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Re: [802SEC] FCC NPRM related to backup power for communications networks

Hi John.
Thank you for bringing forward these docuemnts.
I think 802 has to address these backup power issues and mostly, operation continuance with backup power, as from a potential ruling will follow requirements on the networks and therefore, the network equipment to "survive" very long power outages. This may impose many additional costs on the equipement and cause large concerns on the power consumption of the equipment. Thee is also an issue raised about equipemnt power supply standardization, from the PHY side, with set supply voltages which may need to be standardized to the actual power connectors. I am convinced the industry can adjust. My main concern is "at what cost: as we all know that any increased cost may cause issues and slow down deployment of IP based networks. Moreover, there are requirements here that may require every switch, every backup ower source to need to be managed which implies a storm of MAC addresss and IP address consumption by the industry so each device becomes manageable or at least, can be interrogated. For example, most consumer grade network switches today do not have a MAC address, an externally reachable IP address although they do transport and distribute IP traffic. There is also a question heer about "green" devices which go to sleep...
Both wired eth devices (POE) and wireless devices may be impacted. POE specifes 48Volts as std. Here we see something along the lines of 3.3 or 5V proposed as std. So 802.3 may need to get involved to either adapt or protect 802.3AF. 802.1 may need to be involved too, as we all know the wide popularity of locally administered IP addresses and NATting. Here, the service provider may be required to contact deices "inside" the consumer network and the configuration here of routers may be very problematic for consumers. There is also a question on all wireless stds that may transport VoIP... probably all 802 wireless technologies may be affected.
There are talks of over 40 million affected consumers, my translation, probably over 40 million home IP networks and home edge routers. Maybe something may be needed that allows the customer CPE equipmenet to "certify" the link form the CPE client right down to the "VoIP" host that all the equipement through which hs IP trafic flows to the "E911" service is indeed "backup protected". I beleive there are PHY, MAC and higher layer issues across the board here.
Just my 2 cents worth,
Ivan Reede
----- Original Message -----
Sent: Wednesday, November 26, 2014 12:53 PM
Subject: [802SEC] FCC NPRM related to backup power for communications networks


I haven?t read the entire NPRM, but there are issues here which may affect IEEE 802.

ENSURING CUSTOMER PREMISES EQUIPMENT BACKUP POWER FOR CONTINUITY OF COMMUNICATIONS; TECHNOLOGY TRANSITIONS; POLICIES AND RULES GOVERNING RETIREMENT OF COPPER LOOPS BY INCUMBENT LOCAL EXCHANGE CARRIERS; ET AL.   Proposed to strengthen public safety, pro-consumer, and pro-competition policies and protections appropriately for technology transitions underway; clarified that where carrier offers a service to the public, its service is defined in a functional manner. (Dkt No.  RM-10593 13-5 05-25 RM-11358 14-174 ). Action by:  the Commission. Adopted:  11/21/2014 by NPRM. (FCC No. 14-185).  WCB


John Notor
President/Chief Technologist
Notor Research

Mobile: 1.408.316.8312

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