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I sent this letter to the FCC about interstate cable breaks disrupting local Alaska phone service. It's tilting at windmills, but it's now on the record. This time local services failed April 29 and weren't fully restored until May 14.

¶0 Walter Gregg; PO Box 21693; Juneau, Alaska 99802; [Snipped home phone] May 9, 2021

Enforcement Division
Federal Communications Commission
45 L Street NE
Washington, DC 20554
via Fax: 1-866-418-0232

Long distance submarine cable cut: Local EBS, NOAA, 911, police business phones interrupted

Dear Readers:

¶1 Please consider taking action without delay to prevent yet another 1-2 week interruption to part of the Alaska emergency broadcast system; and hours of interruption to NOAA weather radio; the local police business lines; and even 911. On April 29 at about 1:00 PM, a long distance submarine cable break took down all these services (Dowd 2021). At 3:44 PM, KINY reported that the police 911 and business lines were still down (KINY 2021). It's not known to me if calls to the business lines of the fire departments were also interrupted. But phones did go down at these local schools: Auke Bay Elementary; Mendenhall River Community; Riverbend Elementary; Sayeik; Gastineau Community; Floyd Dryden Middle; and Dzaintik'i Heeni Middle School (Lockett 2021). All this was the result of a nonlocal submarine fiber optic cable break (Alaska Communications 2021a).

¶2 The Emergency Broadcast System has now been partially down for nine (9) days. The ACS rerouted traffic from the broken cable to the one they have left. It doesn't have sufficient bandwidth. As a result, the EBS can't currently reliably send alerts through the local on-air TV networks PBS (3.1), Create (3.2), Kids (3.4), ABC (8.1), theCW (8.2), or Fox (8.3). Initially, the stations would work in the morning, but from 5 PM to midnight, as Juneauites make extensive use of the web, they would either go blocky or off-air entirely. Currently, except for 3.4, they're off the air entirely. The cable company, GCI, started streaming the Anchorage broadcasts over their separate facilities to restore service to their viewers. But there are fewer and fewer cable viewers, and for some reason, that alternative feed is not available as a live fallback for over-air broadcasting. It isn't as if NOAA weather radio can be counted on either. For the first few hours, NOAA communications were down too.

¶3 This is not the first time that a long distance submarine cable break has disrupted emergency communications within Alaska. For example, in December 2019 Anchorage cell phones could not reach 311, 911, or the Anchorage police non-emergency line (786-8900) for several hours. The cause was a cable break in Washington State over 1,000 miles away (Wieber 2019).

¶4 The continuity of local emergency communications should not depend on highly vulnerable long distance submarine cables. Everyone knows that VoIP by Internet can and will fail from time to time. But even the Alaska Telecom Association just assumes that when 911 fails our backup cell and local lines can reach emergency responder business lines (Hughes 2019).

¶5 The ACS knew in advance that 911 would be interrupted when this happened, and instead of arranging automatic backup, they disclaimed warranty and limited liability to $1.00. The ACS became exempt from Alaska regulation effective November 27, 2019. As a result, they changed terms of service. Warranty? Alaska Communications makes no warranty that telephone calls or other transmissions will be correctly routed or completed without error or interruption (including calls to 911). Damages? Alaska Communications' total libaility liability for any and all damages, regardless of the form of the action, shall be limited and capped in their entirety to the greater of one dollar (us $1.00) or the monthly fees Alaska Communications charged you during the one month prior... (Alaska Communications 2019).

¶6 It's reasonable to wonder if the FCC should ban dependency on long distance submarine cables for reaching the listed business numbers of last resort for first responders. This might mean banning phone companies from providing ported numbers for first responder business lines. After the aforementioned 911/Dec 2019 Anchorage outage, an Alaska Communications spokesperson specifically noted that a live interstate connection is required to complete calls to 311, 911, 800 number calling, and ported numbers (Clark 2019). It's just possible that the JPD 907-586-0600 number might be 'ported'. When they moved to the 907-780 Lemon Creek exchange area, they kept their old 907-586 downtown business number. It's also possible they might have switched from ACS to GCI to save money. That would also be a port. If that's the that's the reason for the outage, it's a pretty huge vulnerability and has nationwide implications. Phone companies should at least have to notify ported customers that those numbers can't even receive local calls when long distance lines fail -- and that they will indeed fail from time to time.

¶7 ACS has not been forthcoming about what's wrong. There's nothing on their website about it at all. They do have a feed at twitter.com/AlaskaComm. On April 29 at 3:02 PM, they acknowledged the outage (it started at 1:00 PM). On April 30 at 3:20 AM they indicated that they had finished rerouting traffic and that service might be slow during busy times of the day (Alaska Communications 2021a). There is no further data until May 5 at 8:47 PM, indicating that 'The ship has arrived' (Alaska Communications 2021b). It's now May 9 at 6:30 PM and there's been no further update. This could be a case study in business school about how not to deal with a crisis.

¶8 Please look into this matter and see if steps can be taken to harden our local emergency communications. Submarine cable breaks are hardly rare. When the plan is to just let it kill local services pending manual restoration, and use terms of service to disavow any responsibility, it's time for government regulators to step up to the plate. The old phone system was engineered for a failure rate near zero. The VoIP system with local number portability was created to be cheap. You get what you pay for. It's time to move the pendulum back toward absolute reliability. Thank you.



Walter Gregg

PS: Fair disclosure: I now use a Google Voice VoIP number pending firing ACS. Still, Jack Benny was clearly wrong when he said free can never hurt.


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