5. Issue 1: Backup Batteries Installed on the Premises
of Residential and Small Commercial Customers

5.1. FAR Analysis

Electrical power is a key to ensuring end-to-end telecommunications service. A central battery system was deployed in the 1920s to improve network operations, performance, and reliability. As a result, batteries and generators located in the service provider's central office were able to power both the central office equipment and the customer's telephone in the event of a power outage (assuming the telephone system was otherwise intact). The same continues to be true today for customers receiving wireline telephone service that utilize copper wire facilities. However, newer communications transmission technologies, including fiber-optic and coaxial cable, require distributed backup power systems, in the network and at the customer's premises, in order to maintain service because they otherwise may not be able to power the customer's telephone.

The primary power to operate the central office is provided by the electric utility. A system of batteries and diesel generators located at the central office ensures a continuous source of power in the event that the commercial power is interrupted.

The network is designed with a 99.99% availability objective for the link from the central office to the customer. To meet this very high reliability objective, the traditional telecommunications service providers paid a great deal of attention to the design and implementation of the backup power plant at the central office. How each type of provider attempts to achieve high reliability is discussed below.

Wireline Services: Traditional wired telephone service does not require power at the customer's premises since the telephone obtains power through the copper wires from the central office. However, some customer-owned equipment, such as caller identification boxes and cordless phones, require electric utility power to operate.

Cable Television (cable) Services:7 For traditional cable systems, if power is interrupted at the home, the television will not operate. Therefore, there is no need for extensive backup facilities to keep broadcasting the television signal. As cable service providers move to expand their service offerings to include voice and data, they are putting in place powering schemes similar to those provided by the traditional telecommunications service providers. These include backup power at headend locations (the equivalent of a central office) with batteries at some remote sites. However, customer premises equipment requires battery backup power to operate during a power outage.

Broadband Services and Fiber Architectures: For these systems, the portion of the network close to the customer's premises is considerably different from traditional telephony. For Fiber-to-the-Building or Fiber-to-the-Curb systems, where the provider's fiber optic system is not connected directly to the customer's premises, the backup power units are usually contained within an enclosure located in close proximity to, or inside, the customer's premises. For Fiber-to-the-Home or Fiber-to-the-Premises systems, where the provider's fiber optic system runs all the way to the customer's premises, the battery backup is located on the customer's premises.

Most, but not all, broadband service providers provide backup at the customer's premises. Four to 20 hours of battery backup were typically cited by parties. These service providers indicated that they provide up to 8 hours of backup battery power at the customer's premises.8 Most cable systems provide four to five hours of battery backup in the modem used to provide Voice over Internet Protocol telephone service with the ability to expand the battery reserve, if requested, by a factor of 2 or 3.9

For a given battery capacity, the amount of reserve time for a device depends on its power usage expressed in watts. The usage varies depending on whether the device is on standby where the device is ready to make a call, or in active use. The delivery of traditional telephone service over copper wires normally consumes one to two watts. Other devices can use more power. For example, a digital subscriber line modem can consume five watts in standby, and six watts in operation. A cordless phone or answering device on the customer's premises can consume two to three watts in standby, and three to four watts in operation. To reduce energy consumption and maximize reserve time during an outage, video and data services should be disconnected as soon as possible.

How long a battery will supply power to the customer also depends on the customer's use during a power outage. If the customer makes multiple calls or a few lengthy calls to friends, family, the local power company or local officials, the load is large and the battery will drain fast. If provided with sufficient education, however, customers can be encouraged to conserve their backup power during a power outage or emergency situation by making only necessary calls.

Other factors that affect how long a battery can provide power, in order of impact, include:

Operational Modes - Greater use of sleep, idle and standby modes will reduce the load on the battery.

Battery Type - Some types of battery have more capacity for a given size than others.

Battery Age and Quality of Manufacture - As batteries age, their capacity to store energy is reduced. Lower quality batteries will deteriorate faster.

Battery Temperature - A battery exposed to hot or cold conditions will be able to provide power for a lesser amount of time than at moderate temperatures.

Design of Customer Equipment - Some savings are possible through selection of more energy-efficient devices, however the savings are usually small.

In order to evaluate the implications of establishing minimum performance standards for backup power it is necessary to assess the tradeoffs between the impact of electrical power outages on customers and the costs of providing sufficient battery backup time to minimize the interruption of telecommunications service.

Using California electric utility statistics from the last 10 plus years, a number of significant outage events were profiled, including heat waves, windstorms, wildfires, earthquakes, floods, human error and lightning. Based on the analysis of this information, the risk of a customer losing telephone service during an outage event decreases from 6.8% for systems with four hours of backup power, to 3.9% for systems with eight hours of backup power.10 The addition of more battery capacity to achieve 15-20 hours of backup will further reduce the risk from the 3.9% to roughly 2.0%.

Extended power outages (greater than 14 hours) are caused by large or state-wide outage events such as windstorms, extensive floods or large earthquakes where not only power is lost but widespread physical damage to telecommunications plant and customer equipment is likely. In such a case, the telecommunications network may be disrupted such that the customer is unable to make a call regardless of amount of backup power available to the customer. Based on the above data, the FAR concludes that eight hours of backup is more than sufficient for the vast majority of the power outages. The FAR also finds that, since most consumers have multiple telecommunications means available to them (e.g., both wireline service and cell phone service) it is less likely that all of their telecommunications services will be lost simultaneously.

Based on commercially available products used by carriers today, there are several options available to increase the amount of backup power at the customer's premises. Where service is provided to the customer's premises over fiber optic cable, each customer's premises will have an optical network terminal (ONT). The inclusion of a standard battery backup unit (BBU) with the ONT costs approximately $15 and provides 6.5 hours of backup power at a load of 10-watts.11 The next level of protection involves the addition of a basic external battery pack. This would cost another $20 per unit and extend the available backup power to 13 hours assuming the same load. Finally, to achieve more than 13 hours of backup, a high-capacity battery pack would be required at a cost of $50 per unit ($30 over the basic pack).12

This cost analysis is based on an anticipated load of 10-watts in the event of a power outage. Energy is required to (1) monitor battery status and alarm systems, (2) signal the presence and status of the customer to the network, and (3) provide service. The assumed 10-watt load is representative of the higher loads reported for various current Fiber-to-the Home systems. If the load is reduced, the hours of backup power will increase for the same cost. For instance, the use of the standard ONT/BBU device that would provide 6.5 hours of backup at a 10-watt load may yield approximately 10 hours of backup power at a 6-watt load. Decreasing the load on the battery through using low-power standby modes and idle settings on customer equipment is more cost-effective and permanent than simply adding extra batteries.

5.2. FAR Recommendations/Options

Backup Time: Backup times currently provided by service providers vary from 4 to 20 hours. The backup time should not exceed the backup time of the service provider's network. Having a long battery backup time requirement at the customer's premises serves no purpose if the provider's network is down.

The FAR offers the following options for backup time:

1. No minimum backup requirement. This option recognizes that current implementation of the Best Practices and industry contingency plans have proven adequate to provide emergency telecommunications services in many power outage situations.13

2. Set a minimum backup power requirement of four hours for the telephone to be available for emergency use, not four hours of talk time. This matches the general industry backup capacity for remote terminals that serve the customer premises.14

3. Set a minimum backup power requirement of eight hours for the telephone to be available for emergency use, not eight hours of talk time. This would match the recent FCC requirement of Order 07-177 for eight hours of backup power at remote terminals.15

The FAR states that if either Option 2 or 3 is selected, the Commission should allow an exemption to the requirement for mitigating circumstances such as unreasonably high cost to the provider or customer.

Contingency options could include enhanced battery capacity at the customer's premises with monitoring and replacement by the service provider for a fee or offering a cell phone for emergency use.

Minimum Operating Life: Battery useful life depends on the quality of the battery, the environment in which the battery is located (temperature, etc.), how often the battery is discharged and recharged, and the load on the battery when used. Battery useful life can vary from 1 to 10 years. If the service provider remains the battery owner and is responsible for maintenance, the Commission may need to address the providers' battery maintenance programs.

If the customer is the owner, there is a risk that the batteries will not be replaced on an appropriate schedule, resulting in reduced capacity or failure.

One of the more effective options is to educate customers on the pros and cons of backup battery ownership, care, and maintenance; so as to help the customer make appropriate purchasing or service decisions.

Battery Status: Some battery status monitoring systems have colored lights to indicate system status. Others have audio signals, although the alarm is often not particularly loud. If the BBU or cable modem which does the monitoring loses power, the customer may not realize or notice problems with battery status until telecommunications service is lost. The FAR suggests that options for improving the battery status indicators include customer education to make the customer aware of the availability and capabilities of backup battery service. The FAR also notes that the options for monitoring and alarms will increase the load on the battery and decrease the available backup time.

The FAR offers the following options:

· Require a series of announcement options to be offered to the customer. Options could include brighter or flashing lights for deaf or hearing impaired customers, and variable volume or pitch for blind, visually-impaired, or hearing-impaired customers.

· Require a text or voice message to be automatically sent from the battery monitoring system to a specific telephone number.

Customer Education: As noted above, customer education is a critical factor in maximizing the potential of backup power systems. Providing accurate, relevant information to the customer is an effective tool to use in helping maintain telecommunications during emergencies.

The FAR offers the following options:

· Make such information available on the Commission's web site.

· Require the service provider to disclose battery backup system performance.

· Specify how such information may be provided to consumers such as through advertising materials, brochures, the provider's website, bill inserts, tailored information for consumers with special needs (e.g., hearing or visually impaired), etc. The FAR states that information buried in service agreements is not an effective means of communication.

The FAR states that the information provided to the customer should include:

· Why the backup power was installed.

· What the backup power does and does not do.

· How long the phones can operate under backup power.

· The need for backup power to call E-911 in power outages.

· What the maintenance requirements are.

· Potential risks from such backup power systems.

· Battery replacement information.

· Where to find additional information.

· A recommendation that the customer consider having an alternative means of communication.

The FAR also states that education programs should address the special needs of groups such as the deaf, disabled, or visually impaired regarding the options available to them to extend the life of the backup battery.

Other Options: The FAR says the Commission may wish to consider encouraging service providers to offer optional services for disabled or other Californians with special needs. Examples could include:

· Partially subsidizing the cost of additional battery backup capacity at the customer's premises.

· Providing low cost backup service such as a cell phone for emergencies.

· Offering incentives to community service groups to assist customers with disabilities in emergencies.

5.3. Discussion

This proceeding is post 9-11, Katrina, and Virginia Tech. The narrow purpose of the Section 776 portion is to assess whether California residential and small business consumers are able to make and receive telephone calls for a reasonable time after the commercial power to their premises fails. There is no need to-and we do not by way of this decision-revisit our decision to forbear object regulation of VoIP providers. However, Section 776 does require that we implement standards as to backup power on the customer's premise only if the

benefits exceed the costs.16 As discussed above, the FAR addresses costs to some degree but does not quantify benefits. Thus, there is insufficient information on the record of this proceeding to perform an empirical cost-benefit analysis. Additionally, we recognize that the FCC's Katrina Order is still on appeal and, if overturned, would have dramatic implications on cost/benefit assessments of potential backup power customer premises rules.

There is, however, a paradigm shift underway in the delivery of voice communications. Customers may not know whether their telephone is capable of operating during a power outage without battery backup, much less the limitations of such backup if required. In an emergency that coincides with a power outage, the inability to make a phone call to obtain emergency services could lead to property loss or damage. More importantly, it could lead to injuries and fatalities.

Residential and small business customers whose telephone is incapable of operating during a power outage without battery backup must be made aware of this limitation and educated about the available options for backup power. From a public safety perspective, during an extended power outage, it is necessary that customers have the ability to make necessary phone calls and receive emergency notifications for a reasonable period of time. The question is whether rules are necessary for service providers to inform their customers about service limitations during a power outage, what customer options and responsibilities are, and whether rules are necessary to compel service providers to provide a minimum level of backup power.

If rules are necessary, they should be designed to achieve this goal at the lowest reasonable cost without hindering the evolution of telecommunications technology. This proceeding remains open for further consideration of these issues.

5.4. Consumer Outreach and Education

We believe efforts are needed to ensure that consumers of voice service over fiber, coax and broadband facilities are made aware of the necessary battery replacement and monitoring. Accordingly, an issue to be addressed in the next phase (Phase 2) of this proceeding is the current best practices of service providers in notifying consumers about battery backup power capabilities in a power outage, and how these practices could be enhanced. Another issue for this phase is how the Commission may best educate consumers of their battery backup power options and subsequent responsibilities so that they know their options when choosing a service provider.

We direct Commission staff to focus on these issues in our Consumer Protection Initiative programs, which have included: public service announcements and advertisements; training of community based organizations who in turn train their communities on an issue; Commission consumer websites, such as http://www.calphoneinfo.com; and other consumer education and outreach programs.

Staff and voice providers should work together on customer outreach and education on the issues of backup power and telephone service during an outage, including, for example: backup power issues at the customer premises of residential and small business customers where telephone service is offered over fiber optic lines and coaxial cable; how to use communication services during a power outage; recommendations on second charged, backup batteries for emergencies and/or for family and friends, particularly if the customer has a disability, is elderly or has other special needs. We note, moreover, consumers with traditional wireline service should be made aware of issues such as the failure of cordless phones during commercial power outages.

We expect staff to examine these issues in addition to whatever customer education efforts service providers are already making. Thus, we direct staff to hold a workshop with parties to identify the various technologies, their backup power limitations and how best to describe to customers those limitations, consumer options and responsibilities. In this workshop, we expect industry parties, based on their experience, to assist staff in developing an efficient message to customers.

5.5. Performance Reliability Standards

The Commission will consider in a third and final phase of this proceeding whether there is need to establish performance reliability standards for backup power systems installed on the premises of residential and small commercial customers by all facilities-based providers of telephony services (including those that do not have certificates of public convenience and necessity with this Commission). In considering whether to adopt such standards, the Commission staff will collect information on what individual providers are offering and what industry best practices are with regard to battery backup power. Before establishing any such standards, the Commission will determine that the benefits exceed the costs, as required by the statute, and that the implementation of such standards by service providers is reasonable and feasible.

7 Cable is referred to as CATV in the FAR.

8 FAR at 34 - 35.

9 Id. at 34.

10 The hours of backup indicated here refer to the ability to make a call rather than continuous talk time. The risk percentages are the proportions of the electric utility's customers who loose power for more than the specified time during an outage event.

11 Inclusion of the BBU costs $15 over and above the cost of the ONT.

12 Estimated wholesale prices.

13 Best Practices are addressed in Issue 4.

14 Remote terminals are equipment on the provider's network that are located between the central office, or equivalent for other types of providers, and the customer's premises.

15 See Issue 3; Backup Power on the Telecommunications Network.

16 Section 776(a) provides that the standards shall do the following:

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