5. Issue 1: Backup Batteries Installed on the Property 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 from a facilities-based service provider through copper wires. 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 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 (CATV) Services: For traditional CATV systems, if power is interrupted at the house, the television will not operate. Therefore, there is no need for extensive backup facilities to keep broadcasting the TV signal. As CATV companies move to expand their service offerings to include voice, data, and video, 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.

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. Most CATV systems provide 4-5 hours of battery backup in the modem used to provide Voice over Internet Protocol telephone service.

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 1-2 watts. Many other devices can use more power. A digital subscriber line modem can consume 5 watts in standby, and 6 watts in operation. A cordless phone or answering device can consume 2-3 watts in standby, and 3-4 watts in operation. To reduce energy consumption and maximize reserve time during an outage, TV and data services must 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 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, customers will be able 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 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+ years, a number of significant outage events were profiled, including heat waves, wind storms, wild fires, 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.⁸ 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 wind-storms, 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.⁹ 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).¹⁰

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.¹¹

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.¹²

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 Federal Communications Commission (FCC) requirement of Order 07-177 for eight hours of backup power at remote terminals.¹³

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 CATV modem which does the monitoring looses 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.

· Where to find additional information.

· Battery replacement information.

· A recommendation that the customer should 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 that the Commission may wish to consider encouraging service providers to offer optional services for disabled or other disadvantaged Californians. 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 disabled customers in emergencies.

5.3. Discussion

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. Therefore, 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.

During a power outage, it is reasonable to require some amount of backup power to make necessary calls. As discussed in Issue 3, during a power outage, telecommunications systems remote components currently have 4-8 hours of backup power and may be required to have 8 hours of backup power if federal requirements are implemented.¹⁴ It is not useful to require backup power on the customer's premises that provides service when the telecommunications network is out of service. Thus a reasonable range of backup power at the customer's premises is 4-8 hours.

During an outage, customers should not use their telephones, except when necessary, to conserve backup power and allow the telecommunications system to be used for emergency services. Thus any requirement should pertain to the telephone being available for necessary use as opposed to continuous talk time.

The FAR indicates that backup power facilities are in many cases part of the service provider's facilities. In addition, customers may not have the ability to install, monitor or maintain such equipment. Thus it is reasonable to require that the service provider be responsible for backup power equipment, including monitoring, maintenance and replacement.

For these reasons, we intend to require service providers to provide and maintain at least eight hours of backup power on the customer's premises. In addition, there will need to be a customer education plan to provide the necessary information to customers. The record in this proceeding is not sufficient to implement these requirements. For example, there may be implementation issues that require different types of solutions. In addition, persons with disabilities may have special backup power needs that should be addressed. Therefore, we direct CD to prepare for our consideration a rulemaking to address these matters. CD may, at its discretion, use workshops to facilitate development of the rulemaking.

⁸ 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.

⁹ Inclusion of the BBU costs $15 over and above the cost of the ONT.

¹⁰ Estimated wholesale prices.

¹¹ Best Practices are addressed in Issue 4.

¹² 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.

¹³ See Issue 3; Backup Power on the Telecommunications Network.

¹⁴ Backup power for the telecommunications system remote components is intended to provide for continued operations, including ongoing usage by customers.