To: Alarm Industry Communications Committee

To: Alarm Industry Communications Committee

From: Benjamin H. Dickens, Jr.

Mary J. Sisak

Re: Wireline Report

Date: September 10, 2013

AICC Provides Further Comment on ONA and CEI Requirements

AICC filed comments and reply comments (attached hereto) in the FCC’s proceeding examining whether the RBOCs should continue to be required to comply with Open Network Architecture (ONA) and Comparably Efficient Interconnection (CEI) requirements. By imposing “level playing field” requirements on the RBOCs, the ONA requirements protect the alarm industry and other enhanced service providers (ESPs), like the voice mail industry, dependent upon BOC transmission facilities, from unfair practices.

In a Further Notice of Proposed Rulemaking(FNPRM), the FCC soughtto obtain data that would support eliminating CEI requirements and streamlining or eliminating the ONA requirements. Among other things, the FCC sought comment on the “continued viability of the substantive CEI and ONA narrowband requirements”and on how the FCC could “simplify and modernize efficient access to service elements that competitors still need while at the same time eliminating services that are no longer necessary.” The FCC also sought comment on how to efficiently review requests to reduce or eliminate ONA service offerings that are included in the BOCs’ ONA plans and tariffs, while ensuring that enhanced service providers (ESPs) who rely on ONA services receive notice and are able to provide comments on discontinuance applications.

AICC Files Reply Comments on Proposed Trial Runs to Replace TDM Service

AICC filed reply comments (attached hereto) in response to the FCC's Technology Transitions Policy Task Force’s request for comment on proposed trials to gather data related to the ongoing transitions from time-division multiplexing (TDM) to internet protocol (IP) services. AICC urged the FCC to require trial participants to meet a number of specified criteria, including compliance with the National Fire Alarm and Signaling Code, to ensure the protection of alarm service customers before a trial is authorized. AICC also argued that customers and alarm providers must be notified before any trial is authorized and that after authorization, the trialparticipant must notify customers and alarm companies well in advance of the discontinuance ofTDM-based services. Finally, AICC argued that a trial must be reversible if it is not successful.

AICC Opposes Verizon’s Request to Discontinue POTS Service in Parts of NJ and NY

AICC filed comments at the FCC (attached hereto) opposing Verizon's request to discontinue, pursuant to Section 214 of the Act, 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 argued that Voice Link is not a reasonable substitute for POTS service over copper facilities because it is not compatible with alarm services or medical alert systems and it will not provide reliable and timely access to E911 service. 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. AICC also stated that Verizon's application is premature in light of the ongoing proceeding before the New York Public Service Commission (NYPSC). Finally, AICC opposed 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.

Subsequently, the FCC released a Public Notice stating that Verizon’s request to discontinue service would not be granted automatically. The FCC also required Verizon to respond to a number of interrogatories concerning its proposal and the impact on customers.

FTC Takes Enforcement Action Against Internet-connected Consumer Device

The Federal Trade Commission (FTC) took enforcement action against TRENDnet after a hacker gained access to video feeds of private homes through the SecurView home security camera, and posted them online. SecurView is used by consumers for security and baby monitoring. According to the FTC, TRENDnet failed to secure the product, which allowed a hacker to gain access to private video feeds from customer homes. As part of a settlement, TRENDnet agreed to notify users of the security problem, help users secure their devices, and submit to independent security audits every two years for the next two decades.

1