Telecom Interests Challenge CPUC's Proposed Changes to Backup Power Rules
Providers are pushing back on a California Public Utilities Commission (CPUC) proceeding that suggests regulating how much wireline and wireless carriers and ISPs can rely on portable generators to guarantee network resiliency. The proceeding, initiated this summer, asks about the right ratio of mobile generators to network facility sites to ensure system resilience, as well as where the mobile generators need to be stored to ensure that they're deployed in a timely fashion during disasters.
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The number of portable generators that a carrier maintains "cannot be reduced to a mathematical formula or ratio," T-Mobile said in comments this week. The company maintains a fleet of dedicated portable generators statewide, but "how, when and where to deploy" them depends on factors only the carrier can determine based on real-time information, it said. A mandated ratio of portable generators to sites would be a "misguided ... attempt to oversimplify network resiliency and would be unrealistic, unproductive, and unlawful."
T-Mobile also said it's looking into advanced battery technology and other resiliency options, and it plans to incorporate them in California and elsewhere when feasible. But even if CPUC "had the authority to require the use of such advancements -- which it does not" -- requiring them in the name of resiliency "would be unwarranted, counterproductive and contrary to the Commission’s prior determination to avoid micromanaging the way carriers address resiliency."
Maintaining continuity of service involves using everything from backup power and mobile generators to mobile wireless facilities and overlapping network design, Verizon said. The CPUC proceeding is "a solution in search of a problem since the current network resiliency rules for communications service providers work well."
Different wireless operators don't have the same number of wireless facilities in the same locations with the same coverage, so they wouldn't all need the same number of portable generators, Verizon argued. Micromanaging mobile generator use should be avoided, it said, as rigid rules "would likely impose significant costs with little benefit for network reliability."
AT&T likewise said carriers "need continued flexibility to address backup power on a case-by-case basis."
Wireless ISP DigitalPath said the CPUC should focus on identifying and addressing issues that prevent providers' compliance with its resiliency program. Backup power equipment might not be possible at some network locations due to space constraints or local or state regulations, it noted. For example, lack of space is an inherent problem for backup generators in residential neighborhoods, and because of such issues, customers there accept that power outages might mean limited service availability. DigitalPath added that changing network resiliency rules to require providers to install backup generators in those neighborhoods would likely cause providers to decommission the site instead.
If there are to be rules about storage of portable generators, DigitalPath suggested requiring them to be within the drive time to deliver a generator before onsite backup power is exhausted, plus an additional 25% drive-time margin.
In addition to the providers' comments, the CPUC proceeding saw some support this week from the Communications Workers of America and the Utility Reform Network, a utility customer advocacy group. They said in a joint filing that while large wireline and wireless carriers have previously opposed regulatory and policy efforts to improve network resiliency, the need for better requirements was most recently demonstrated by communications network failures during the Los Angeles County fires in January. They urged a 1-to-1 ratio of mobile generators to sites, except where there's backup power via stationary equipment such as solar panels.
The proceeding also asks about how the CPUC can verify service provider claims that implementing 72-hour backup power requirements at some sites isn't feasible. Verizon said it's not clear why providers' current explanations aren't enough, arguing that small-cell and outdoor distributed antenna system sites are typically on wooden power distribution poles or streetlight poles, where there typically isn't enough space for 72 hours' worth of batteries or generators to be attached or adjacent.
AT&T said it often uses emerging technologies to speed up recovery, such as satellite-enabled "Cells on Wheels" and predictive analytics that pre-stage assets ahead of severe weather. Wireless providers all hustle to outperform one another on reliability and restoration speed, it said, and that competition "ensures that any breakthrough -- whether in alternative energy, artificial intelligence, or network virtualization -- is adopted rapidly."