AICC Files Comments on VoIP to the FCC

The Alarm Industry Communications Committee (AICC) and the Central Station Alarm Association (CSAA) submitted on August 15, 2005 comments on behalf of its members to the Federal Communications Commission's (FCC) request for comments regarding additional steps needed to ensure that providers of VoIP services provide ubiquitous and reliable E911 service.

In its comments, the AICC has asked the Commission to consider public safety requirements that should be imposed on VolP providers in addition to E911. Specifically, CSAA asks the Commission to impose notification and non-interference requirements on VolP providers to protect the safety interests of subscribers to central station alarm services.

Based on its responsibility to promote safety of life and property, the Commission adopted rules to require VolP providers that are interconnected to the PSTN to provide E911 service. The Commission found that imposing an E911 requirement is reasonably ancillary to its responsibility under the Act for making available "a rapid, efficient, Nation-wide, and world-wide wire and radio communication service… for the purpose of promoting safety of life and property through the use of wire and radio communication."

The Commission’s rules require interconnected VolP providers to transmit all 911 calls, as well as a call back number and the caller's Registered Location for each call, to the appropriate emergency authority. Further, the Commission requires that the E911 service must be a standard feature of the VolP service and not an optional feature. The Commission also requires all providers of interconnected VolP service to advise every subscriber of “the circumstances under which E911 service may not be available … or may be in some way limited by comparison to traditional E911 service. Interconnected VolP service providers also must distribute warning stickers or other appropriate labels to all subscribers “warning subscribers if E911 service may be limited or not available…”

The Commission states that "while a provider of VolP service enjoys the opportunity to introduce new and exciting public interest benefits to the communications marketplace, and to profit from those offerings, that opportunity brings with it the responsibility to ensure that public safety is protected."

CSAA agrees with the Commission that VolP providers have a responsibility to ensure that public safety is protected. However, with respect to the subscribers to central station alarm service, this responsibility cannot be met solely by extending access to E911. Rather, just as the public relies on access to E911, subscribers to central station alarm operations rely on these services for personal, home, and business protection. Thus, VolP providers should be required to ensure that they do not interfere with other public safety mechanisms employed by subscribers, such as central station alarm services. At a minimum, VolP providers should be required to determine whether a new VolP customer has alarm service and to notify and work with the alarm company before cutting over the customer's service in order to ensure that alarm service is not degraded, interrupted or terminated.

CSAA believes that such a requirement is consistent with the Commission's Title I responsibility to promote "safety of life and property.” It also is consistent with the notification requirements imposed by the Commission on VoIP providers in connection with E911 service, whereby the Commission requires providers of interconnected VoIP service to advise subscribers of the circumstances under which E911 service may not be available or may be limited in comparison to traditional E911 service.

The full text of the CSAA comments is available here.