III. Backup Power Systems Installed on the Property of Residential and Small Commercial Customers--Plan of Action

Section 776 addresses backup power systems installed on the property of residential and small commercial customers by telephony providers. The first step in the investigation will be to determine the telephony providers' current practices regarding backup power systems, including the feasibility of establishing such systems where they do not exist. The second step will be to obtain the telephony providers' and other interested parties' recommendations for reliability standards and the associated costs and benefits.

To this end, the Commission's Communications Division (CD) is directed to convene a technical workshop of subject matter experts to inform the Commission on this matter. The workshop to discuss "back up power installed on the property of residential and small commercial customers" will be held June 5, 2007. CD will provide timely notice on the Commission's Calendar and to the service list.

The outcome of the workshop will be an informational request that will seek more detailed information, concerns and issues related to backup power systems on the property of residential and small commercial customers. The request will direct respondents to provide recommendations along with associated implementation costs and benefits. While the bill concerns itself with only backup power, a cost/benefit analysis should be viewed holistically. For example, there is no customer benefit if power is maintained/restored but the lines are flooded under water.

The request will be sent to all facilities-based telephony providers and other interested parties. Upon receipt of the responses to the request, CD will compile the information into a report that:

1. Identifies the concerns and issues that the Commission must address, including current best practices and the technical feasibility of establishing battery backup requirements;

2. Identifies recommendations presented by the parties and their level of support;

3. Identifies a recommended course of action, as well as any other viable options;

4. Discusses the costs and benefits of implementing the recommended course of action;

5. Proposes a definition of small businesses for the purpose of this investigation; and

6. Identifies any concerns or issues that remain to be addressed.

The draft report will be sent to the parties for comment. Upon receipt of the comments, CD, in consultation with the assigned Commissioner, will prepare a revised draft report, which will be provided to the parties for comment.5 A proposed decision, which adopts a final report, then will be prepared.

5 For any or all of these three workshop topics, CD may evaluate a gradation of possibilities with varying costs and benefits. Option A, for example, may have some benefits but relatively high costs. Option B may be the opposite with several other options falling in between. All possibilities may be feasible, and CD will specify its recommended options in accordance with the requirements of §§ 776, 2872.5 and 2892.1.

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