FAA, 911 and NCS circuits have seperate reporting criteria. Bell Atlantic
rerouted most of the 911 lines to local answering points quickly, and didn't
require the DACS rebuild to complete. I don't know if enough 9-1-1 calls were
blocked for a long enough time to require filing a report.
The reporting criteria are written regulations. Just like accountants look
for loopholes in the tax regulations, carriers seem to look for loopholes
in the FCC regulations to minimize what their reports.
As Bob Cannon pointed out, the FCC is starting a "voluntary" project where
ISPs would also file outage reports. So expect ISPs to start redefining
things to avoid filing an outage report. I suspect that was also the reason
why AT&T Wireless didn't initially file a report after Rochelle Park, although
Bell Atlantic did. Wireless, cable, pager, satellite are treated seperately
in the FCC regulations.
The ISP reporting regulations were supposed to be posted on the FCC web site
today, but I haven't found them yet.
As always, I speak only for myself.