CTIA has submitted an ex parte filing with the FCC that urges the commission to defer a Notice of Proposed Rulemaking (NPRM) for a system that would create new reporting and public disclosure requirements for wireless providers concerning the reliability of their networks during and after natural disasters.

In the event that the Bureau of Public Safety and Homeland Security petitions the FCC for an NPRM on the matter, CTIA is asking that the commission instead seek additional comment in a notice of pubilc inquiry and evaluate the merits of any relevant metrics on this subject through a more collaborative forum.

CTIA, which met recently with the four major U.S. wireless carriers on the matter, said it is concerned that the proposed rules under consideration are similar to recommendations submitted to the FCC earlier this year by Consumers Union (CU). Those rules suggest that carriers report, and the Commission publicly disclose, the percentage of cell sites out of service in a particular county during an event classified as a disaster by the FCC. 

CTIA argues that CU’s proposed metric does not provide an accurate picture of a network's true condition and such information would not be of value to consumers.    

"As many providers’ cell sites are configured with overlapping coverage, the proposed metric risks overstating the degree to which cell site outages adversely affect service availability," CTIA wrote in the filing. "Ongoing and future deployments of “small cell” and Distributed Antenna System configurations that underlay existing coverage would exacerbate that risk even further."