AICC Files Comments Opposing Streamlining and Forbearance of Section 214 Requirements

AICCLogofullcolorOn February 16, AICC filed reply comments on the Commission’s Technology Transitions Further Notice of Proposed Rulemaking (FNPRM), concerning proposed changes to the rules in connection with the discontinuance of legacy voice service. The notice addressed (1) retirement of landline copper lines and (2) replacement of legacy services (i.e., traditional Plain Old Telephone Service, also known as “POTS”) with next-generation service, such as Voice over Internet Protocol (VoIP).

AICC urged the Commission to reject the streamlining and forbearance proposals outlined in the FNPRM and in the comments of Verizon and AT&T because they are not in the public interest.

AICC argued that the process to allow carriers to discontinue voice services should not be streamlined if there are alternative providers of voice services because entities offering services over fiber, cable and wireless networks, and IP-based services, oftentimes do not provide the same quality, reliability and functionality as the TDM-based services and legacy voice services on which consumers rely.

AICC stated that to be an acceptable alternative to legacy voice service, an alternative voice service should provide the same quality, reliability and functionality as the TDM-based services on which consumers rely.  To be functionally equivalent to a TDM-based service, the new service must be equivalent with respect to dialing, dial plan, call completion, carriage of signals and protocols, loop voltage treatment, decibel loss, jitter, dual tone multi frequency (DTMF) signal performance, compression and latency.  The service should meet these standards for the entire span of the connection, even when a call is routed to an intermediate provider in the call path.  It also should include twenty-four (24) hours of standby power supply capacity for communications equipment deployed in the field and twenty-four (24) hours of standby power supply capacity for communications equipment at the central office or equivalent facility.   In addition, a substitute service must support alarm signaling from premises, including medical alert or PERS systems and the ability for an alarm provider to reach a remote alarm system and control it as necessary.

AICC stated that the alarm industry has experienced serious issues in 2016 and 2017, when alarm signals were not completed in connection with Verizon’s fiber facilities or, possibly, an alternative cable network provider. AICC also discussed how alternative providers make changes to their networks that affect service reliability and quality on a regular basis- either by changing their own network parameters, for example, with respect to compression, or by using intermediary providers that do not meet the same reliability and quality standards. AICC also noted that Verizon sought to replace POTS service with a substandard wireless alternative, Voice Link, on Fire Island, NY, which was not capable of supporting alarm services.

AICC further argued that a carrier should not be able to rely on services provided by other providers to justify the discontinuance of legacy voice services because a carrier cannot know that services provided by another provider will meet the necessary reliability and functionality standards or ensure that an alternative provider will not change its service parameters.

AICC stated that the Commission should examine alternative services, provided by the discontinuing carrier and other providers, as part of the Section 214 discontinuance process to make a specific determination as to whether each such service meets reliability and functionality standards such that the public interest will not be adversely affected by the discontinuance of legacy voice services. Accordingly, the Commission should not streamline the Section 214 process as proposed in the FNPRM and the comments of Verizon and AT&T.

AICC also opposed the proposals urging the Commission to forbear from applying section 214(a)’s discontinuance requirements to carriers seeking to transition from legacy voice services to next-generation replacement services.  AICC argued that no showing has been made, as required by Section 10 of the Communications Act, that Section 214 approval is not necessary to ensure that the charges, practices, classifications, or regulations by, for, or in connection with that telecommunications service are just and reasonable; Section 214 approval is not necessary for the protection of consumers; and forbearance is in the public interest in all such cases.  Further, AICC argued that we know that every and all alternative voice service is not an adequate substitute for legacy voice services.  Accordingly, blanket 214 forbearance is not in the public interest and cannot be granted.

AICC also argued that if the Commission is asking whether Verizon, for example, should be able to discontinue its regulated legacy interstate voice services when it offers unregulated FiOS service, such a result would not be in the public interest.  AICC argued that many alarm customers rely on tariffed, legacy voice services in connection with their alarm services.  Importantly, interstate toll free services are oftentimes used to transmit an alarm signal from the subscribers on- premise alarm system to the alarm monitoring service.  Local exchange carriers should not be allowed to discontinue access to interstate services, such as toll free services, to their subscribers of regulated voice services.

–Contributed by Mary Sisak, AICC Counsel



Missouri City, TX is Live with ASAP

On January 23, Missouri City, TX became the 33rd PSAP in the United States and the 6th PSAP in Texas to implement the Automated Secure Alarm Protocol (ASAP) service. Missouri City is operational with Guardian Protection Service, Monitronics, Protection One, Rapid Response Monitoring, Tyco, and Vector Security. ADT is scheduled to go live with Missouri City iASAP-Concept1Dn February.

ASAP benefits PSAPs by reducing 10-digit phone call volume from alarm companies; reducing 9-1-1 processing time from minutes to seconds; and eliminating errors and miscommunications from voice calls. These benefits translate to improved public safety outcomes.

For more information on ASAP or to access ASAP resources (videos, webinars, training and outreach materials), contact or 703-242-4670, or visit

TMA Member Webinar: Alarm Industry Operating Metrics – Best In Class

TMA-Signature-Webinar-logoTMA members, register now for Alarm Industry Operating Metrics – Best In Class on March 29, 2018 1:30 pm EDT and find out where your company stands in the industry. Register HERE

How does your operation measure up – what performance margins are you delivering? Join John and Chris Brady of TRG Associates to review Best in Class operating margins – central station margins, installation gross and net margins, costs to create metrics, service margins, G & A as a percent of revenues and others across the industry. We will discuss how to calculate these margins – what is included and what is not. Learn how your operation compares based upon your customer base size and mix of life safety services.

The webinar is presented at no charge exclusively for TMA members.


Amazon Technical Evangelist to Highlight TMA Technology Summit

CTOs, CIOs, Technical Directors of Monitoring Centers … Don’t Miss “Monitoring Center 2018: How to Modernize Your MTMA Tech Summit Logoonitoring Center for Omnichannel Customer Engagement”

Don’t let outdated technology hold you back!  Elevate your monitoring center, drive better business results and meet customers’ growing expectations by modernizing your facility. Learn about what types of technology (Speech Recognition for QC, text to speech, AI, etc) will help you break down your organizational silos and remove the limitations of legacy infrastructure.  Empower your operators to deliver consistent customer experiences at every touchpoint and across all channels within your organization.  Take back achievable solutions to update your infrastructure and learn about processes that are vital to support a personalized customer experience.

Join Randall Hunt, Senior Technical Evangelist and Software Engineer at Amazon Web Services in Los Angeles, for this session at TMA’s upcoming Technology Summit. Through his experienRandall Hunt Amazonces at SpaceX, MongoDB, AWS, and NASA, Hunt has dealt with a wide range of both business and technical issues across many different verticals and has a deep understanding of deploying large scale technical solutions to the cloud.

TMA Technology Summit Conference details and registration

TMA 2018 Annual Meeting Keynote Speaker Says Leaders Must Build Trust During Change

TMA is pleased to announce the keynote speaker for its 2018 Annual Meeting (October 13-17 in Palm Beach, FL). David Horsager, CEO and best-selling author of “The Trust Edge,” will present Build Trust or Die Amidst Change:  How to Build Trust, Lead Others & Grow Revenue Through Times of Transition.

“Change is constant – and the speed of business is faster than ever before,” says Horsager. “How do you build trust and keep things running smoothly during major business transitions or uncertain political climates? In this session, I’ll show leaders how times of change are the greatest opportunity to build trust and achieve business results in the face of uncertainty.”

Attendees will benefit from these key takeaways from Horsager’s presentation:

  • The single most important driver in communication during times of transition
  • How to accelerate decision making and keep momentum moving for those you lead

    David Horsager

    David Horsager

  • Why the “How” is more important than the “Why”

David Horsager, MA, CSP, CPAE is the CEO of Trust Edge Leadership Institute, national bestselling author of The Trust Edge, inventor of the Enterprise Trust Index™, and director of one of the nation’s foremost trust studies: The Trust Outlook™. His work has been featured in prominent publications such as Fast Company, Forbes, The Huffington Post and The Wall Street Journal. David has advised leaders and delivered life-changing presentations on six continents, with audiences ranging everywhere from FedEx, Toyota and global governments to the New York Yankees and the Department of Homeland Security. Get free resources and more at and

The schedule and registration information for the TMA annual meeting, which will be held at the Eau Palm Beach Resort, will be posted soon on the TMA website.



TMA Members, Interested in Tax Breaks?

TMA will present our next Signature Series Webinar, Tax Breaks for TMA Members, on Thursday, March 22 at 1:30 PM EDT. Register now at .

TMA-Signature-Webinar-logo Join TMA associate member alliantgroup for an informative session on the latest updates to powerful tax credits and incentives for companies within the security integration industry. Hear from alliantgroup’s technical director, Greg Knarr, as he walks you through the Research and Development (R&D) Tax Credit and why it applies to you, the latest changes to the tax code from the IRS and how you can qualify for these exciting credits and incentives. To date, alliantgroup has helped security companies uncover more than $73 million in credits and cash refunds.

The webinar is offered exclusively and at no charge to TMA members.