Dear Chairman Pai,
We write today to request that you solicit feedback and include recommendations on wildfire related threats in the Wireless Network Resiliency Cooperative Framework (Framework). While the Framework has provided useful guidance on preparing for and responding to many emergencies, it lacks targeted recommendations for wildfires. This is a substantial shortcoming of the Framework that must be addressed immediately.
On April 1, 2019, the Federal Communications Commission's (FCC) Public Safety and Homeland Security Bureau (Bureau) released a public notice seeking comment on the implementation and effectiveness of the Framework. Specifically, this solicitation noted:
"On November 5, 2018, the Public Safety and Homeland Security Bureau issued letters (collectively, the PSHSB Letters) to each of the signatories of the Framework (Signatory, or collectively, Signatories), asking them to provide post-disaster action reports for the 2017 and 2018 hurricane seasons as part of the Commission's comprehensive investigation of the Framework."
The 2017 and 2018 hurricane seasons were devastating, and we are pleased to see the FCC taking steps to increase resilient communications in the context of hurricanes. This work will help protect property and save lives in states where hurricanes present a regular threat. However, in states like California where wildfires are rapidly increasing in regularity and severity, there is an urgent need for targeted recommendations to promote network resiliency.
If the FCC intends to conduct a truly "comprehensive investigation of the Framework," the Bureau must solicit feedback from Framework signatories on their actions before, during, and after recent wildfires throughout the United States. The FCC regulates interstate communications in all 50 states and the Framework must address emergency communications threats faced by all states and territories. Accordingly, we request that you take immediate action to include wildfire response recommendations in the Framework.
We appreciate your attention to this crucial public safety issue and look forward to working with you to promote resilient communications during emergencies.