In line with our petition on and phones operating in a power outage, we have decided to start trying to collate further information that Ofcom has failed to either consider, or quite frankly given time frame they have had, failed to bother to attain.

You can see our petition here

What we look at in this page is

  1. Recap of other articles
  2. (ESN) Emergency Services and their external communications
  3. Statistics used by Ofcom for their justification in power outages
  4. Any information we are requesting from sources directly


So, the issues we are concerned with is that in 2020 the PSTN network will become legacy, this is how your phone works now.

PSTN offers resilience in a power outage, with the potential to last indefinitely. This is because the only thing that requires power in order for you to use your phone is your local exchange, these can be powered by generators in a power outage, or are likely far away from your premises that they would not be included in the same power outage.

Going forward, and after VoIP is introduced, the regulations in Telecoms only enforce 1 hour of emergency calls during a power outage, but we then have a lot of other considerations

  1. Alarm Systems in the home
  2. Panic Lines
  3. Dalliers for vulnerable people
  4. People living in rural areas
  5. People who have fallen out of touch with technology
  6. Any type of monitoring system
  7. Vulnerable people in general

So that would be from a pure technical perspective.

Now, I am not an expert in mental health or vulnerable people, but I would say that the following should be included with the above which may not be considered within the definition of “Vulnerable”

  1. Older people and power outages, specifically lack of heat during winter months and subsequently an inability to communicate with the outside world.
  2. Mental health with older people, power cuts, especially in winter months, could make you feel vulnerable, isolated and cut off now that there will be no available phone service.

Any major issues we need to recap?

  1. The largest issue with this changeover is that on a fixed line broadband service, while Ofcom suggest that individuals more at risk require communication for longer than 1 hour, there is no way to actually deliver this. This is due to the mobile masts only lasting 1 hour in a power cut (some may last longer) and that if the local BT Street cabinet loses power, it does not matter how much resilience is at the vulnerable persons premises, they will not be able to dial out.

Now we will start by briefly looking at the ESN

ESN Change

ESN – This is the emergency services network, essentially the communication used by emergency service providers when out and about.

Currently this operates on the Airwave Network, but from 2020 there is a phased roll out plan to move this to EE 4G.

In the current mobile infrastructure, if we take call routing as an example

  1. Consumer calls are the lowest priority
  2. 999 calls take precedence over consumer calls

Theory being, that if you take an event like New Years Eve, the mobile network is busy, flooded in fact, but if someone dials 999, it should in theory disconnect a consumer call to make space for the emergency call.

It has always been difficult to find this documented as fact, there is a lot of opinion though.

When Airwave moves to EE 4G, we are expecting that on the infrastructure, Emergency Services communication takes precedent over consumers.

So if you take an event like the London Riots, we wouldn’t expect any non-emergency consumer calls to be able to connect from a capacity perspective.

However, we don’t currently know how a 999 call fits into this.

Now the other thing we don’t know about the EE 4G change is how this impacts the masts, it could be that it means for contingency we have a solution, as currently Airwave lasts 7 days in a power outage, if the EE masts are going honour the same principle, then we potentially find that our solution to most problems will be to drop landlines and look for suitable mobile replacements. At the very least, we would hope that 999 calls will route.

If you recall from previous articles, mobile phone masts will currently only last 1 hour in a power cut, some may last for 4 hours.

However, when a piece of equipment loses mains power and moves to back up power, the dynamic of how that equipment works can change. So it could be that the masts when losing mains power only allow the Emergency Services access to the resilient network to preserve power.

In that case, we go back to having no solution to our issues, including 999 calls and the other services we rely on that do not route to 999, which are the 7 points listed towards the start of this article.

So this Emergency Services Network Change and the Continuity with Emergency services during a power outage (change from PSTN to VoIP) are being dealt with as isolated issues, whereas if we join these issues, we have the potential to build a robust infrastructure that has contributions from both the consumer market and the tax payers money (Emergency Services Contributions) which would actually reduce our costs of running the emergency services.

ESN – Current Queries

04/01/2019 – We recently contacted the home office to gain further information around how the new ESN infrastructure is expected to work in a power outage. Initially we are querying the resilience to see how long the network is expected to last in a power outage.

If the number of days that this is intended to last is suitable, we will then query our other concerns around capacity and how the network will operate during a power outage.

Expected Response – The auto response from Home Office enquiries email states 20 working days, 04/02/2019

Response – No response was ever received under the freedom of information act.

Ofcom Supporting Data

The guidance in question is ‘Protecting access to emergency organisations when there is a power cut at the customer’s premises’

There is the after consultation document which has all concerning parties feedback, this is much longer but in short, it did not change the outcome of the guidance, so you can read all of that document, but this one is cleaner and easier to read.

In our other articles, for defining our solutions we looked at some of the information available, essentially to define that for the vast majority of individuals, a VoIP landline offers no benefit of any kind.

Now in this article we will be focusing specifically on supporting evidence for why 1 hour is sufficient within a power cut from this statement

‘We consider that one hour’s protection represents an appropriate minimum level of
protection in most cases given that the average length of a power cut is less than one

Along with this table

ofcom data

Now this relates to an Ofgem report, first off, we know this much

  • These are simply percentages with no values to identify what the percentages related

What we don’t know is

  • Total number of customers impacted (e.g. 72 out of 100 experience a power cut each year)
  • Total number of UK premises this data relates to

So without either of these, the data is meaningless because we cannot work out

  1. How long an average power cut lasts (so if we take an 11 hour power cut and a 1 hour power cut, the average power cut would be 6 hours)
  2. How many people are impacted for each category

The other issue we have from this alone is that it isn’t possible to average the percentages over the year when the base value of residential premises is a large number. So where this table has 0% for power outages over 12 hours, we would expect that this is not 0 premises, but rather a rounded percentage. So if there are 25 million UK residential premises, 1% represents 250,000 premises or close to that number.

However, we can pick an arbitrary figure that would be close to the expected amount to determine how true these statements are, because what we need to identify is the number of hours without a phone vs the number of hours with a phone in order for the statement in red above to be true.

However, the improvement of the services over time is something that we cannot consider without knowing the total number of residence in question

  1. We would expect that new premises are built on new more resilient infrastructure for the power network
  2. From this data alone, there is nothing to suggest an improvement, it could simply be that the new premises being built increase the number of short power cuts, when looking at percentages over time without a number of residence, it is possible this is the only reason the table shows an improvement.

The other larger issue we have is that this table data stops at 18 hours, we know that consumers can experience power cuts that last longer, the only source we can really find for this is tabloid media, say for the Lancaster Power Outage, ‘55,000 premises without power for 4 days or more’ was the type of statement we saw for this particular outage.

This makes accounting for this statement difficult.

High level Assumptions and Exclusions

We would assume that the risk of issues in a power cut increases in relation to how long it lasts. This can be time spent without heating, especially for the elderly, to the risk of issues with moving around in poor light, the use of other means to light your home (exposed flames for example), to the extent of something like Flooding going from a risk to your location, to an issue at your location over time or the increased risk of looting during the longer a power outage/flood event lasts (Lancaster, Themes flooding in recent years as an example).

There was some detailed analyses done on this data by Ofcom back in 2012, this was done to show that a property has on average power for pretty much the entire year, however, the way in which they did this was essentially that a power cut not occurring at one property reduces the power cut time at another property. They used a method of analyses we use in telecoms to work out the up time of a location when we have disaster recovery methods in place, e.g. Site B can handle communications for Site A, we are disregarding this analyses in its entirety as in this case Site B having power does not alleviate Site A losing power, so we cannot use that method of working out resilience (also known as ‘Five 9s’ calculations). They then concluded that this meant it would be unlikely that a call to emergency services would occur at the same time as a power outage, with no supporting evidence of this conclusion or consideration that there could be a relationship with power outages and a need for emergency services.

As the data is “Per Customer” in “100 customers”, we don’t know whether this data represents the total outages for a consumer base as a whole, or whether there is repeated data. For example, does a premises that has a 1 hour power cut and an 18 hour power cut in a year get counted twice in this, or are they represented by 1 power cut?

High level Conclusion

Based on this data alone, we can say the following

ofcom data

Since 2010 – 33-40% of residence that experience a power cut in a year, the power cut lasts more than 1 hour.

Since 2010 – 18-23% of residence that experience a power cut in a year, they will have a working phone 1 hour, no access for up to 1 hour.

Since 2010 – 16-18% of residence that experience a power cut in a year, the time the phone will not work during the power outage will be greater than the time the phone will work during the power outage. Essentially, if the power cut is greater than 2 hours, we know the phone will not work past the first hour, we will spend more time in that scenario without a phone than we will spend with a phone.

We know that we can only rely on mobile telephone solutions for 1 hour during a power outage, and that 2 million UK residence currently live in a landline only world.

Low Level Conclusions

Asserting a residential consumer base of 25 million (exact figures not known, but assumption is that 1 residential consumer for electricity is equal to 1 residential property)

Based on power outages impacting 72 customers per 100 in a year (exact figures for each year not known, this was taken from the last Ofcom document we could see reference this, 2012)

Using the year that most represents the data, 2015/2016 (as the percentages are already rounded, I cannot average the years, so I am opting for a representative year)

Year/Percentage of outages Number of premises impacted by this power cut Scenario in the year Number of hours without a working phone (Lower) Number of hours without a working phone (upper)
3 minutes up to but excluding 1 hour 67% 12.06 Million 0 0
1 hour up to but excluding 2 hours 18% 3.24 Million 0 3.24 million man hours
2 hours up to but excluding 3 hours 6% 1.08 Million 1.08 million man hours 3.24 million man hours
3 hours up to but excluding 6 hours 6% 1.08 Million 2.16 million man hours 6.48 million man hours
6 hours up to but excluding 12 hours 3% 540,000 3.24 million man hours 6.48 million man hours
12 hours up to but excluding 18 hours 1% 180,000 2.16 million man hours 3.24 million man hours

So, we can say that on this infrastructure 180,000 individuals will be without a phone for 11-17 hours each, with the first 1 hour being supported by the VoIP solution.

If we can consider that these individuals are ‘at risk’ during this time, and there is an increased likelihood of an event that requires communication with the outside world, we can say that 180,000 individuals are exposed for 2.16 – 3.24 million hours per year as far as our combined infrastructure goes i.e. would this indicate an added issue in relation to emergency services?

Is this conclusion relevant?

Nope, at least not as relevant as it should be.

So the individual numbers exposed are certainly relevant, 180,000 individuals on an assumed user base would be exposed to an at risk scenario for an extended period of time greater than 12 hours, we could argue that just shy of 2 million individuals are exposed for an extended period of time greater than 6 hours. We don’t expect them all to require emergency services during this time, but we do expect them to require some form of communication.

We can also say that an unknown quantity of individuals experience a power cut greater than 18 hours.

The rest of it has no real standing unless we were to liaise with recognised authorities for more data, so my assumption on this data is that we are exposed to risk in a power cut, which I have no supporting evidence for.

However, as far as this statement from Ofcom being true

‘We consider that one hour’s protection represents an appropriate minimum level of
protection in most cases given that the average length of a power cut is less than one

We can see that it isn’t, disproving this statement is easily achieved with this data available because it is pretty much a supposition, assumption, there is no evidence to support this. The reason it can be disproved so easily is that, while the average power cut may be less than 1 hour, it is alluding to the fact that we need access to emergency services during a power cut.

  • So during a power loss scenario, we will collectively have 18 million hours access to the emergency services for 18 million impacted premises.
  • Within the 18 million impacted premises, 6.12 million will have up to 22.68 million hours without access to emergency services or communications
  • That is based on there being 25 million premises.
  • That is based on mobile solutions and landline solutions only being available for 1 hour.

So using their own assertion, and by viewing the data in a different way, we can see that their assertion supports our conclusion i.e. during a power cut, there are more hours without a phone than there are with a phone on the new technology.

So if we were to assume that Ofcoms data were correct and all we needed to base our conclusion on, we would on average require a solution that lasts for 2.26 hours during a power cut scenario, as on average, 1 hour would not be enough. So while the majority of power cuts are 1 hour in duration, the average power cut is not 1 hour in duration.

Yes, it is nonsense maths, but no more nonsense than the Ofcom Maths (for the 2018 and 2012 analyses on this topic). The reason it is nonsense is that is that there is no relevant supporting data for the analyses, analyses of this type without supporting evidence is not statistics, it is simply arithmetic.

Statistical Analyses in this case would require taking measurements from the model that is under study, in order to do this we would need to know specifically the volume of emergency calls that are made during a power outage and at what point the call is made from the start of the power outage.

Anything outside of this is not part of our analyses model.

So what is the true issue with this data and conclusion?

All the data, analyses and conclusions so far from Ofcom are outside of the required analyses model.

Because the analyses done in 2012 by Ofcom is so flawed and because the 2018 analyses is essentially supposition based on high level numbers, I can use this data to write or try to prove or support pretty much any conclusion I so choose. This means that I can write a conclusion, then define how the data supports that conclusion. That is actually what I did in this article and it shouldn’t be possible to the degree that it can be done.

I can re-write my methods and analyses to support Ofcoms conclusion, I can make my conclusion more solid, I can actually get another conclusion out of this that would suggest that given the extent of the power cuts, it is unlikely that this would occur during hours of poor light. Essentially, it is so high level it is useless as far as providing valuable data is concerned.

The same as we saw Ofcom do in 2012, they concluded that because a premises has power for most of the year on average, it would be unlikely that emergency services would be called in this time anyway with no supporting evidence, even though we know that individuals require emergency services during floods, looting and theft, and we know that there is a relationship between these events and lost power, or they require help or even comfort away from emergency services during a power outage.

The most important thing we know about this analyses model is that a premises not having a power cut does not decrease the length of time that an unrelated premises has a power cut (that is the issue with both the 2012 and the 2018 analyses models from Ofcom)

What are we doing next?

We have made a statement which you can view in this petition (link below)

“The current approach and guidance laid out by Ofcom has significant flaws, they are following their usual approach where the only consequence to bad decisions is monetary, however, in this scenario the consequence to this change being handled badly can be injury, reduced quality of life or death i.e. unable to contact emergency services when it is needed most.”

Now we feel that the only thing our current analyses proves is that this statement is accurate, because the approach by Ofcom is poor, the consequence to this being handled badly is not part of their usual remit i.e. this will have the potential to result in loss of life. This is simply proven by virtue of no relevant analyses being done by Ofcom and no supporting evidence to their statements. We can also use their analyses and guidance, both high level from 2018 and detailed from 2012, in order to prove that all the statements they are making are not supported by evidence.

We are also in the process of creating letter templates for people to use to their local MPs or The Prime Minister.

Main Priorities

Ensuring that methods of access actually work (which VoIP over fixed line broadband will not offer)

Ensuring that methods of uninterrupted access for vulnerable individuals actually work (Which VoIP over fixed line broadband will not offer, largely due to BT Street Cabinet considerations)

Ensuring that consumer advice, market guidance, technology guidance and industry guidance actually benefit the customer (VoIP over landline does not offer benefits over other more robust solutions which can be attained for the vast majority of consumers at no extra cost, in fact, you can attain more contingency and reduce current costs by avoiding landline solutions in their entirety, you can read more of that on this page 10 Reasons Why You Shouldn’t Get a VoIP Landline In Your Home)

Ensuring that specific questions for identifying ‘at risk’ individuals are regulated.

Ensuring that specific solutions for ‘at risk’ individuals are defined and regulated.

Ensuring that USO grade services are delivered, and that required technology to remote areas is suitable (Satellite Broadband)

You can read up about this in more detail on this page PSTN switch off and what it means to you or to see some other outlying issues around the change in technology, you can see an example of education requirements needed on this link Dial Tones – An important thing people don’t know about

Thanks for reading, and don’t forget to sign and share our petition