According to research conducted in 2003 by the Federal Communications Commission (FCC) and National Communications System (NCS), less than 10 percent of the nation’s approximately 7,500 9-1-1 call centers – more formally called Public Safety Answering Points (PSAPs) – were participating at that time in what is called the Telecommunications Service Priority (TSP) program.  The two biggest problems cited for the lower-than-expected participation rate were: (1) the apparently limited understanding of what the TSP program is, and how it works; and (2) a lack of the funding needed to implement the program at the local level.  Following the study, the FCC and NCS (an agency of the Department of Homeland Security (DHS)), initiated a nationwide campaign to help ensure that all of the nation’s PSAPs would be registered in the TSP program; the FCC/NCS effort received strong support from the National Emergency Number Association (NENA), the National Association of 9-1-1 Administrators (NASNA), and the Association of Public-Safety Communications Officials (APCO). On 17 November 1988, 15 years before the 2003 study, the FCC had issued a “Report and Order” (FCC 88-341) establishing the TSP program, which is managed for the FCC 

Provisioning TSP usually comes into play after a breakdown of the communications infrastructure has occurred, and new service is needed, frequently in a different location by the NCS.   TSP provides both for priority installation and for priority restoration of the telecommunications services that are considered critical to national security and emergency preparedness (NS/EP), particularly in times of crisis – an umbrella term that covers a broad spectrum of situations ranging from natural disasters such as floods, forest fires, and hurricanes to man-made disasters such as terrorist attacks. 

Restoration and Provisioning – Both Are Needed

 For operational purposes, TSP provides two types of priority service: (1) Guaranteed priority restoration of enrolled telecommunications services when the service provider’s resources are overextended; and (2) Priority provisioning for telecommunications services when the normal provider processes will not meet the requirement. Restoration TSP must be set up well in advance – i.e., long before an emergency or disaster occurs – and in that context it serves as an unusual type of operational insurance for the communications network.  

TSP restoration plans are essential to the continuing operation of: emergency operations centers (EOCs), 911 centers, and other emergency-operations centers; data centers; the headquarters of police and fire departments as well as hospitals; and – particularly in recent years, critical infrastructure owned by the private sector. Provisioning TSP usually comes into play after a breakdown of the communications infrastructure has occurred, and new service – e.g., field operations centers and emergency shelters – is needed, frequently if not always in a different location TSP can augment existing emergency communications capabilities and serve as an important component of almost any organization’s emergency plans and/or training exercises.  Without TSP enrollment, which mandates that the service provider repair TSP services before other commercial and residential services, the service providers usually will repair service requests on a first-come, first-served basis.  

Alternate Sources of TSP Funding

TSP usually is ordered from a local service provider, at rates set by the service provider (usually with input from or under limits set by state public-utility commissions).  There typically would be an initial set-up charge and, after that, monthly recurring charges for priority-restoration TSP.  For provisioning TSP, the requester is liable not only for the provider’s service charge but also for the cost of installation. TSP enrollment costs vary both by locality and by service provider. The extreme variation of TSP tariffs among states sometimes creates considerable difficulty, in fact, for various state and local agencies that manage or are otherwise involved in emergency operations to enroll in the TSP program but, because of budgetary constraints, cannot implement TSP on their own. 

On 26 May 2003 the National Association of Regulatory Commissioners (NARUC) recommended, in recognition of the cost of enrolling in TSP, that state public utility commissions review, and revise as necessary, their respective TSP tariffs to ensure that those tariffs are fair, reasonable, and affordable.  Until that review and (if necessary) revision change is completed, though, emergency operations managers may have to look for alternative funding sources to cover the cost of TSP. Among the possibilities are fees from state E-9-1-1 taxes, state USF (Universal Service Fund) surcharges, the Federal Universal Service Fund (FUSF), and DHS grants for emergency communications.      

To summarize: TSP provides both protection and continuity for critical NS/EP functions when demands on a service vendor’s resources might well be at their highest.  If the PSAP and/or other emergency communications capabilities are not covered by TSP, the service vendor is under no obligation to repair the PSAP connectivity ahead of the systems owned by commercial customers. Priority restoration for 9-1-1 call centers and PSAPs is, in that context, a valuable insurance policy that all states and local jurisdictions – and the owners and operators of private-sector critical-infrastructure facilities – should seriously consider. 

Links for additional information 

TSP program (including information on how to enroll)   FCC sponsorship, and how to enroll in TSP

Joan K. Grewe

Joan K. Grewe, a retired Army officer and former deputy chief of staff for the Defense Information Systems Agency (DISA), is director of DHS Services for Terrestar, a private-sector business serving the federal government, with particular focus on the U.S. Department of Homeland Security. She previously served tours of duty in support of the National Communications Systems’ Continuity Communications Program and as an MCI/WorldCom National Security and Emergency Preparedness liaison to DHS. She also advised DHS on issues of government-industry policy, information sharing, and collaboration on programs related to the security of the nation’s infrastructure. She holds a Bachelor of Business Administration from Loyola University of Chicago and a Masters of Business Administration from Wesleyan University in Indiana.

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