January 3, 2012

 

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Ken,

Some quick comments:

Congress is attempting to auction off spectrum to gain funds to offset the deficit. Additional Public Service is attempting to gain access the 10 MHz at the 700 MHz Band to set up a nationwide Public Service Broadband network. Additional, inserted in this bill is an attempt to expand services for 911 centers, called Next Generation 911. While other versions of the many, recent Spectrum Bills in Congress involved our frequencies, this bill seems to spare us on that front, but opens up another front.

AICC has been working with the FCC to educate them that of the dangers of alarm sending signals to 911 directly to 911 without the "intervention" of central stations. First the FCC issues an NOI (Notice of Inquiry) to industry floating the idea and asking for comments. We worked with APCO, the Police Chiefs, Fire Chiefs and Sheriffs associations on a coordinated response. Despite our efforts, the FCC then issued a NPRM (Notice of Proposed Rule Making) asking for comments. Response to that is due December 12.

In a sort of side move, the FCC language appeared in a version of the Spectrum Bill last Thursday. We immediate began lobbying efforts - educating Congressional staff about the dangers of this move.

Supposedly, if this becomes law, the FCC would have the authority to go ahead.

You should know about AICC. We are a self-funded committee under CSAA and are a group of 38 companies and associations who have interest in alarm communications. In some form, we have been around since 1969. Among our members are CSAA, ESA, SIA, ADT and other major companies and virtually all the manufacturers who manufacturer alarm equipment. We retain a law firm and a lobbyist in Washington, DC. I have had the privilege of being its chairman for 18 years. We meet quarterly in Washington, DC with conference calls as needed.

As we see it, if this is allowed to proceed, we can see entities creating security devices able to communicate directly with 911, using text messaging and the Internet, bypassing central stations. The 911 centers will quickly be overwhelmed. I see this as an industry-wide issue, affecting the the burglar alarm and fire alarm industry (central stations and dealers) and the PERS providers. In my view, this could be the most detrimental issue to hit us for some time.

You will find information on AICC on the CSAA website. Please let me know if you need any additional information.

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The Alarm Industry Communications Committee is following recent events in Congress regarding the spectrum bill and has realized that there is a major problem with the 9-1-1 Implementation portion of the spectrum bill as adopted by the House Energy and Commerce Subcommittee on Communications and Technology on December 1, 2011 regarding the sending of automatic signals to 911 centers. The problem could well result in 9-1-1 operators being flooded with automatic sensor generated calls, potentially from security devices, as well as Personnel Emergency Response System (PERS) calls. The alarm industry which currently screens these calls before they are forwarded to 9-1-1 centers knows from experience that the vast majority of these calls from burglar and fire alarm systems as will has from PERS systems do not require dispatch.. Regarding PERS, the overwhelming majority of calls (99%) do not require the dispatch of emergency services. In many cases the senior is seeking just to talk with someone. Currently the alarm industry screens all these calls before they are sent to the 9-1-1 operator to determine whether emergency services need to be dispatched. On an annual basis we screen over a 100 million calls.. Of that, we can resolve in the high 90 percentile.

Based upon the language of the Subcommittee bill under (e) (4) (B) definitions of an emergency call "nonhuman-initiated automatic event alerts, such as alarms, telematics, or sensor data, which may also include real-time voice, text or video communications.", we believe that sensor driven calls to the 9-1-1 center will render them unable to respond to real emergencies.

While we understand that the Subcommittee wants to allow texting as an adjunct or replacement for voice, based upon how the bill is drafted, sensors could be installed that would result in emergency signals being sent directly to the 9-1-1 center without verification. This would flood 9-1-1 operators with calls. Imagine how many calls to 9-1-1 centers would have been generated if sensor driven calls were allowed during the recent Virginia earthquake this past summer. We also are concerned that Personnel Emergency Response Systems (PERS) will be set up to send messages directly to the 9-1-1 center. Currently, there is no technology that would enable 9-1-1 centers to electronically screen out such calls. We know from past experience of some 20 years ago, that companies devised systems whereby a homeowner or business owner could repeatedly send emergency messages using tape dialers directly to police and fire dispatchers. Police and fire services around the country had to pass laws to ban the practice because it was crippling their ability to field real emergency calls. With today's technology one could easily put a sensor into an alarm system which would directly dial, text or communicate over the Internet to 9-1-l centers.

The AICC is concerned that the FCC would use this authority to move forward with their desire to allow sensor driven calls to 9-1-1 centers unless Congress changes the existing language in the bill.

You are urged to IMMEDIATELY contact your Congressman and Senators especially senators, since the Senate is probably the only place at this point in time to stop this.

We have drafted language to address this issue:

Under (5) (B) which addresses Next Generation 9-1-1 services The term 'Next Generation 9-1-1 services' means an IP-based system comprised of hardware, software, data, and operational policies and procedures that”

 

"(B) processes all types of emergency calls, including voice, manually initiated text messaging, data, and multimedia information, provided that any data messages must be verified before being sent to the Public Service Answering Point."

 

Possible report language:

To minimize the danger that PSAPS may be overwhelmed by false or unintentional emergency communications, device initiated data must be verified before being sent to a PSAP.

 

Lou Fiore

Chair

Alarm Industry Communications Committee