Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

Transcription

1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC In the Matter of ) ) AT&T Petition to Launch a Proceeding ) Concerning the TDM-to-IP Transition ) GN Docket No ) Petition of the National Telecommunications ) Cooperative Association for a Rulemaking ) To Promote and Sustain the Ongoing ) TDM-to-IP Evolution ) REPLY COMMENTS OF THE ALARM INDUSTRY COMMUNICATIONS COMMITTEE The Alarm Industry Communications Committee ( AICC ), on behalf of its members 1 and pursuant to the Commission s Public Notice, 2 hereby files reply comments on the "Petition to Launch a Proceeding Concerning the TDM-to-IP Transition" filed by AT&T Inc. ("AT&T") on November 12, Specifically, AICC shares the concerns expressed by a number of commenters with respect to AT&T's proposal for "trial runs" that appear to involve replacement of time-division multiplexed (TDM) facilities and services with Internet protocol (IP)-based services for some part of an incumbent local exchange carrier s (ILEC s) area on a flash-cut basis. Such a proposal could significantly adversely impact customers of residential and 1 Central Station Alarm Association (CSAA), Electronic Security Association (ESA), Security Industry Association (SIA), Bosch Security Systems, Digital Monitoring Products, Digital Security Control, Telular Corp, Honeywell Security, Vector Security, Inc., ADT Security Services, Inc., AES- IntelliNet, Alarm.com, Bay Alarm, Intertek Testing, Security Network of America, United Central Control, AFA Protective Systems, Vivint (formerly APX Alarm), COPS Monitoring, DGA Security, Security Networks, Universal Atlantic Systems, Axis Communications, Interlogix, LogicMark, Napco Security, Alarm Detection, ASG Security, Security Networks, Select Security, Inovonics, Linear Corp., Numerex, Tyco Integrated Security, FM Approvals, the Underwriters Laboratories, CRN Wireless, LLC and Axesstel. 2 See, Public Notice (Pleading Cycle Established on AT&T and NTCA Petitions), DA , released December 14, 2012.

2 business alarm services. As shown herein, at a minimum, clear standards to protect alarm services customers must be part of any trials allowed. Specifically, IP services must have at least eight (8) hours of power back up; they must have the ability to send alarm signals undistorted; they must allow for line seizure, or its equivalent; and they must provide the alarm services provider the ability to see if the broadband connection is lost. AICC member companies protect over 30 million residential, business and sensitive facilities and their occupants from fire, burglaries, sabotage and other emergencies. Protected facilities include government offices, power plants, hospitals, dam and water authorities, pharmaceutical plants, chemical plants, banks, schools and universities. In addition to these commercial and governmental applications, alarm companies protect a large and ever increasing number of residences and their occupants from fire, intruders, and carbon monoxide poisoning. Alarm companies also provide medical alert services for obtaining ambulances in the event of medical emergencies. In this regard, the alarm industry works hand in hand with the public safety community to focus government resources on actual, verified emergency situations. Under AT&T's proposal, ILECs would submit proposals for specific wire centers where the trials to replace TDM facilities would be conducted. In these areas, the Commission would implement reforms to facilitate the migration of end-user customers from legacy TDM services, such as plain old telephone service (POTS), to IP-based services. If adopted, AT&T's proposal also would allow service providers to notify customers that TDM services will no longer be available after the transition to IP-based services. Although the underlying communications services utilized by customers in connection with alarm services include wireline broadband services, the majority of alarm customers still rely on POTS as their underlying communications service. Virtually all customers of Personal

3 Emergency Response Systems (PERS) are connected by POTS. The most significant concern with AT&T s proposal is the alarm monitoring service will no longer operate for customers who rely on POTS as the communications service over which their alarm services ride if their POTS service is disconnected. This problem arises because of two major issues: line seizure and the inability of IP services to appropriately encode and decode the tone messages sent by alarm panels. Line seizure allows an alarm panel to seize control of a phone line if alarm signals need to be transmitted to a monitoring center. When installing broadband service, some providers of VoIP-based telephony do not take line seizure into account and bypass the line seizure device, rendering it inoperable. Consumer conversions to VoIP-based digital telephony systems can cause the same problem if the correct practices are not followed. Customers' alarm monitoring services also may not operate when their POTS service is replaced with IP services if the IP services do not appropriately encode and decode the tone messages sent by alarm panels. In recognition of this problem, the National Fire Protection Association (NFPA) created a standard, which was inserted into the National Fire and Signaling Code (NFPA 72), to be followed by Managed Facilities Voice Network systems such as Verizon FiOs, AT&T U-Verse, and digital voice services of cable companies, to give alarm companies and their customers equivalent service. If the providers of IP services do not follow the NFPA standard, alarm signals may not be transmitted to the alarm monitoring central office during a fire or security event, thus placing the customer in jeopardy. To ensure that the alarm system continues to work properly, AICC s members have advised their customers to notify the company and to test the alarm system if the customer migrates to broadband or VoIP service. However, the broadband provider, at the time of installation, also should advise the customer to contact the alarm company and test the alarm

4 system to ensure that the customer receives this important information when he or she is most likely to pay attention to the warning. It is important to note that there are millions of installed alarm devices in homes and businesses that cannot automatically detect if the line seizure feature has been disconnected or bypassed. In this circumstance, the first time a customer may realize his or her alarm service is not working properly may be when there is an emergency situation and the appropriate emergency service personnel are not dispatched to the premise. AICC and its members are well acquainted with these problems as they have been occurring on a regular basis ever since customers have voluntarily started to migrate their communications service to broadband. For example, where the broadband provider has bypassed the line seizure feature or the IP service distorts the signal and the alarm company must change to a different format or alarm panel at the customer premise, the alarm company must make a service call to the customer s premise to properly reinstall the customers alarm service. In most cases the alarm company can manage the situation because it affects only a few customers at a time. However, under AT&T s proposal, the possibility exists that a large number of alarm customers would lose their POTS service at the same time, in which case, the alarm company may not be able to properly test and reinstall, if necessary, the alarm services for all affected customers with no disruption in the provision of alarm services. The need for a service visit also could impose a significant cost on alarm customers and companies. Further, at the end of the trial, if customers are then switched back to POTS, these issues would arise again. AICC and its members also have concerns with AT&T's proposal because IP-based services may not provide the same quality of service and standard of reliability and survivability as the public switched telephone network (PSTN) and POTS. Users of security and fire alarm systems installed over the last 30 years have depended on the PSTN and POTS to deliver with

5 certainty, alarm signals to a centralized location where professional staff monitor the alarm signals and dispatch appropriate first responders as needed. This reliance on the PSTN for life safety applications is a direct result of the PSTN being engineered to assure a high probability of call completion twenty-four hours a day, seven days a week. It is not clear that broadband networks and IP-based services have a comparable quality of service. Two components of broadband networks that affect their reliability and survivability are their redundancy and power supply. It is not clear that all broadband networks have sufficient redundancy to remain operational when equipment and software are upgraded. Power back-up for broadband networks and customer equipment, which, unlike POTS, is not powered by the central office, is also a concern for AICC and its members. To address this issue, the National Fire Alarm Code, which was developed by a consensus group composed of many diverse stakeholders, including major broadband network providers such as AT&T, under the direction of the National Fire Protection Association, established a back-up power requirement of eight (8) hours. However, it is AICC's understanding that AT&T's U-verse customer service equipment is provided with only four (4) hours of back-up power. It would be of concern to AICC and its members if their customers are forced to transition from POTS, an extremely reliable service which operates even during power outages, to a service that does not even meet the National Fire Alarm Code standard, at a minimum. Finally, in addition to at least 8 hours of power backup, IP service providers should provide the ability for alarm service providers to see if the customer s broadband connection is lost.

6 Based on the foregoing, AICC urges the Commission to ensure that any "trial runs" it may allow do not adversely affect the alarm services of customers. At a minimum, any trials must be conducted in a manner that ensures alarm services remain operational at all times and that the service quality, reliability and survivability of the alarm customer's communications are not degraded. Respectfully submitted, ALARM INDUSTRY COMMUNICATIONS COMMITTEE Dated: February 25, 2013 By: /s/ Mary J. Sisak Benjamin H. Dickens, Jr. Mary J. Sisak Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP 2120 L Street, N.W., #300 Washington, D.C., (202) office (202) fax mjs@bloostonlaw.com