On August 6, 2025, the FCC released a Third Further Notice of Proposed Rulemaking and Order on Reconsideration (FNPRM and Order, respectively) on the Commission’s Disaster Information Reporting System (DIRS). Although originally scheduled for consideration at the Commission’s August Open Meeting, the items were adopted prior to the meeting.
- FNPRM – In the FNPRM, the FCC seeks comment on proposals to modernize DIRS “to ensure the system is collecting information useful to disaster response without imposing unreasonable burdens on stakeholders.” More specifically, the FCC seeks comment on:
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- Streamlining the DIRS Reporting Framework – The FCC seeks comment on methods to streamline DIRS reporting, including by (i) simplifying DIRS reporting for manual filers by offering them the “ability to file a single, dynamic form instead of the current array of ten separate worksheets concerning different types of service and infrastructure”; and (ii) eliminating or modifying DIRS worksheet or information fields, including the “Percent of Historical Capacity Available” field from the Wireless Cell Site by County worksheet, among other changes.
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- Eliminating the Requirement to File DIRS Final Reports – The FCC seeks comment on eliminating the requirement for mandatory DIRS filers to file a final report within 24 hours of DIRS deactivation.
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- Eliminating DIRS Reporting for Resellers and Mobile Virtual Network Operators (MVNOs) – The FCC seeks comment on whether to limit DIRS reporting to facilities-based providers and exempt MVNOs and resellers from DIRS reporting.
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- Extending the Network Outage Reporting System (NORS) Reporting Waiver to DIRS-Lite Activations – The FCC seeks comment on whether to extend the NORS waiver to DIRS-Lite activations.
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- Eliminating Barriers to Information Sharing – Noting that only 22 federal, state, Tribal, and territorial emergency management or public safety agencies have sought and been granted direct access to NORS and DIRS information, the FCC seeks comment on ways to make it easier for these agencies to obtain direct access to NORS and DIRS filings for use in restoration and recovery efforts.
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- Cost Benefit Analysis – The FCC seeks comment on whether its proposed changes “would generate benefits for communications service providers and public safety officials that outweigh the costs,” estimating that its proposals “will result in annual cost savings of approximately $4 million, which outweighs the $1,400 one-time cost and the $215,000 annual recurring costs to implement these changes.”
Comments are due thirty days following the FNPRM’s publication in the Federal Register, and replies are due sixty days following publication.
2.Order on Reconsideration – In the Order, the FCC grants, in part, the Alliance for Telecommunications Industry Solutions’ (ATIS’s) Petition for Clarification and/or Reconsideration of the FCC’s Second Report and Order by “clarif[ying] the scope of the suspension of [NORS] reporting obligations during DIRS activations, thereby reducing filing burdens.” The FCC otherwise denies ATIS’s Petition, including its request to clarify that waiver of the NORS reporting obligation also waives the obligation to notify 911 and 988 special facilities. More specifically, the FCC:
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- “[C]larif[ies] [its] outage reporting requirements for outages that occur in the same geographic area as a DIRS activation. In these circumstances, providers must file in NORS if the required filing will become due prior to the first DIRS filing deadline of the activation. Requirements to submit any NORS filings with deadlines that occur after the first DIRS filing deadline will be waived as long as the outages are timely reported in DIRS. If the first DIRS filing deadline occurs before the NORS notification is due, then the provider may file solely in DIRS.”
- The FCC further explains that (i) “[t]his waiver does not apply to outages occurring outside of the geographic area where DIRS is activated, nor does it apply to outages with notification deadlines that occur after DIRS is deactivated”; and (ii) “[a]ll outage impacts that are not timely reported in DIRS must still be reported in NORS.”
- The FCC “den[ies] ATIS’s request to clarify that NORS filers be allowed to withdraw notifications or reports that are filed in NORS before the first DIRS filing deadline solely because DIRS has been activated in the area of the outage,” finding “that the benefit of maintaining the NORS report on file outweighs any burden of potentially receiving duplicative reports.”
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- “[D]ecline[s] ATIS’s request to clarify that the NORS reporting waiver during DIRS activations applies to 911 and 988 special facility outage notification requirements because ATIS’s request is both procedurally and substantively infirm.”
The Order will be effective upon publication in the Federal Register.
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