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Underscoring the importance of equitable and resilient communications systems, �鶹������ý’s Resilient Communities program has provided public comments in two recent federal proceedings.

Broadband Requirements for Publicly-Funded Housing

Responding to the Department of Housing and Urban Development (HUD)’s request for public comment in its proceeding on Narrowing the Digital Divide Through Installation of Broadband Infrastructure in HUD-Funded New Construction and Substantial Rehabilitation of Multifamily Rental Housing, Resilient Communities (RC) signed onto the , which emphasized broad applicability of the broadband requirement as well as open-access and future-proofed design. While RC supports the intention to require broadband installation in HUD-funded new construction and major rehabilitations, we see this as an opportunity to build improved resilient and equitable communications systems that last well into the future.

To that end, RC submitted separate comments with detailed recommendations for open-access and future-ready design specifications. Our recommendations include provisions to require that broadband infrastructure is open to multiple vendors, enabling consumer choice; that it is useable for innovative community technology amenities providing broad access to digital opportunity and resources; and that it is adaptable for changes in technology, bringing down the cost of future retrofitting. We believe that publicly funded communications infrastructure should be adaptable as technologies and data needs change. By contrast, with standard telecommunications installation models, future upgrades to fiber will require ripping out existing cables and completely rewiring buildings.

For example, in new construction, open access infrastructure should be installed between the building demarcation room, and individual units, apartments, or floors. This should be extended to multi-dwelling units (MDUs), so sharing of communications resources can occur on a larger scale. This would allow a number of residents in a building or MDU to benefit from economies of scale and obtain broadband resources from a variety of vendors. Additionally:

• Individual units should be wired for high-speed data access at communications outlets.

• Site-wide expansion and flexibility can be ensured by using conduit instead of simple buried wiring between buildings for distribution of service provider cabling.

• Conduit or raceway should run from each building’s communications room to each unit’s central phone, TV and data wiring panel.

• Fiber optics and Category 6 (CAT6) cable should be used instead of Category 5 Enhanced (CAT5e) normally used in standard telecommunications installations.

Making these guidelines standard practice can help bridge digital inequities among public and affordable housing developments. The long-term savings and the inherent opportunities make such a capital investment a very cost-effective way to create a major improvement.

Preparing Communications Networks for Storms and Outages

RC’s comments submitted May 31st, 2016 in the Federal Communications Commission (FCC)’s Proceeding on Network Resilience argue that a “Cooperative Framework” among commercial telecom carriers — as proposed by by AT&T, Sprint, T­Mobile, US Cellular, and Verizon, together with CTIA (The Wireless Association) in its April 27, 2016 ex parte letter to the Commission — is not sufficient for ensuring that local communities hit by storms or other emergencies have access to critical information.

We do not believe that voluntary steps taken by industry to shore up network resilience should obviate the need for legislative action – in particular, enforceable data-­sharing standards. A cooperative agreement forged solely among industry representatives leaves out leadership by those most informed about local needs and experiences: local groups on the front lines in flood zones, as well as emergency response personnel and government officials.

Furthermore, we are concerned that participation and compliance with CTIA et al’s proposed “Framework” is voluntary,­­ meaning that if a carrier prefers to withdraw or not comply with parts of it, there are no consequences. Those saving lives on the front lines must have access to vital information about network health to target aid and develop contingency plans.

We support instead the following enforceable standards:

• Telecom carriers should provide local authorities as near as possible to real­-time access to specific wireless outages that have occurred in their areas during disasters and up to date status on their restoration efforts, to focus searches on areas where outages preclude residents and others from otherwise contacting first responders.

• For this information to be most effective, we recommend sharing data at the Census Tract or Block Group level, which will enable targeted response for those most affected by future disasters.

• Further, we recommend that carriers be required to provide consumers with real-time access during emergencies to provider-specific outage information, with estimated restoration times, to better enable consumers to pursue alternatives, workarounds and relocation efforts.

• Finally, we recommend that carriers be required to provide localities specific information regarding proposed temporary infrastructure deployment measures and operational status of such temporary installations so that localities can facilitate transportation and permitting and better gauge disaster area communications coverage.

In short, we propose that the most effective aid is a different kind of mutual aid from that named in CTIA’s letter: neighbors helping neighbors with the support of government and broader response resources. We hope that with this goal in mind, the Commission will take steps to provide response officials and residents with the information they need to help themselves and each other at times of critical need.