ESA responds to FCC: 'Communications will be hindered if all aspects ... are not reliable'

Just got an email from ESA with their response to the FCC's recent public notice on a possible POTS sunset. You can download a PDF of Alarm Industry Communications Committee chairman Louis T. Fiore's official response to FCC here. The basic thrust is "We want to work with you and support IP, but need to be sure it reall WORKS..." Which IP doesn't a lot of the time when you're dealing with alarm panels. And that's kind of a big deal when you're dealing with people's lives and property. Here's the email from ESA in it's entirety:
ESA and Other Industry Groups File Comments with FCC on National Broadband Plan Recently, the Alarm Industry Communications Committee (AICC) – whose membership is comprised of representatives from ESA, the Central Station Alarm Association, the Security Industry Association and several national companies – submitted comments to the Federal Communications Commission in response to AT&T’s recent filing concerning the transition from the circuit-switched network to broadband and IP-based communications. As part of the American Recovery and Reinvestment Act of 2009, Congress directed the FCC to create a national broadband plan by March 17, 2010 that seeks to ensure that all Americans have access to broadband capability. As part of their plan development, the commission, in December, sought comments on the transition from a circuit-switched network to an all-IP network. The FCC is trying to determine whether or not new policy should be considered and what relevant questions should be raised on how best to monitor and plan for such a transition. Read the FCC public notice. On December 21, AT&T filed a comment with the FCC that, among other things, explicitly called for the phasing out of the Public Switched Telephone Network (PSTN). In their filing AT&T states (emphasis added), “Due to technological advances, changes in consumer preference, and market forces, the question is when, not if, POTS service and the PSTN over which it is provided will become obsolete. In the meantime, however, the high costs associated with the maintenance and operation of the legacy network are diverting valuable resources, both public and private, that could be used to expand broadband access and to improve the quality of broadband service. It is for that reason that one of the most important steps the Commission can take to facilitate an orderly transition to an all-broadband communications infrastructure is to eliminate the regulatory requirements that prolong the life of POTS and the PSTN.” Read AT&T’s comments. Today, approximately one-third of Americans live in, work in and go to premises where security systems are utilized. Accordingly, many Americans would be impacted if the PSTN is retired before there is a thorough understanding of how it is relied upon everyday in security applications to protect them from harm. Therefore, the AICC in its filing has called on the FCC to consider a plan of orderly transition to broadband and IP-based communications – one that ensures communications services to all Americans will operate with a high degree of reliability and compatibility with existing life safety services and equipment. Read the comments from AICC. ESA supports broadband development and IP-based communications. These developments carry great potential in connection with alarm services such as the ability to transmit more data at faster speeds from a protected premise to the monitoring station. However, the ability of the alarm industry to rely on broadband and IP-based communications will be hindered if all aspects of the communications path are not reliable. Further, ESA and other industry groups support a gradual transition to broadband and IP-based communications to ensure compatibility with existing services and equipment. As the FCC works on its National Broadband Plan, ESA, through its active involvement in the AICC, will continue to monitor, participate in and report back on the development and impact of the plan.


[...] and patchy, due to idiosyncrasies like throttling and packet dropping. Understandably, the industry does not feel good about entrusting its life safety protection duties to what is really still a young technology. Not [...]

[...] been following the POTS Sunset news as it’s occurred, blogging and writing stories when the FCC asked for public comment, and when AT&T proposed POTS be [...]