Asking Ofcom

My email to Ian Strawhorne, Head of Enforcement at Ofcom, 30 August 2023

I have seen your letter "Ability of customers to contact the emergency services during a power cut" dated 20 July 2023. This appears to contradict what I was told when I spoke (at some length) this morning with an agent who identified himself simply as Andrew, in your Customer Contact Centre. I am writing to ask your help in establishing the correct position. 

(I am a private individual who understands Telecoms a bit, and wants to be able to advise others in my community about their options upon removal of PSTN services. I have also read your 2018 document "Protecting access to emergency organisations when there is a power cut at the customer’s premises Guidance on General Condition A3.2(b) ").

Your letter says "There is a regulatory obligation on all CPs in General Condition 1 A3.2(b) to ensure uninterrupted access to emergency organisations for their customers, regardless of whether they are offering Voice over Internet Protocol (VoIP) services 2 or not."

In my call to Andrew, I queried the response that I had had from my current CP, Plusnet, when I asked what solutions they were offering for people like me, without a usable indoor mobile signal on any network, upon the retiring of the PSTN service. Plusnet told me that they do not plan to offer a VOIP service beyond the end of PSTN, and so they understand that there is no obligation for them to make provision for any solution that would maintain power to my router in the event of a power cut.

Andrew went away to consult others, then came back to me to confirm that the provision of a "solution" to continue voice calls for the first hour of a power cut was down to the VOIP provider, not the Broadband provider. And he confirmed that there was no Universal Service Obligation on VOIP providers - their decision to serve a customer was purely a commercial one. If this is all correct, then it seems likely that VOIP providers, if they take seriously your requirement to fund backup solutions for those at risk, may simply choose not to serve expensive "at risk" custoemrs at all.

Is that right, please?

I have searched online for any VOIP provider making any mention of Battery Backup Units (BBUs) and can find none. A VOIP provider (who I have used for a charity that I help) has confirmed that they are not offering anything, saying "Section 4.8 has always made a point of defining our services as supplementary - with specific mention of 999 and other emergency facilities. While this was originally drafted in regards to fixed handsets that look a lot like landline phones (Grandstreams, Yealinks, etc) - it is still very much the case today that our service is supplementary." Are they OK to say this?

Your 2022 review of performance found no substantial fault with the action of CPs in handling the issue of 999 calls during a power outage. Yet I can find no Broadband or VOIP CP who shows any sign of acknowledging the existence of Battery Backup units (apart from BT who used to offer one for FTTP, but since seems to have stopped). Could you help me understand how this can be, please?

I will post any reply that I receive, here.