FCC rules for backup power

Wayne E. Bouchard web at typo.org
Tue Nov 13 21:00:34 UTC 2007

On Tue, Nov 13, 2007 at 03:07:03PM -0500, Sean Donelan wrote:
> Proposed new FCC rules for backup power sources for central offices, cell 
> sites, remote switches, digital loops, etc.  For the first time, the FCC 
> is considering specific backup power time requirements of 24 hours for 
> central offices and 8 hours for outside plant and cell sites.  Although 
> most carriers tended to follow old Bell System Practices for backup power,
> BSP's weren't official regulations.
> ISPs aren't specifically covered, but ....
> <http://www.tessco.com/yts/industry/products/infra/infrastructure/power_supplies/pdf/agl_reprint.pdf>

I would suggest that these requirements will run afoul of local
regulations regarding the storage of combustibles such as diesel fuel
or other hazardous materials. (Think 111 8th ave and 9/11) This
article seems to take much the same position.

In short, this, to me, is the FCC putting it's nose where it doesn't
belong. This is not something which should be regulated by this
agency, it should be something done by the various communications
operators in conjuntion with local municipalities. Yes, this means
that there will be variances in many places but the regulations in
place regarding fuel storage and so forth (no to mention batteries for
DC plants, FM200 storage, etc, etc) are there because they are deemed
to be in the best interests of the local community. The FCC has no
idea what those "best interests" are and never will.

Besides, when you're talking about a Katrina sized event, 24 hours is
meaningless. Normal communications were not restored on many areas of
the region (not just Louisiana) for days or weeks afterwards. And the
assessment of what had occured didn't really begin until after the 24
hour mark was over anyway. The NTSB learned from its process of
grounding planes after 9/11 that there are some emergency events where
having pre-existing procedures in place can actually be harmful. The
determination was that if there had been a process defined, all it
would have done is slow things down by restricting what controllers
could and could not do. Better to just let them use their knowledge
and experience and act in the best way they know how, given the
situation before them.

Lets also point out that a generator is most often going to be outside
the building at ground level, wether or not it is contained within its
own structure. And if the generator isn't, there's a fair chance it's
fuel tank would be. Not everyone will be willing to deal with the
expense of burying it. As such, these are usually totally exposed to
the elements and any lowland flooding. Meaning that if something fails
in a facility due to a weather related event, it's probably going to
be the generator. We've all seen that many times before.

My $0.37


Wayne Bouchard
web at typo.org
Network Dude

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