Before the Federal Communications Commission Washington, D.C

Transcription

1 Before the Federal Communications Commission Washington, D.C In the Matter of ) ) Section Application of Verizon New ) WC Docket No York, Inc. and Verizon New Jersey, Inc. ) ) For Authority Pursuant to Section 214 of the ) Comp. Pol. File No Communications Act of 1934, As Amended ) To Discontinue the Provision of Service ) COMMENTS OF THE ALARM INDUSTRY COMMUNICATIONS COMMITTEE The Alarm Industry Communications Committee ( AICC ), on behalf of its members 1 hereby files comments opposing Verizon's request to discontinue certain domestic telecommunications services in parts of New Jersey and New York affected by Hurricane Sandy and to replace the existing wireline network with a wireless service called Voice Link. AICC opposes Verizon's application because it intends to replace traditional wireline service with Voice Link, which does not offer customers all of the functionality or reliability of traditional wireline service, including the ability to use alarm services and medical alert systems. AICC believes that Verizon's application is premature in light of the ongoing proceeding before the 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 New York Public Service Commission (NYPSC). AICC also opposes Verizon's proposal to "grandfather" customers using copper facilities only until such time as those facilities need repair in the future, at which time their service will be discontinued. As shown herein, the Commission should deny Verizon's request. 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. The alarm industry works hand in hand with the public safety community, including Public Safety Answering Points and police and fire departments, to focus government resources on actual, verified emergency situations. As AICC has demonstrated in other proceedings, the majority of alarm customers still rely on plain old telephone service (POTS), and the underlying copper infrastructure, as their underlying communications service. 2 Simply put, POTS and the underlying copper infrastructure provide the high reliability communications service necessary for alarm services. Moreover, POTS continues to operate during power outages, when consumers may be most vulnerable and in need of emergency services. 2 Reply Comments of AICC, GN Docket No , filed February 25, 2013, at pp

3 Verizon's proposed Voice Link service is not a reasonable substitute for POTS service over copper facilities. As acknowledged by Verizon, Voice Link is not compatible with alarm services or medical alert systems. Among other deficiencies, Voice Link does not adequately transmit the signals used by alarm systems and medical alert systems and it does not have sufficient back-up power. Voice Link should be properly designed to remedy these faults. Moreover, it appears that Voice Link will not provide reliable and timely access to E911 service. Therefore, Verizon's proposed service is wholly inadequate to meet the life/safety needs of the community. The Commission should not lightly allow a carrier to force consumers to a service that does not provide basic life/safety functionality. AICC also believes Verizon's application is premature in light of the ongoing proceeding before the NYPSC. The premise of Verizon's application is that existing copper facilities were destroyed by Hurricane Sandy and will not be rebuilt. However, it is not clear that this is the case as the NY PSC has allowed Verizon to use Voice Link service as an alternative to basic landline service to customers on the western portion of Fire Island on a temporary basis only. The New York PSC proceeding is continuing and it is not clear, at this time, whether all of the areas claimed by Verizon as without copper facilities will, in fact, not have copper facilities replaced. Finally, the Commission should reject Verizon's request to "grandfather" customers in the affected areas whose copper facilities are still working only until such time as those facilities no longer work. Since these facilities are still working, they were not destroyed or rendered inoperable by Hurricane Sandy and, therefore, there is no basis to include them in this petition. There also is no support for Verizon's statement that it would be impractical to repair these copper facilities in the future should they give out. On the contrary, in its notices to customers, Verizon states that it will 3

4 deploy and repair copper facilities to firehouses, police stations and other government buildings. Verizon does not explain why it is impractical to repair some copper facilities and not others. Based on the foregoing, AICC urges the Commission to deny Verizon's application. Respectfully submitted, ALARM INDUSTRY COMMUNICATIONS COMMITTEE 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) mjs@bloostonlaw.com Dated: July 29,

5 Certificate of Service I hereby certify that two copies of the forgoing Comments of the Alarm Industry Communications Committee in WC Docket No and Comp. Pol. Filed No was sent on July 29, 2013 via U.S. Mail and an additional copy via facsimile to the following: Competition Policy Division Wireline Competition Bureau th Street, S.W., Room 5-C140 Washington, D.C Attention: Carmell Weathers (202) facsimile (two copies by U.S. Mail and one copy by facsimile) Via U.S. Mail, postage prepaid, to the following: William H. Johnson, Esquire Katharine R. Saunders, Esquire VERIZON 1320 North Courthouse Road, 9 th Floor Arlington, VA By: _/s/ Kelly Laraia Kelly Laraia Blooston, Mordkofsky, Dickens, Duffy, & Prendergast, LLP 2120 L Street NW, Suite 300 Washington, DC