AICC Fall Meeting Welcomes Members of Congress

On September 7, the Alarm Industry Communications Committee hosted its fall meeting in Washington DC and welcomed two Members of Congress with important connections to telecommunications legislation and regulations.

Rep. Susan Brooks (R-IN) currently serves on the House Energy and Commerce Committee and is a member of the Communications and Technology, the Health, and the Oversight and Investigations Subcommittees.  She spoke about disaster preparedness and Hurricane Harvey, noting that any natural disaster affects the alarm industry. She noted that the whole country needs to be connected to broadband — the lack of it is “not fair to small towns, rural areas which are struggling to survive” — and the need to rewrite the Telecommunications Act of 1996.

Later in the meeting, Rep. Greg Walden (R-OR), chairman of the Energy and Commerce Committee’s Subcommittee on Communications and Technology, addressed the AICC members primarily on the issue of Net Neutrality. AICC members noted that they are participating in the comments process. Walden said his committee is “fully committed to finding a legislative solution that takes care of bad behavior but does not suppress innovation.” He noted that reauthorizing the FCC as an agency needs to happen before the Telecoms Act can be addressed.

AICC Fall 2017 Walden Fiore Hauhn Signer

From left: TMA Executive Director Jay Hauhn, AICC Chair Lou Fiore, Rep. Greg Walden (R-OR), AICC lobbyist Bill Signer

Following the representatives’ remarks, AICC members were able to ask questions and put forward their concerns as an industry of small businesses regarding the Telecoms Act, Net Neutrality, and FirstNet.

Annual AICC Communications Survey Open Now

For the sixth consecutive year, AICC Chair Louis T. Fiore is coordinating the annual AICC Communications Survey. “The results have been used to inform regulators of our [industry] communications needs,” he says. “It only works if the response is robust. So please participate!”

This survey focuses on the percentages of monitored accounts using POTS (plain old telephone systems), VoIP digital dialers (DACT), or other technologies either as a sole method of transmission or in conjunction with another technology. The ten-question survey will take no more than a few minutes to complete. Participation is not limited to TMA or AICC members — industry-wide input will strengthen the findings. Input is anonymous and individual answers will be kept confidential.

Read Security Systems News’ interview with Lou Fiore for more information.

Find the survey at https://www.surveymonkey.com/r/R9SH7JC

Fiore will share results following the September 1 closing of the survey.

FCC Adopts NPRM, NOI, and Request for Comment on Copper Retirement, Section 214 Discontinuance and State Law Preemption

The FCC has released a Notice of Proposed Rulemaking (NPRM), Notice of Inquiry (NOI), and Request for Comment outlining proposed changes to current rules regarding copper retirement and the discontinuance of telecommunications service and seeking comment on the preemption of state laws governing the maintenance or retirement of copper facilities “to accelerate the deployment of next-generation networks and services by removing barriers to infrastructure investment.”

The FCC’s NOI addresses state laws inhibiting broadband deployment.  Comments on the NOI are due June 12 and reply comments are due July 10. 

In the NOI, the FCC seeks comment on  adopting rules that would help decrease State-sponsored impediments to broadband deployment. Most importantly for the alarm  industry, the FCC seeks comment on “whether there are state laws governing the maintenance or retirement of copper facilities that serve as a barrier to deploying next-generation technologies and services that the Commission might seek to preempt.”  As examples of rules that may be barriers to deploying next-generation technologies the FCC states that “certain states require utilities or specific carriers to maintain adequate equipment and facilities” and others “empower public utilities commissions, either acting on their own authority or in response to a complaint,  to require utilities or specific carriers to maintain, repair, or improve facilities or equipment or to have in place a written preventative maintenance program.”  The  FCC seeks comment on:

  • The impact of state legacy service quality and copper facilities maintenance regulations.
  • The impact of state laws restricting the retirement of copper facilities.
  • Whether Section 253 of the Act provides the FCC with authority to preempt state laws and regulations governing service quality, facilities maintenance, or copper retirement that are impeding fiber deployment, including whether such laws have the effect of prohibiting the ability of incumbent LECs to provide any interstate or intrastate telecommunications service and whether such laws are not competitively neutral or not necessary to preserve and advance universal service, protect the public safety and welfare, ensure the continued quality of telecommunications services, and safeguard the rights of consumers.

The FCC also asks for comment on:

  • Eliminating excessive delays in negotiations and approvals for rights-of-way agreements and permitting for telecommunications services.
  • Prohibiting excessive fees and other costs that may have the effect of prohibiting the provision of telecommunications service.
  • Prohibiting unreasonable conditions or requirements in the context of granting access to rights-of-way, permitting, construction, or licensure related to the provision of telecommunications services.

In the NPRM, the FCC seeks comment on proposed changes to the copper retirement and  Section 214 rules to discontinue services.  The comment dates for the issues raised in the NPRM have not been established.

The FCC proposes a number of revisions to the Part 51 network change disclosure rules and the rules applicable to copper retirement.  Under one proposal, the FCC would repeal Section 51.332 of the rules and return to the prior short-term network change notification rules for copper retirement.  Under this proposal,  an incumbent LEC would be allowed to retire copper facilities 90 days after FCC issuance of a public notice and without providing direct notice to retail customers.

Under a second proposal, the FCC would eliminate all differences between copper retirement and other network change notice requirements, rendering copper retirement changes subject to the same long-term or, where applicable, short-term network change notice requirements as all other types of network changes subject to Section 251(c)(5).  Under this proposal, an incumbent LEC would be allowed to retire copper facilities 10 days after FCC issuance of a public notice and without providing direct notice to retail customers.

Under a third proposal, the FCC would “retain but amend Section 51.332 to streamline the process, provide greater flexibility, and reduce burdensome requirements for incumbent LEC copper retirements.”  Among other things, the FCC seeks comment on whether the rule should be changed to require an incumbent LEC to serve notice only to telephone exchange service providers that directly interconnect with the incumbent LEC’s network and not retail customers and reduce the waiting period to 90 days from 180 days after the FCC releases its public notice before the planned copper retirement can be implemented.

Similarly, the NPRM proposes a number of measures to shorten timeframes and eliminate protections when an incumbent LEC seeks to discontinue the provision of a telecommunications service pursuant to Section 214 of the Act.  Specifically, the FCC seeks comment on:

  • Reducing the Section 214(a) discontinuance process for applications that seek authorization to stop accepting new customers for the service while maintaining service to existing customers (a.k.a. “grandfathering”) to 10 days.
  • Changing the list of eligible services for grandfathering.
  • Adopting a streamlined uniform comment period of 10 days and an auto-grant period of 31 days for both dominant and non-dominant carriers for discontinuance of services that have been grandfathered for at least 180 days.
  • Whether the FCC should conclude that Section 214(a) discontinuances will not adversely affect the present or future public conveniences and necessity, provided that fiber, IP-based, or wireless services are available to the affected community and what types of fiber, IP-based or wireless services would constitute acceptable alternatives.

Read more and submit comments.

Act by August 1: Annual AICC Communications Survey

AICC Chair Louis T. Fiore has issued a call for participation in the annual AICC Communications Survey. The results of the survey assist the AICC in planning messaging and strategy for legislative efforts involving Congress and the FCC.

This survey, now in its fifth year, focuses on the percentages of monitored accounts using POTS (plain old telephone systems), VoIP digital dialers (DACT), or other technologies either as a sole method of transmission or in conjunction with another technology. The ten-question survey will take no more than a few minutes to complete.

Survey participation is not limited to AICC or CSAA members. Industry-wide input will strengthen the findings. Input is anonymous and individual answers will be kept confidential.

Results will be presented at the September 2016 AICC meeting.

AICC: Wireless Disaster Resilience and Information Sharing Proposal

AICCLogofullcolorWireless Industry Seeks to Avoid Unwanted Regulation Following System Failures after Superstorm Sandy

On April 28, the FCC’s Public Safety and Homeland Security Bureau issued a Public Notice seeking comment on the ex parte presentation made by wireless providers AT&T, Sprint, T-Mobile, US Cellular, and Verizon, together with CTIA, in which they announce a “Wireless Resiliency Cooperative Framework” described as “a voluntary initiative that will enhance coordination and communication to advance wireless service continuity and information sharing during and after emergencies and disasters.”

In the letter, the carriers detail a five-pronged approach to enhance industry coordination to “facilitate greater network resiliency and faster restoration of service” which they assert will “obviate the need for legislative action or inflexible rules that could have unintended consequences.”  Specifically, the five prongs include: (1) providing for reasonable roaming under disaster arrangements when technically feasible; (2) fostering mutual aid during emergencies; (3) enhancing municipal preparedness and restoration; (4) increasing consumer readiness and preparation; and (5) improving public awareness and stakeholder communications on service and restoration status.  Under each prong, the carriers provide specific actions that they will undertake designed to “enhance coordination among wireless carriers and all key stakeholders, improving information sharing and making wireless network resiliency more robust.”

The Disaster Resilience Proposal is clearly an effort by the wireless industry to avoid unwanted regulation in the wake of notorious system failures after Superstorm Sandy and other recent disasters. Since many alarm companies rely on the existing cellular network for customer premise alarm radios, as well as communications with field personnel, this matter is of obvious interest to the alarm industry. Since the FCC is fond of adopting “industry consensus” proposals on thorny issues that draw a lot of public complaint (such as network outages), AICC and alarm providers should review the proposed approach to see if it is something that they can live with (or if it instead ignores the need for protecting and rapidly restoring wireless alarm operations).

Opposition comments, or suggestions on how to remedy any shortfalls in the industry proposal, can be submitted to the FCC. AICC is planning on providing feedback on this matter to the FCC by the end of June.  Please contact CSAA Counsel John Prendergast at jap@bloostonlaw.com if you have any concerns to include in such comments.

Alarm Industry’s Jerry O’Brien Laid to Rest

Jerry O'Brien funeral

Photo by Lou Fiore

Former Alarm Industry Communications Committee (AICC) Chair Jerry Michael O’Brien was buried at Arlington National Cemetery on February 29. He passed away in Tampa, FL on August 30.

CSAA Past President and current AICC Chair Lou Fiore and CSAA Counsel Ben Dickens attended the burial service. Last fall, AICC members passed a resolution in honor of O’Brien’s contributions to the alarm industry.

The following is an excerpt from the remarks given by the Chaplain, Captain Scott Foustat, at the service.

“By the time Jerry was 18, he was married, he had enlisted in the Air Force, and he soon would be a parent. Jerry’s dream was to develop, design and launch rockets, but as many of us discover, the needs of the Air Force come first, so Jerry was assigned to become an air traffic controller … not rockets, but a very reputable career path nonetheless. Jerry made the best of it, and he excelled at his job, establishing air traffic control centers all over the world, often in very remote places.

“Jerry was eventually selected for officer training, and he commissioned as an AF Officer, one of the last to do so without a college degree. While in the Air Force, Jerry and his family moved 21 times in 20 years. Jerry’s service spanned the Vietnam War, and he was awarded the Bronze Star Medal, among many others.

“Following his military career, Jerry took on various adventures, including managing a motion picture studio, representing an energy conservation business, managing API Security telecommunications, which led him to join Omnipoint-a start-up telecommunications company.

“Jerry will be remembered as a patriot, loyal friend, caring father, and beloved husband. Jerry rarely asked for anything in life (except maybe another cup of coffee), but he did have one request: to be buried at Arlington. It’s an honor for us today to grant that request!”

FCC Proposes Fines for RF Radiation Violations

By Lou Fiore, Chair, Alarm Industry Communications Committee

At our December 3, 2015 AICC meeting, AICC Counsel John Prendergast reported on FCC proposed fines for RF radiation violations on rooftops against two communications companies. This, of course, evoked concerns by some in attendance about these issues regarding the security industry’s use of cellular and private wireless data radio systems, such as AES-Intellinet, CRN Wireless and cellular devices used by the alarm industry.  This concern could be relevant at both customer locations as well as rooftops where IP links and repeaters are located.

The bottom line is that because of their low power and duty cycle, it is virtually certain that most private wireless systems provided by AES-Intellinet and CRN Wireless meet all current FCC exposure requirements for protecting the general population, company employees or roof-top service personnel.  Wireless system users should nonetheless review this matter as part of their equipment evaluation and purchase process. These data radios are compliant if used correctly, and in other cases, such as higher powered voice systems, relatively simple measures can render them compliant. Correct labeling of the radios and, for higher powered radios, proper RF warning signs can be important to guard against FCC violations.

The FCC rules require all licensees to comply with RF radiation exposure limits. These rules provide guidelines and procedures for licensees to evaluate the environmental effects of RF exposure from FCC regulated transmitters. These rules include Maximum Permissible Exposure (MPE) limits for electric and magnetic field strength and power density for transmitters operating from 300 kHz to 100 GHz. Most “premises-to-central station” wireless data devices operate in the 460 MHz private radio band and the 800 MHz and higher cellular bands, and are therefore subject to the MPE limits.  MPE is defined as the electric and magnetic field strength to which a person may be exposed without harmful effect and with an acceptable safety factor. This is the limit set in a report issued by the FCC. There are two such criteria, one for the general public and another for alarm company installers, service personnel working on these systems and other contractors that may be working near the radio antennas (HVAC, etc.). MPE is computed as the average power level against an area of skin and is shown as milliwatts per a square centimeter (mW/cm2).

Based on information provided by the equipment manufacturers, the computations below are designed to size up the compliance of most private wireless radio system equipment operating on the designated central station “offset” frequencies under the FCC rules. As always, you will want to verify the compliance of your individual system, including how it is configured, with the manufacturer and your installation vendor.

The exposure limits for cellular equipment are more complicated and will be discussed in this forum at a later time, although it is safe to assume that cellular units, installed according to the manufacturers’ instructions, should also be safe for much of the same reasons.

In 1996, the FCC adopted new guidelines and procedures for evaluating environmental effects of RF emissions. The 1996 guidelines incorporate two tiers of exposure limits based on whether exposure occurs in an occupational or “controlled” situation or whether the general population is exposed in an “uncontrolled” situation. These categories were based on an FCC Report entitled “Evaluating Compliance with FCC Guidelines for Human Exposure to Radio Frequency Electromagnetic Fields”, also known as OET BULLETIN 65.  In 2013, the FCC adopted clarifications to its RF rules, and proposed other rule changes aimed at a further tightening of these restrictions.

It should also be noted that under Rule Section 1.1307(b), a Private Land Mobile Radio Services operation is currently exempt from performing an RF compliance evaluation if it uses a building-mounted antenna, and its power is less than 1000 watts ERP.  For a tower mounted antenna, it is exempt if the power is less than 1000 watts ERP, and the antenna is more than 10 meters above ground.  The FCC has proposed to move away from these “categorical exemptions” toward a single formula to be calculated for each radio; but it is not known whether and how soon this rule change will be adopted.  It also bears mention that, if the FCC determines that a rooftop or other location is generating excessive RF radiation, stations using that location can be dragged into the compliance effort if they contribute at least 5% to the RF environment of the site, even if they were exempt from measuring RF compliance.

The two tiers of exposure are defined below:

General population/uncontrolled exposure.

 For FCC purposes, uncontrolled exposure applies to human exposure to RF fields when the general public is exposed or in which persons who are exposed as a consequence of their employment may not be made fully aware of the potential for exposure or cannot exercise control over their exposure. Therefore, members of the general public always fall under this category when exposure is not employment-related.

Occupational/controlled exposure.

 For FCC purposes, controlled exposure applies to human exposure to RF fields when persons are exposed as a consequence of their employment and have been made fully aware of the potential for exposure (and therefore can exercise control over their exposure).  This information may be provided to workers in writing and/or verbally. Occupational/controlled exposure limits also apply where exposure is of a transient nature as a result of incidental passage through a location where exposure levels may be above general population/uncontrolled limits (see definition above), as long as the exposed person has been made fully aware of the potential for exposure and can exercise control over his or her exposure by leaving the area or by some other appropriate means.  Warning signs are generally used to advise transient persons of the need to be mindful of RF exposure situations.

At the frequencies used by AES Intellinet and CRN Wireless alarm systems in the 460 to 466 MHz area, the MPE for controlled and uncontrolled exposure compute as 1.555 mW/cm2 and 0.315 mW/cm2 respectively.

Power levels for these systems are rather low, both with a prescribed power output of 2 watts. The power reduces quickly as one moves away from the antenna.

But a very important factor that must be considered is duty cycle. An AES alarm radio unit checking in once per day has a duty cycle of 0.0000057, yielding an average power output of 0.0000114 watts (11.4 microwatts).  CRN Wireless alarm radio systems operate as a one-way network. The typical duty cycle for such systems is 0.000017, yielding an average power of  0.000034 watts (34 milliwatts). These both yield an MPE of 0.0001 mW/cm2     which is well under the FCC’s MPE criteria.

If you consider an AES Intellinet customer unit relaying eight of its neighboring units, which is a feature of this system, this will yield an average power output of 90 microwatts and an MPE of 0.0002 mW/cm2, still well under the FCC’s MPE criteria.

For AES Intellinet IP Link base stations and CRN Wireless repeaters, the duty cycle is substantially higher because of the fact that these units operate as gateways for multiple customer units. For example, for a system with 600 customers, considered a computational target load, the duty cycle is 0.00342, yielding an average power output of 0.00684 watts (6.8 milliwatts) for AES IP Links and 0.011, yielding an average power output of 0.0229 watts (23 milliwatts) for CRN Wireless. Even at this higher rate, the average power is still very low. This computes to a MPE’s of 0.012 mw/ cm2 and  0.052 mw/ cm2 for AES and CRN respectively, well under the FCC’s MPE criteria.

These figures, both at the customer’s premises and base station locations should prove to be a worst case scenario, since they were computed using a 9 dbi antenna, which is generally the maximum gain antenna used. So, a lower gain antenna, which is used more often, would reduce these power levels even more.

So what does this all mean for alarm companies?

At the frequency where private wireless radio systems units operate (between 460 and 466 MHz.), the number derived from the equations given by the FCC compute MPEs well below the FCC’s criteria.

Let’s consider the customer locations. Using the frequency, power level, duty cycle and antenna gain, the MFE would not be an issue unless a customer (or alarm company personnel servicing the equipment on the costumer’s premises) would be constantly within one inch from center of antenna.

With the antenna mounted on the control unit or remoted (to attain some height), there should normally be absolutely no issue. Although the distance limit shown is absurdly low, care should be taken to ensure that by some quirk of installation, no one is normally, constantly located within one inch of the antenna. The subscriber cabinet usually provides this clearance, but installations that are in the middle of the living space should be avoided.  Of course, alarm panels and radio units are generally installed in a closet, attic or other space that is not a nuisance to the occupants and invisible to a would be intruder, so there is usually no risk of prolonged close exposure.

Let’s consider the AES Intellinet IP Link and CRN Wireless repeater locations. Using the frequency, power level, duty cycle and antenna gain, the MPE would not be an issue unless general population or service personnel would be constantly within 6 inches from center of antenna.

However, these locations are usually remote from the general population and are often mounted high on a rooftop in such a manner that such contact would be impossible anyway. It will be advisable to make sure this is there is some physical barrier between the antenna and a path or location where humans can be present. With a limit of 6 inches, this should be rather easy to attain.

Summary

With a greater focus by the public and the FCC on RF exposure created by prolonged use of cellular handsets right next to the human ear, it is important to ensure that wireless alarm systems comply with FCC RF rules.  The good news is that alarm radios generally are not designed to be used next to the human body, so compliance can be easily achieved in the vast majority of cases.  Nonetheless, alarm service providers should work with the manufacturers and installers to make sure newer RF rules such as equipment labeling and (in the case of higher powered rooftop or tower mounted radios) warning signs, worker instructions and barriers are correctly observed, and to stay on top of any other requirements the FCC may adopt in the future, in response to its 2013 rule change proposals.