FCC rules for backup power

2007-11-13 Thread Sean Donelan



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>



Re: FCC rules for backup power

2007-11-13 Thread Wayne E. Bouchard

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
[EMAIL PROTECTED]
Network Dude
http://www.typo.org/~web/


Re: FCC rules for backup power

2007-11-13 Thread Mike Lyon

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 <[EMAIL PROTECTED]> 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
> [EMAIL PROTECTED]
> Network Dude
> http://www.typo.org/~web/
>


Re: FCC rules for backup power

2007-11-13 Thread Deepak Jain



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


Re: FCC rules for backup power

2007-11-13 Thread Jared Mauch

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 [EMAIL PROTECTED]
clue++;  | http://puck.nether.net/~jared/  My statements are only mine.


Re: FCC rules for backup power

2007-11-13 Thread Mike Lyon

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 <[EMAIL PROTECTED]> 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 [EMAIL PROTECTED]
> clue++;  | http://puck.nether.net/~jared/  My statements are only mine.
>


Re: FCC rules for backup power

2007-11-13 Thread Sean Donelan


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



Re: FCC rules for backup power

2007-11-14 Thread J. Oquendo
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?
> 
> http://www.thecentraloffice.com/Katrina/lkctla.jpg

Obviously that CO didn't fork out enough for the "vertically integrated
high availability, maximized throughput, horizontal latency free,
managed distribution with 99.9% 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



smime.p7s
Description: S/MIME Cryptographic Signature


Re: FCC rules for backup power

2007-11-14 Thread Jerry Dixon

Jared> and all this time I thought you just wanted to attend those meetings to 
see all of our bright faces and partake of the chocolate chip cookies :)

In all seriousness, it is very good to get involved in these meetings and stay 
on top of what is going on.  Plus it helps the gubment types out on what is 
reality or what is doable versus going off on a wild tangent.  Especially with 
recovery, understanding what the real vulnerabilities or exposures are, and of 
course planning response activities.

I can't thank many of you enough that have taken an active role in helping USG 
out over the last few years and also the insights that you've shared with many 
of us that have worked these issues in the past.  So with that said, get 
involved and let your opinions be known.  Also you have a great opportunity 
coming up with new elections about to take place to help shape or influence the 
way ahead but you've got to get involved.

Another good link on current documents on national level response and 
preparedness can be found here:

http://www.dhs.gov/xprepresp/publications/


Also recommend setting up the usual google alerts on some keywords like:

"cyber and homeland"
"communications and homeland"

Lastly there is a great effort underway led by a bi-partisan Congressional 
Commission.

See http://www.csis.org/tech/cyber/

Congressman & Chairman Langevin & Ranking Member McCaul are two good people to 
send letters to or communicate with related to many of these issues if you have 
concerns.  There office is real responsive to Cyber & Communication issues.  
They're the ones that setup the Congressional Cyber Commission.

http://homeland.house.gov/about/subcommittees.asp?subcommittee=12

-Jerry


-Original Message-
From: Jared Mauch [mailto:[EMAIL PROTECTED]
Sent: Tuesday, November 13, 2007 04:44 PM
To: 'Mike Lyon'
Cc: 'Wayne E. Bouchard', 'Sean Donelan', nanog@merit.edu
Subject: Re: FCC rules for backup power


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 [EMAIL PROTECTED]
clue++;  | http://puck.nether.net/~jared/  My statements are only mine.





Re: FCC rules for backup power

2007-11-16 Thread Michael Loftis




--On November 13, 2007 3:07:03 PM -0500 Sean Donelan <[EMAIL PROTECTED]> 
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.