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Katrina Reply Comments FINAL BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) Recommendations of the Independent ) Panel Reviewing the Impact of ) EB Docket No. 06-119 Hurricane Katrina on ) Communications Networks ) TO: The Commission REPLY COMMENTS OF COX ENTERPRISES, INC. Alexandra M. Wilson Scott S. Patrick Vice President of Public Policy Jason E. Rademacher Cox Enterprises, Inc. 1225 19th Street, NW Its Attorneys Suite 450 Washington D.C. 20036-2458 DOW LOHNES PLLC 1200 New Hampshire Avenue, N.W. Suite 800 Washington, DC 20036 (202) 776-2000 (phone) (202) 776-2222 (fax) August 21, 2006 TABLE OF CONTENTS TABLE OF CONTENTS................................................................................................................ 1 INTRODUCTION AND SUMMARY........................................................................................... 1 I. A STRONG PUBLIC-PRIVATE PARTNERSHIP IS CRITICAL TO EFFECTIVE EMERGENCY PREPAREDNESS AND DISASTER RECOVERY. ............................... 3 II. THE PRIVATE SECTOR MUST CONTINUE TO TAKE A LEADERSHIP ROLE IN PLANNING FOR AND RESPONDING TO EMERGENCIES. ....................................... 5 A. Cox’s Employees Are the Foundation of the Company’s Disaster Response. ............. 5 B. Cox Maintains a Company-Wide Commitment to Disaster Preparedness. .................. 6 C. Cox’s Business Continuity Plans Performed Exceptionally Well in the Aftermath of Last Year’s Hurricanes.................................................................................................. 7 1. Cox’s Disaster Recovery Effort Led to the Quickest Possible Resumption of Service to Affected Areas......................................................................................... 7 2. Cox’s Businesses and Employees Throughout the Country Provided an Overwhelming Humanitarian Response to the Hurricane Crises........................... 10 D. Cox is Dedicated To Using Its Experience in Last Year’s Hurricanes To Strengthen It Future Disaster Responses .......................................................................................... 11 III. THE ELECTRONIC MEDIA ARE PLAYING AN INCREASINGLY IMPORTANT ROLE IN DISASTER PREPAREDNESS AND RESPONSE --AND GOVERNMENT AGENCIES MUST RECOGNIZE THEIR GROWING IMPORTANCE TO POST- DISASTER RECOVERY. ................................................................................................ 12 IV. ADOPTING MANY OF THE KATRINA PANEL’S RECOMMENDATIONS WILL SIGNIFICANTLY IMPROVE THE COUNTRY’S EMERGENCY PLANNING AND RESPONSE....................................................................................................................... 15 A. The Commission Should Work With the Communications Industry To Develop Preparedness Guidelines, But Should Not Impose One-Size-Fits-All Requirements. 15 B. Cox Supports the Katrina Panel’s Proposals Regarding Voluntary Waivers and Outage Reporting. ....................................................................................................... 17 C. The Commission Should Do All It Can To Improve Disaster-Preparedness Coordination Between Federal, State, and Local Government and the Communications Industry. .......................................................................................... 18 D. Cox Supports the Implementation of Voluntary NRIC Best Practices for 911 and E911 Service Reliability. ............................................................................................ 21 E. The Commission Should Use Its Ongoing EAS Proceeding To Improve Emergency Communications to the Public.................................................................................... 22 CONCLUSION............................................................................................................................. 23 2 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) Recommendations of the Independent ) Panel Reviewing the Impact of ) EB Docket No. 06-119 Hurricane Katrina on ) Communications Networks ) TO: The Commission REPLY COMMENTS OF COX ENTERPRISES, INC. Cox Enterprises, Inc. (“Cox”), by its attorneys and pursuant to Section 1.415 of the Commission’s rules, 47 C.F.R. § 1.415, hereby files these reply comments in response to the Commission’s Notice of Proposed Rulemaking in the above-captioned proceeding. 1 INTRODUCTION AND SUMMARY Cox is one of the nation's leading media and automotive services companies, with a presence in hundreds of large and small communities throughout the country. Founded as a newspaper company in 1898, Cox’s operating subsidiaries today include Cox Communications, Inc. (cable television, telephone, high-speed Internet, and other advanced broadband services) (“CCI”);2 Cox Newspapers, Inc. (newspapers, local and national direct mail advertising and 1 Recommendations of the Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks, Notice of Proposed Rulemaking, EB Docket No. 06-119, FCC 06-83 (released June 27, 2006) (the “NPRM”). 2 CCI is a multi-service broadband communications and entertainment company with more than 5.9 million total residential and commercial customers. The company offers both analog and advanced digital cable television services and an array of other communications and entertainment services, including residential local and long distance telephone (both circuit- switched and Voice over Internet Protocol) and high speed Internet access. In addition, CCI provides communications solutions for both large and small business customers, providing high- speed Internet, voice and long-distance services, as well as data and video transport services. customized newsletters);3 Cox Television (television, television sales rep firms and research);4 and Cox Radio, Inc. (broadcast radio stations and interactive web sites).5 For many decades, these companies have played a crucial role in informing Cox communities about emergencies of all kinds – natural and man-made, large and small.6 Whether it provides cable, television, radio, telephone, broadband and/or newspaper service to the communities it serves, Cox often is the source to which customers turn when they need fast, accurate, and reliable information about an emergency, or when they need to reach out to law enforcement or first responders. Indeed, prompt restoration of a Cox service often is necessary to give residents the tools they need to weather a disaster and its aftermath. With its diverse business holdings and long history of planning for and responding to emergencies in all parts of the country, Cox has a unique perspective on the challenges involved in providing communications services of all types in disaster areas, and on the useful role that government can play in helping companies maintain and restore services when disaster strikes. Cox, therefore, ________________________ CCI is the nation’s fourth largest cable operator and the nation’s tenth largest telephone company, and provides service to hurricane-prone areas of Louisiana and Florida. 3 Cox Newspapers is one of the nation’s largest newspaper publishing enterprises. Founded in 1898 as the cornerstone of Cox Enterprises, Cox Newspapers now produces 17 dailies and 25 non-dailies in 9 states, including the hurricane-prone states of Florida, Texas, North Carolina, South Carolina, and Georgia. Total circulation for the company’s newspapers reaches 1.2 million each weekday and more than 1.6 million on Sundays. 4 Cox entered the television business in 1948 and now owns 14 television stations, including 2 stations in Orlando, Florida. 5 Cox Radio, Inc. (NYSE:CXR), which is a majority owned subsidiary of Cox, is one of the largest radio broadcasting companies in the United States. Upon consummation of all announced transactions, Cox Radio will own, operate or provide sales and marketing services to 80 stations in 18 markets. A majority of the company's stations are concentrated in the Sunbelt, including Gulf-region stations in Florida, Alabama, and Texas. 6 Cox also owns Manheim Auctions, Inc., which is the nation’s leading sponsor of vehicle auctions and provider of vehicle repair and certification services and web-based technology products. In addition, Cox holds an equity stake in a range of Internet businesses, including AutoTrader.com, the world's largest and most visited source of used vehicle listings for dealers and consumers. 2 has an acute interest in helping the Commission ensure that implementation of the Katrina Panel’s recommendations improves communications providers’ ability to withstand and recover from emergencies, for the benefit of their employees, their customers and their communities. As described below, Cox agrees with those commenters that have expressed support for many of the Katrina Panel’s recommendations. The Panel identified a number of vital roles that the Commission can play, including: (1) working with industry to establish voluntary guidelines for disaster preparedness and the prepositioning of assets; (2) working with other federal, state, and local agencies to guarantee that employees involved in communications infrastructure restoration have ready access to disaster areas and whatever supplies are made available by government; (3) streamlining the STA and waiver process where necessary for service restoration; and (4) working with other federal agencies to ensure that all coordination and credentialing processes are clear to all communications providers both before and after a disaster occurs. Cox also files these reply comments
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