awareness gap experienced by consumers in going from traditionally line-powered 

services to non-line powered services. This is a key example of the way in which the FCC 

has gathered information on technology transitions and addressed specific consumer 

needs to ensure continued connectivity and access to public safety services.

16 See 911 Governance and Accountability; Improving 911 Reliability, Policy Statement and 

Notice of Proposed Rulemaking, 29 FCC Red 14208 (2014).

17 Pursuant to the New and Emerging Technologies 911 Improvement Act, Pub. L. 110-283 

(2008).

18 The report will be out on or before Dec. 31, 2015. The Commission's prior Fee Reports are 

available at https://www.fcc.gov/encyclopedia/9 l lFeeReports.

Page 4
Appendix IV: Accessible Data

accessible, and minimally burdensome tool for recording EAS 

dissemination data and developing an FCC Mapbook that can illustrate 

the manner in which an EAS ale1i is propagated throughout part or all of 

the United States."

Page 49 GAO-16-167 Internet Protocol Transition

20

In the wireless context, the ability to send a text message to 911 in an 

emergency situation is an obvious benefit of the technology transitions. 

To support this evolution, and apprise itself of the readiness of the 

nation's ability to utilize text-to-911 technology, the Commission maintains 

a Text-to- 911 Registry that provides notice of which Public Safety 

Answering Points (PSAPs) support the text-to- 911 function.21 Wireless 

technology transitions have also enabled better location accuracy for first 

responders. This year the Commission issued new standards for wireless 

location accuracy and is requiring wireless service providers to report on 

their plans and progress, including the development of

the National Emergency Address Database that will provide for better 

indoor location accuracy.22 Additionally, when the Commission made new 

spectrum available for Citizens Broadband Radio Service this year, it did so with 

the requirement that the Spectrum Access System Administrators must take 

network security into account and provide the security models to the 

Commission for review.23

The Commission has also taken other new approaches to leverage data as 

technologies evolve and better understand the effects of the technology 

transitions on public safety. Recognizing the need to respond to dynamic 

changes in the IP environment, the FCC has actively engaged with the 

private sector and other relevant stakeholders through mechanisms such 

 

19 Review of the Emergency Alert System, Sixth Report and Order, 30 FCC Red 6520, 6521, para. 

1 (2015).

20 Id. at 6521, para 2.

21 See Public Safety and Homeland Security Bureau Announces Update to PSAP Text-to911 Readiness and Certification Registry, PS Docket Nos. 10-255, 11-153, Public Notice, 

30 FCC Red 8196 (PSHSB 2015). The Commission has streamlined this data process so 

that the Registry of PSAPs capable of receiving Text-to-911 is continuously updated and 

available via an online database. Id.

22 Wireless E911 Location Accuracy Requirements, Fourth Report and Order, 30 FCC Red 1259, 

1257, para. 37 (2015).

23 Amendment of the Commission's Rules with Regard to Commercial Operations in the 

3550-3650 MHz Band, Report and Order and Second Further Notice of Proposed 

Rulemaking, 30 FCC Red 3959, 4061, para. 346 (2015).

Page 5
Appendix IV: Accessible Data

as federal advisory committees, including the Communications Security, 

Reliability, and Interoperability Council (CSRIC) and the Technological 

Advisory Council (TAC), to better understand the dynamic of the 

technology transformations.

The Draft Report states that "CSRIC has not specifically looked at ways 

to improve reliability of IP-networks."

Page 50 GAO-16-167 Internet Protocol Transition

24 I note that CSRIC has been 

studying IP resiliency issues for years. For example, CSRIC II, which was 

chartered from 2009-2011, made recommendations on cybersecurity best 

practices and best practices related to E911 for VoIP services, 

investigated the transition to an "all-IP NG 911," made recommendations 

for national security/emergency preparedness priority services in an all-IP 

environment, and made recommendations on ISP network protection. 

25The Commission received recommendations from CSRIC IV earlier this year 

on how it can assure that communications sector entities are 

implementing adequate cyber risk management processes;26 the 

Commission is in the process now of evaluating and implementing these 

recommendations. The Commission has also charged CSRIC with understanding 

the barriers to cyber threat information sharing among providers in order 

to better secure IP-based communications services.27 The Commission's 

Technical Advisory Committee has been tasked with developing an 

understanding of the cybersecurity vulnerabilities that accompany increased 

smart phone usage, a key method of consumer and public safety 

communications.28 Finally, the Commission

 

24 Draft Report at 18.

25 See FCC Encyclopedia, Communications Security, Reliability and Interoperability Council II, 

Working Groups, https://www.fcc.gov/pshs/advisory/csric/wg-descriptions.pdf (last visited 

Nov. 20, 2015).

26 CSRIC IV, Working Group 4 Final Report, Cybersecurity Risk Management and Best Practices 

at 1 (Mar. 2015), https://transition.fcc.gov/pshs/advisory/csric4/CSRIC IV WG4 Final Report 

031815.pdf (last visited Nov. 18, 2015)

27 See CSRIC V Working Group Descriptions and Leadership at 4-5 (charge to Working Group 5) 

https://transition.fcc.gov/bureaus/pshs/advisory/csric5/Working GroupCSRICV 110515.pdf (last 

visited Nov. 18, 2015).

28 See FCC Technological Advisory Council, 2012, Wireless Security & Privacy Working Group 

presentation (Oct. 31, 2012). See also FCC Technological Advisory Council, 2013, Cloud Security 

Recommendations (Dec. 9, 2013); FCC Technological Advisory Council, 2014, 

Recommendations on Supporting the Transition to IP, Recommendations for Mobile 

Device Security and Privacy and Recommendations for Evolution to Internet of Things 

(Dec. 4, 2014).
Appendix IV: Accessible Data

has begun analyzing network security plans in the context of mergers and 

acquisitions in order to protect against security gaps and to ensure network 

resiliency moving forward.

Page 51 GAO-16-167 Internet Protocol Transition

29

Additional Resources are Needed to Evolve Data Analysis

As described above, the Commission has executed on numerous aspects of its 

strategy to collect the data necessary to ensure the core values of 

communications remain intact throughout the technology transitions. 

While the data collected offer significant insights into the technology 

transitions, additional resources would give the Commission the desired 

holistic data view needed, and thus further the Commission's mission. As 

Chairman Wheeler recently testified before Congress, the Commission 

currently lacks the ability to translate its numerous data collection 

programs into the type of system that would allow for "big data" analytics 

of the operational status of our nation's networks.30

Conclusion

Thank you for the opportunity to respond to the Draft Report. The technology 

transitions offer a unique opportunity to advance communications services in a 

manner that maximizes value to the public while minimizing, to the extent 

feasible, risk to the nation's consumers and businesses. We agree with 

GAO about the importance of ensuring an informed, data-driven process 

for determining which services can be seamlessly supported during the 

transition, which services will need to be transformed, and which services 

will no longer be supported in an IP world, while preserving the core 

functions of public safety, universal service, competition, and consumer 

protection. The Commission's strategy for doing so combines traditional 

regulatory approaches with innovative methods that match the dynamism 

of the communications environment, and we are committed to making 

sure that this strategy is informed by adequate data through our rules, 

policies, and regular outreach to affected communications industry 

 

29 29 See, e.g., Letter from William T. Lake, Chief, Media Bureau, to Catherine Bohigian, 

Executive Vice President, Gov't Affairs, Charter Communications, Inc., at Enclosure, 22 

(Sept. 21, 2015) https://apps.fcc.gov/edocs public/attachmatch/DOC-335394A2.pdf.

30 FCC Oversight: Hearing Before the Subcomm. on Commc'n and Tech. of the H. Comm. 

Energy and Com., l 141 Cong. (Nov. 17, 2015) (testimony of FCC Chmn. Tom Wheeler).

Page 6
Appendix IV: Accessible Data

sectors. The Commission looks forward to working with GAO towards this 

critical mission.

Sincerely,

David Simpson

Rear Admiral (ret), USN

Chief, Public Safety and Homeland Security Bureau

Page 52 GAO-16-167 Internet Protocol Transition
Related GAO Products

Federal Information Security: Agencies Need to Correct Weaknesses and 

Fully Implement Security Programs. GAO-15-714. September 29, 2015.

Cybersecurity: Recent Data Breaches Illustrate Need for Strong Controls 

across Federal Agencies. GAO-15-725T. June 24, 2015.

Cybersecurity: Actions Needed to Address Challenges Facing Federal 

Systems. GAO-15-573T. April 22, 2015.

Information Security: IRS Needs to Continue Improving Controls over 

Financial and Taxpayer Data. GAO-15-337. March 19, 2015.

Information Security: FAA Needs to Address Weaknesses in Air Traffic 

Control Systems. GAO-15-221. January 29, 2015.

Information Security: Additional Actions Needed to Address 

Vulnerabilities That Put VA Data at Risk. GAO-15-220T. November 18, 

2014.

Information Security: VA Needs to Address Identified Vulnerabilities. 

GAO-15-117. November 13, 2014.

Federal Facility Cybersecurity: DHS and GSA Should Address Cyber Risk 

to Building and Access Control Systems. GAO-15-6. December 12, 2014.

Page 53 GAO-16-167 Internet Protocol Transition

Related GAO Products

(543353)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. 

Listen to our Podcasts and read The Watchblog.

Visit GAO on the web at www.gao.gov.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

PleasrintoRecyldPapr.