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Friday, October 7, 2022

PERSPECTIVE: The Risk of Battle-Testing Critical Communications Infrastructure Transition

We all have numbers that we’re connected to in life, but if there is any set of digits that people have allegiance to it is their phone number. That personalized link, like the device it is attached to, is something upon which we have all become very dependent for work, play, personal life, fraud prevention (via one-time passcodes) and especially emergencies.

Nowhere is that more obvious than when a natural disaster or some other catastrophic event occurs. If we’re in that location, there is little to no way of letting our families or even emergency authorities know where we are, what help we may need, or what direction we can offer to render to aid to others who may need more urgent attention. And if we’re fortunate to live outside of an affected location, our ability to reach loved ones or direct assistance in disaster areas is seriously compromised.

Despite the fact our communications are more mobile and versatile than they have ever been, the networks that they built upon are not invincible. Look at any major or regional disaster over the past 70 years and you will find communications failures (e.g. downed lines or towers, destroyed switching stations, trunking failures, etc.) as one of the most costly and challenging issues facing emergency response and post-emergency recovery. Post-Hurricane Maria, Puerto Rico is still experiencing this challenge today nearly half a year since the epic storm crashed into the island.

Beginning April 8, routing for America’s communications networks will be transitioning to a new system. In 1996, the FCC established rules to enable a customer to keep the same telephone number even when the customer switches service providers. At the same time, the FCC directed the establishment of a Number Portability Administration Center (NPAC) to manage the porting of phone numbers between carriers. Next month, the 2,000-plus carriers that provide phone services in the United States will start transitioning from the current legacy system run by Neustar to a new system built by iconectiv, a subsidiary of Swedish phone company Ericsson.

The ability to port telephone numbers has become an integral part of our lives as, on average, more than 100,000 telephone numbers are ported each day. But NPAC’s role is bigger than porting numbers: the core NPAC database is updated about 1.8 million times a day. Beyond porting, the database also accounts for new telephone numbers injected into inventory on any given day, switch upgrades, regular maintenance, carrier-related merger and acquisition activities and emergency preparation/recovery, i.e. migrating traffic in anticipation of or reaction to major but localized network disruption. It’s arguably the most important piece of critical infrastructure no one’s ever heard of. Done under the auspices of the FCC, “[The NPAC] is a national resource that provides critical inputs to communications services, public safety, and law enforcement.”

As much as the vision for this transition is about securing the integrity of communications and providing for improved cost savings to communications carriers, it is far from clear that the NPAC transition effort is itself resilient enough to handle one of America’s “bad days.”

As recent history has shown us, the shape and form of those “bad days” can take any number of forms. It can be a switching station in lower Manhattan destroyed when two planes and multiple buildings come down upon it, all-consuming fires sweeping across hills in the southwest that destroy cellular towers, or saturating waters and violent winds that wipe out any and all structures in its path along any coastline or inland area in America.

As easily as any of these examples could be part of the plot line of a Hollywood blockbuster, they are all very real examples of recent “bad day” history in America over the past 20 years. Each was epic, memorable and costly (in lives and dollars). And when a switching center is rendered inoperable by a disaster, the NPAC uses number portability to reroute calls through a working switch. This allows individuals to continue making and receiving calls – so long as their phone works and they are able to get a working cell phone signal. In the five days after Hurricane Maria in Puerto Rico, the NPAC helped to ‘port’ more than 660,000 telephone numbers typically routed through switches in Puerto Rico to mainland switches,enabling individuals in an area with service to connect with friends and family on and off the island. On Sept., 11, 2001, the NPAC used this routing procedure for the first time to restore service to more than 60,000 phone numbers after a switch was destroyed when the World Trade Center towers were destroyed. Because of redundant systems and extraordinary contingency measures, those numbers were rerouted to switches in Connecticut and New Jersey, ensuring individuals could contact friends and family following the attack.

With this incredible infrastructure and technology transition literally just weeks away, and Hurricane Season 2018 beginning June 1, it is paramount that this new communications system not only operates as intended but has a robust and vetted contingency plan in case it does not. There is too much riding on our communications infrastructure to have anything less than success, and this is where the government’s track record should give us pause.

Three weeks before the disastrous rollout of Healthcare.gov in October 2013, the vendor building the system testified that the new system “has achieved all of its key milestones from the initial Architecture Review … to Project Baseline Review      … and, most recently, the Operational Readiness Review” and that it was “confident that it will deliver the functionality that [the U.S. Department of Health & Human Services] has directed to enable qualified individuals to begin enrolling in coverage when the initial enrollment period begins on October.” Moreover, anyone involved in homeland security technology programs over the last decade needs no reminder of failed technology programs ranging from FBI case management to the SBInet border security program. We should learn from these mistakes so we don’t repeat them.

The new NPAC system is set to go live in less than 30 days with transitions occurring on a region-by-region basis. The first region to move into this new system is the American Southeast, which includes North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi, Louisiana, Tennessee, Kentucky … and Puerto Rico. If the names of these locations don’t give you enough pause, it would be timely to remember where most of the hurricanes end up taking disastrous residence when they finally come ashore. (Hint – these locations have hurricane visitors on a regular basis.)

That is reason enough why this transition should be on the radar screens of state emergency managers who require and are dependent upon reliable communications to respond and begin recovery for any disaster situation.

The large carriers are telling the FCC that extensive testing has occurred, and are downplaying the importance of a contingency plan, with AT&T calling the chances of a catastrophic transition “exceptionally low.” Others are pushing back.  The Cloud Communications Alliance calls the “lack of a workable, tested contingency rollback plan … an unacceptable risk” and warns that existing proposals do not accommodate the needs of smaller telecommunications service providers.

For all of the truly remarkable technical achievements the communications industry has brought to our lives, durability and reliability remain a fundamental concern in the most pressing of conditions. Read any after-action report from any local, regional or national disaster over the past 70 years and every one one of them will cite communications failures and lack of resiliency as a systemic, if not recurring, problem.

Given the potential impact of an error-prone NPAC, the lack of contingency planning or information on NPAC’s ability to port numbers in disasters, this transition does not build a lot of confidence as this new system takes over – just as Hurricane Season 2018 begins. We have too many things riding on our communications infrastructure to simply hope that this transition will be effective, flawless or durable in the most demanding of conditions. Every piece of America’s supply chain operations, national security, economic security, healthcare networks, emergency networks, media, personal networks and more are all riding on this transition.

Which is why emergency managers and homeland security officials should be asking some fundamental questions:

  • What can the FCC and our carriers tell us about the level of independent testing done to make sure this new communications system works?
  • What is the contingency plan if it doesn’t work?
  • What assurances can you provide that the same communications services we’ve always depended on in disasters will not be adversely impacted by the transition?

Like any taxpayer, I want to believe my government is making smart decisions and is exerting even stronger oversight to ensure this system is going to perform flawlessly and will be able to take any punch thrown at it. But like the passengers getting on board the Titanic who were told their ship was unsinkable, I’d rather have more transparency and testing of this new communications approach and network before any of us step on board for a national cruise.

There are far too many icebergs out there in this dynamic risk-filled world waiting to strike us, and the worst feeling in the world is crying for help and not being able to get that message out or heard.

That’s an approach none of us can afford with the NPAC transition.

Rich Cooper
Rich Cooper is Editor-at-Large for HSToday. A former senior member of DHS’ Private Sector Office (PSO), Cooper has been a frequent writer and contributor to numerous media outlets. He is Vice President for Strategic Communications & Outreach for the Space Foundation and a Principal with Catalyst Partners, LLC. Cooper is also a former Senior Fellow with GWU’s Cyber and Homeland Security Institute and has also served in senior positions at NASA, the US Chamber of Commerce Foundation, SAS and several other profit and not-for-profit enterprises.

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