Due to the modernization of the Public Switched Telephone Network (PSTN), the Federal Communications Commission (FCC) has initiated rules to protect telecom subscribers during power outages. For years, customers have assumed the telephone would work even during outages. However, as the PSTN becomes more fiber-based, additional requirements are necessary to keep the network operating during outages. The FCC has established criteria for companies to meet for voice use of the network.
These requirements became effective June 7, 2017, for companies serving fewer than 100,000 lines. Larger companies implemented the requirements earlier. Many companies already have planned their network to fulfill the FCC requirements. The FCC also required telephone companies to establish customer education and notice requirements to help make customers aware of the fiber-based network’s capabilities.
Federal rules at 47 Code of Federal Regulations Section 12.5 establish steps companies must follow to be in compliance. Those steps cover:
- Covered service providers’ (CSP) obligations to offer backup power
- Subscriber disclosure obligations
The FCC defined CSP as a provider of facilities-based fixed, residential voice services that aren’t line-powered. The intent is to help CSPs understand what they must do to meet their new obligation to offer backup power in the event of outages. As of the effective date of the rules, CSPs must offer their customers a point-of-sale option delivering at least eight hours of standby backup power. By February 13, 2019, the requirement increases to at least one point-of-sale option for a minimum of 24 hours of backup power.
Both the eight-hour and 24-hour options must be a complete solution that provides battery or other power or allows connecting another power source apart from the service provider.
Either option must offer backup power on the customer premises to provide the ability to reach a 911 service in an emergency.
The second requirement is to officially educate end-user customers of available options. The FCC sets forth this requirement by requiring disclosure in the form of a customer notice at the point of sale for new customers and annually for all existing customers.
That notice must include these options:
- Backup power duration
- Testing and monitoring
- Disclosure reasonably calculated to reach each subscriber
The notice also must cover service limitations with and without backup power and must include information on the proper use and storage conditions of backup power equipment. This also includes information about the effect of power outages on the use of 911 services and the type of service that will continue to work with backup power.
The FCC offers a template in order FCC-15-98 for the notice content and format. If you have further questions, contact your trusted BKD advisor.