Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

Transcription

1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC In the Matter of ) ) Technology Transitions ) GN Docket No ) AT&T Petition to Launch a Proceeding ) GN Docket No Concerning the TDM-to-IP Transition ) COMMENTS OF THE ALARM INDUSTRY COMMUNICATIONS COMMITTEE The Alarm Industry Communications Committee ( AICC ), on behalf of its members 1 hereby files comments on the AT&T Proposal for Wire Center Trials, filed on February 27, 2014, in which AT&T proposes trials to transition from TDM-based service to Internet Protocol (IP) services for wire centers in Carbon Hill, Alabama and Kings Point, in Palm Beach County, Florida. As shown herein, AT&T's proposed trials fall short in three areas and require modification. First, AT&T's trial should not be approved at this time because one of its proposed service alternatives to TDM voice service does not allow alarm or Personal Emergency Response System (PERS) services and AT&T has not explained how its other alternative services meet the high technical standards necessary for alarm and PERS life safety applications. Second, AT&T's trials do not contain sufficient notifications to consumers and alarm service 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 LLC., 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 providers. Third, the trials do not contain adequate measures to evaluate their success. To correct these deficiencies and ensure the adequate protection of consumers, AICC urges the Commission to require AT&T to make the modifications identified in these comments before approving the trials. Introduction 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 increasing number of residences and their occupants from fire, intruders, and carbon monoxide poisoning. Alarm companies also provide PERS for obtaining medical services and ambulances in the event of medical emergencies. The majority of alarm customers still rely on TDM-based telephone service as their underlying communication service and a majority of customers of PERS service are connected by TDM-based telephone service. For these customers, their alarm service, in conjunction with their TDM-based service, allows necessary functions like line seizure and the detection of a loss in communications path and tone messages sent by the alarm panel are properly encoded and decoded. In addition, because the TDM-based network was engineered to be highly reliable, with quality of service standards and with an independent power source, traditional TDM-based communication service has provided alarm customers with a highly reliable service that they have come to expect and rely on. 2

3 Some alarm customers have already replaced, either knowingly or unknowingly, their TDM-based service with IP-based services and, as a result, alarm companies have experience in identifying and resolving problems and issues that arise when a customer's TDM-based service is disconnected and an IP service alternative is used in connection with alarm services. For example, broadband providers have bypassed the line seizure function when installing broadband service, which prevents alarm signals from being transmitted to the alarm monitoring station. Some IP services do not properly encode and decode alarm signals or may do so on an inconsistent basis. Most IP services do not have sufficient back up power at the customer premise and broadband networks do not have sufficient back up power throughout the network to ensure operation during emergencies. Some broadband providers make periodic and sometimes automatic changes to various technical parameters of their service, like compression, without notification, which impacts the functioning of alarm services. These issues are not insurmountable and the alarm industry has had various degrees of success in working with communication service providers to address them. Further, at this time, consumers can avoid these problems because a reliable TDM-based service is available when IPbased service is not sufficient. However, this will not be the case during AT&T's proposed trials and, ultimately, if AT&T is allowed to discontinue TDM-based service nationwide. Therefore, it becomes even more important that IP-based services meet certain minimum requirements and that those requirements include consistent and measurable delivery of service for alarm equipment signal transmission. In short, to ensure that consumers continue to maintain the valuable life safety services they rely on during the trial (and beyond), the communication services intended to replace TDMbased service must meet certain technical criteria equivalent to TDM-based service. In addition, 3

4 in order to make an informed decision about whether to participate in the trials, consumers must receive adequate notification of the affect a different communication service may have on their alarm services. Further, in order to ensure that the installation of IP-based service does not disrupt alarm service and in order to evaluate the impact of the change on alarm service, alarm companies must be notified when the underlying communication service is changed. The specific modifications to AT&T's proposed trials that are necessary to meet these criteria and to ensure that consumers' life safety services are maintained follow. AT&T s Proposed TDM-Replacement Services Must Meet Minimum Technical Requirements In its trials, AT&T states that it will replace TDM-based services with AT&T's U-verse Voice service, AT&T's U-verse High Speed Internet services, and AT&T's Wireless Home Phone service and Wireless Home Phone and Internet service. Consumers in the trial areas, however, will not have access to all of these alternatives and, in some cases, consumers will have access only to Wireless Home Phone service. According to AT&T, Wireless Home Phone currently does not support certain services, including alarm monitoring and medical alert services. AT&T states that it is working on enhancements to this service so that it is compatible with alarm services. However, AT&T has provided no details on what those enhancements will entail or when they will be available. Accordingly, AT&T's trial should not be approved until the enhancements to Wireless Home Phone have been made and alarm companies have had an opportunity to test the service to ensure that it supports alarm services. In addition, AT&T's filing does not explain how its proposed trial services meet the National Fire Protection Association fire code standard in NFPA 72, which contains certain requirements that managed facilities-based voice networks (MFVN), like AT&T U-verse, must meet to be an acceptable method for fire alarm signaling transmission from a protected premises 4

5 to a supervising central monitoring station. The current edition of NFPA 72 was specifically developed in recognition of changes in traditional telephone company networks, the evolution of digital communications technologies and the provision of service by entities other than regulated telephone companies to set standards to be followed by MFVNs equivalent to traditional TDMbased service. The NFPA 72 standards for MFVNs are intended to ensure that their services meet the rigorous quality assurance, operational stability and consistent features that were the hallmarks of the traditional networks operated by telephone companies. Pursuant to NFPA 72, a MFVN service should be functionally equivalent to traditional TDM-based telephone service provided by authorized common carriers with respect to dialing, dial plan, call completion, carriage of signals and protocols, and loop voltage treatment. In addition, MFVN must provide a number of features, including 8 hours of standby power supply capacity for MFVN communications equipment located at the protected premise or field deployed and 24 hours of standby power supply capacity for MFVN communications equipment located at the communication service provider's central office. The state of Florida incorporated many aspects of NFPA 72 into its fire code. 2 Qualified MFVNs meeting the code standards are allowed for fire alarm monitoring in the state of Florida. 2 See, 69A F.A.C. (effective Nov. 1, 2009). Among other things, the Florida Administrative Code provides that a MFVN is a physical facilities-based communications network that : (a) Is managed and maintained by the service provider to ensure service quality and reliability from the service subscriber location to the point at which a call is transferred or handed off to another MFVN peer network such as the public switched telephone network (PSTN), defined as a single or an interconnected collection of local, long distance and international phone companies; (b) Conforms to all relevant PSTN standards with respect to: 1. Dialing, 2. Dial plan, 3. Call completion, 4. Carriage of alarm signals and protocols, and 5

6 Conversely, to the extent AT&T's proposed trial services do not meet the standards adopted in the Florida Administrative Code, they would not be allowed for fire alarm monitoring in Florida. It appears that AT&T's U-verse service meets some of the requirements in NFPA 72 and the Florida Administrative Code, but not others. For example, it is AICC's understanding that U- verse customer service equipment is provided with only four (4) hours of back-up power and not the required eight (8) hours of back-up power. It also is AICC's understanding that U-verse can be installed to preserve the integrity of digital alarm communicator transmitter (DACT) formats, to allow the DACT to seize the connected telephone line, dial the digital alarm communicator receiver, and transmit signals indicating a status change in the alarm (i.e., an intruder or a fire). However, it is not clear that AT&T will ensure that this format integrity and installation requirement is preserved with any software or hardware changes to U-verse. It also is AICC's understanding that AT&T wireless services have no provision for line seizure. Accordingly, AT&T should explain how its proposed trial services comply with the Florida Administrative Code, NFPA 72 and any other requirements in the Florida and Alabama codes that apply. Further, to ensure that AT&T's TDM-replacement services do not interfere with existing services and equipment relied on by consumers (i.e. alarm services, fax), AT&T's TDMreplacement services should be tested with such devices before the trials are authorized. AT&T first should conduct a survey of stakeholders to get lists of specific device models that may be 5. Loop voltage treatment; (c) Provides real-time transmission of voice and real-time transmission of signals that carry alarm industry standard alarm formats unchanged; (d) Preserves primary line seizure for alarm signal transmission; (e) Provides a method of electrical power backup such as a battery that provides a minimum of 8 hours of continued uninterrupted voice service availability to the attached alarm system, and (f) Provides disaster recovery plans to address individual customer outages and network power restoration procedures. 6

7 affected by the trials, and conduct lab testing with a representative suite of the devices, including alarm panels, PERS, and medical monitors. AT&T also should be required to disclose the network interface requirements they are designing in connection with the TDM-replacement services, including, the compression used, bandwidth, protocols used, timing, battery, so that customer premises equipment makers can perform their own evaluation of the services. As indicated, because consumers will no longer have traditional TDM-based services to fall back on, if necessary, these tests need to be performed in advance of the trial. In addition, AT&T should be required to maintain the network interface requirements used during testing throughout the trials (and also when AT&T moves to wide deployment) to ensure that consumer equipment, such as alarm systems, perform correctly moving forward. AT&T's Proposed Notifications Should be Modified Although AT&T proposes a number of outreach efforts and notifications to customers and local government officials in connection with the trials, AT&T's proposal in this regard is not sufficient. As an initial matter, AICC urges the Commission to require prior approval of all letters and notifications to be sent to customers concerning the trials. It appears that AT&T includes some sample customer letters in the confidential version of its proposal and AICC urges the Commission to require AT&T to file them as public. It appears that AT&T offers no support for a claim that this information, which is intended to be sent to the public, should be treated as confidential. Furthermore, AICC believes this information requires public scrutiny to ensure customer notifications are complete and accurate, as a trial cannot be considered voluntary if the trial participant does not have full knowledge. Among other things, AT&T's outreach and customer notifications should include information concerning the services that will no longer work or be available to trial participants. 7

8 They should include information regarding alarm system function and the affect a change in communication service may have on a customer's alarm service. For example, AT&T's customer letters and notifications should advise customers that the trial, in part, is assessing the impact of the change in communication service on alarm systems, whether AT&T is complying with MFVN standards and how customers can report any problems they experience after their communication service is changed to ensure data is properly collected and analyzed. AT&T also should directly provide information to consumers about the impact of power failures on its network and the customer's equipment.at&t states that it provides a description of battery backup for terminal equipment online at its U-verse Voice Support web page and other "customer-facing documents and states that the same information will be "readily available to customers of the Trial Wire Centers." 3 However, many, if not most, customers will not even be aware that power supply could be an issue, especially with respect to AT&T's network, if the information is not directly provided. In addition, although AICC does not object to AT&T's proposal referenced in Section 5.2 of AT&T's Wire Center Trial Operating Plan to indicate that the trials are being conducted under Commission oversight, it should be made clear that this is not an endorsement by the Commission of the services being offered by AT&T. AT&T also should be prohibited from using the trials and its customer communications, notifications, customer service center contacts and service plans, to market its competitive alarm products. To ensure that the alarm system continues to work properly, AT&T should advise the customer at the time of installation of broadband and/or wireless services, when available, to contact the alarm company and test the alarm system. It is important to note that there are 3 AT&T Wire Center Trial Operating Plan at 32 and 33. Information concerning the impact of power failures on AT&T's wireless network and customer equipment should be provided to customers, as well. 8

9 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. NFPA 72 requires MFVN providers, when providing service to a new customer, to give notice to the customer of the need to have any connected alarm system tested by authorized fire alarm service personnel to make certain that all signal transmission features have remained operational, including the proper functioning of line seizure and the successful transmission of signals to the supervising station. In addition to customers and government officials, AT&T should be required to provide timely notice to alarm companies and other service providers that will be impacted by the trials concerning the project rollout timelines so that measures can be taken to address issues and to provide any necessary system updates to protect against any discontinuation of service. AT&T should conduct meetings with the alarm industry, including AICC and the alarm companies in the affected areas, to discuss the technical parameters of the IP services that will be offered so that alarm companies can respond to any disruption in alarm service and any customer inquiries they receive in connection with the trials. AT&T's Proposal Is Not Adequate to Measure the Success of IP Services in the Trial Areas and It Will Not Have Nationwide Applicability To measure the success of the trial, AT&T proposes "to collect and report data about the progress of the trial, IP call quality and network performance, and customer satisfaction with the migration process and the new wireless/ip products. 4 However, there is no plan for collecting data around alarm monitoring and medical alert customers to ensure services are properly 4 AT&T Wire Center Trial Operating Plan at 3. 9

10 transmitting and receiving signals with monitoring centers. Relevant data measurement and collection points around legacy alarm and alert system function should be incorporated into the trial. Further, AT&T's plan to track customer complaints to determine customer satisfaction is not sufficient for alarm services because the customer may not know that his or her alarm is not functioning properly until there is an alarm event and emergency services are not dispatched. The alarm industry should be included in the trial process, as described in these comments, to measure customer impact. In order for alarm companies to determine and measure the impact on their customers, they would need information about the alarm customers participating in the trials, such as the customer telephone number, or the exact zip codes and the phone number prefixes (NPA NXX) for the trial areas. AT&T also should provide dedicated customer service numbers, with dedicated, specially trained personnel to handle complaints and inquiries from customers to properly collect data on the trials. In addition, AT&T should provide a contact for alarm companies and other service providers or manufacturers that have an issue with the trials, as general customer service numbers usually require the caller to validate a premise number before taking an inquiry or complaint. Finally, AT&T's proposed trials fall short of its goal of identifying and resolving the operational, technical and other issues that could arise when existing TDM-based networks and services are discontinued nationwide. On the contrary, AT&T's limited trials based on only two locations with relatively few customers, neither of which are representative of the nation or the typical alarm customer, will not have nationwide applicability. 10

11 Conclusion AICC and the alarm industry believe that IP-based services have the potential to provide benefits to customers, including alarm service customers. However, these benefits will be fully realized only if IP-based servicess are equivalent in quality, reliability and operational stability to the traditional TDM-based to AT&T's trials outlined herein, will help to ensure that alarm customerss benefit from and are not hurt by, the trials. Accordingly,, AICC urges the Commission to require AT&T to modify its proposed trials are discussed herein. networks and services historically provided by telephone companies. The modifications Respectfully submitted, ALARM INDUSTRY COMMUNICATIONS COMMITTEEE Louis T. Fiore Chairman Alarm Industry Communications Committee Dated: March 31,