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>
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 --- Wayne Bouchard web@typo.org Network Dude http://www.typo.org/~web/
What? The gov't putting their nose in where it shouldn't be? NEVER! -Mike On Nov 13, 2007 1:00 PM, Wayne E. Bouchard <web@typo.org> wrote:
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
--- Wayne Bouchard web@typo.org Network Dude http://www.typo.org/~web/
On Tue, Nov 13, 2007 at 01:15:53PM -0800, Mike Lyon wrote:
What? The gov't putting their nose in where it shouldn't be? NEVER!
I must say, if you're a provider with US presence and you're not paying attention to the FCC, DHS (NCS, NCSD) and possibly that thing called NSTAC you may wake up one day and be amazed what is going on. Take an example - Unregulated chemical industry becomes regulated under DHS. (One of the 17 sectors that the govvies track). There's stuff to track that doesn't involve having a full time employee to associate with it, but some allocation of time is valuable. If you don't, who knows, you may have Senator Stevens setting policy that is relevant to you. http://hsgac.senate.gov/ http://homeland.house.gov/ There's all sorts of interesting stuff in this space to track. What if your network traffic doubled tomorrow due to a pandemic outbreak and everyone starts telecommuting? http://www.dhs.gov/xprevprot/programs/editorial_0760.shtm Perhaps it's wrong, or maybe they're right? I think continuing to watch the activities in this space are going to be critical to our evolution as providers of these ip packets. - Jared ps. other stuff of interest: www.it-scc.org (free) www.pcis.org (us, ca) -- Jared Mauch | pgp key available via finger from jared@puck.nether.net clue++; | http://puck.nether.net/~jared/ My statements are only mine.
I do find it very interesting with all of what has happened post 9/11. Or maybe it's just more in the open now since then. But now we have the gov't putting there noses into everything network related it seems. For example, the Patriot Act (not saying this is good bad, i'll leave my thoughts to myself), CALEA and every other wire-tapping means that they have. Hell, now we even have SOX, but that wasn't really due to 9/11 but having that in place does it make life a pain for those in Enterprise IT. I think we have a very interesting next couple of years ahead of us with the Administration change. It will be interesting to see if the internet gets more regulated or less regulated. My $.02 worth. Mike On Nov 13, 2007 1:44 PM, Jared Mauch <jared@puck.nether.net> wrote:
On Tue, Nov 13, 2007 at 01:15:53PM -0800, Mike Lyon wrote:
What? The gov't putting their nose in where it shouldn't be? NEVER!
I must say, if you're a provider with US presence and you're not paying attention to the FCC, DHS (NCS, NCSD) and possibly that thing called NSTAC you may wake up one day and be amazed what is going on.
Take an example - Unregulated chemical industry becomes regulated under DHS. (One of the 17 sectors that the govvies track).
There's stuff to track that doesn't involve having a full time employee to associate with it, but some allocation of time is valuable.
If you don't, who knows, you may have Senator Stevens setting policy that is relevant to you.
http://hsgac.senate.gov/ http://homeland.house.gov/
There's all sorts of interesting stuff in this space to track. What if your network traffic doubled tomorrow due to a pandemic outbreak and everyone starts telecommuting?
http://www.dhs.gov/xprevprot/programs/editorial_0760.shtm
Perhaps it's wrong, or maybe they're right? I think continuing to watch the activities in this space are going to be critical to our evolution as providers of these ip packets.
- Jared
ps. other stuff of interest:
www.it-scc.org (free) www.pcis.org (us, ca)
-- Jared Mauch | pgp key available via finger from jared@puck.nether.net clue++; | http://puck.nether.net/~jared/ My statements are only mine.
One of the results of the changes is that there will probably be fewer COs in the world of the future. They strictly speaking aren't required as often as they used to be, and more and more infrastructure will be deemed "end-powered" or outside plant anyway. If everything goes fiber to the premises, we could have huge swaths of land covered by singular or paired monolithic (but hopefully well designed/operated) COs. The article makes a lot of wild predictions/concerns that are frankly outside of the scope of the ruling. *How* you provide power is your business. The FCC isn't even declaring *what* counts. If your battery plant explodes and you don't get your 8 hours of run-time, its not like they are going to severely penalize you -- the idea is the effort and consideration of on going operation. While we talk about "restoring" connectivity, etc -- major reconstruction can take a while. 24/8hrs is about life safety. Once power goes out, lots of people need to call for help. Even if the cell sites are up, if where they connect to the POTS infrastructure is dark, no one can call 911. *THAT* is the way I read this. This is not about business continuity, or saving property -- just making sure E911 and other things keep working while people could be under a tree that fell into their house *during* the storm. Deepak
On Tue, 13 Nov 2007, Wayne E. Bouchard wrote:
On Tue, Nov 13, 2007 at 03:07:03PM -0500, Sean Donelan wrote:
Can you find the FCC proposed 24-hours of backup power at this CO after Hurricane Katrina? http://www.thecentraloffice.com/Katrina/lkctla.jpg
Sean Donelan wrote:
On Tue, 13 Nov 2007, Wayne E. Bouchard wrote:
On Tue, Nov 13, 2007 at 03:07:03PM -0500, Sean Donelan wrote:
Can you find the FCC proposed 24-hours of backup power at this CO after Hurricane Katrina?
Obviously that CO didn't fork out enough for the "vertically integrated high availability, maximized throughput, horizontal latency free, managed distribution with 99.99999% clusterfsck free with a track record to obtain operational multiples on the valuations of power" version. http://tinyurl.com/2ogat8 ==================================================== J. Oquendo SGFA (FW+VPN v4.1) SGFE (FW+VPN v4.1) "I hear much of people's calling out to punish the guilty, but very few are concerned to clear the innocent." Daniel Defoe http://pgp.mit.edu:11371/pks/lookup?op=get&search=0xF684C42E
--On November 13, 2007 3:07:03 PM -0500 Sean Donelan <sean@donelan.com> 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_s upplies/pdf/agl_reprint.pdf>
If it makes Qwest put backup on the mini-DSLAM at my curb, good. I'm damn sick of losing access every time we have a power bump out here because they are too cheap to provide backup for anything except their CO out here. However I do agree that the FCC is the wrong org to do it, because, as stated elsewhere, they don't have a clue about local regs/etc.
participants (7)
-
Deepak Jain -
J. Oquendo -
Jared Mauch -
Michael Loftis -
Mike Lyon -
Sean Donelan -
Wayne E. Bouchard