Forced VOIP Migration.

I recently spoke with a State of Idaho Public Utilities Commission representative. The conversation concerned consumer forced migration to fiber optic data services, VOIP phone services and some of the issues we are struggling with, the lack of formality and control. My Company is, first and foremost, a Life Safety company. Our services revolve around Fire Alarms, Panic Button Intrusion Detection, and Gas Detection Systems.?

As I started to write the email, I began to reflect on many more issues with the forced copper-to-fiber migration, "Plain Old Telephone "POT" phone lines, to Voice Over IP Protocol "VOIP". The repressive was very willing to help me; however, he requested I send him an email outlining many of the issues. This article is a derivative of that very email.?

I hope to provide some good insight into some of them.?

I know the technology is going to advance, and I am a very strong supporter of new emerging technologies; my goal with this article is;

1. Start a conversation. If a Public Service Provider is forcing migration from technology, the provider must provide public notice, Radio, Paper, and Direct to all affected area consumers. No different than Cell carriers were required to notify and set dates for the 3g sunset termination and turn down.?
2. Open the line of communication between service providers such as ourselves and Consumers, Agencies that may not know or even understand the magnitude of some of these issues,?
3. Point out a real cost to the consumer is incurred if the Public Utility Services providers go unchecked, and many are hidden until migration.
4. There is the real potential loss of property or life if the issues are not addressed. This is very serious, and the "old antiquated services are still being used.?
5. Consumers need to be informed properly and will need time for transition.
6. Demonstrate there is a need for some oversite. The shift from one technology to the next is a way for the Public Utility Service Provider to self-deregulate themselves and become an IT-Service providers and no longer under the FCC or PUC authority. In many States like Idaho, VOIP and IT Services are not regulated. The real regulation is the consumer and pocketbook.

Last week a Service Change affected three cities' ability to call certain toll-free carriers. The change kept Life Safety, Security, and Public Safety systems from reaching the Central Monitoring Stations to dispatch first responders. The service outage lasted three days. The affected consumers included a Hospital, TSA, Colleges, Child Care, Public Schools, City Fire Department, City Main Admin Buildings, Fraternities, Assisted Living Facilities, and many private businesses, illustrating that the issue is all-encompassing and not limited to private, public, State, or local consumers. The problem is and will continue to affect all consumers.

Many public phone utility companies are starting to transition from copper POT lines to all fiber data services, essentially voice-over-internet protocol. One of the providers supplied me with this list of cities that will be a forced transition though the list did not include any timelines. The list included Idaho, Washington, and Oregon; because of the reach of each of the service providers, the issue is not a single-state issue.??

With A Communications Public Utility Service provider that services copper POT lines, there is an expectation of the quality of service due to E-911, Life Safety and Emergency call service, response time, and in-service uptime to be maintained by the Utility area Provider. Once a consumer becomes a VOIP subscriber, the above expectations are no longer regulated by any group. In most cases, the consumer has no idea that the measured level of services has changed because the provider has moved from a Public Utility Service Provider to an IT services provider, and IT Service Providers are currently not regulated to the same extent or at all.

In areas where the incumbent Public Utility Services Providers are forcing the consumer to transition technologies from Copper phone lines to Fiber-optics and in-house VOIP services, the provider is essentially self-de-regulating themselves through shifting technologies. By classifying copper communication lines as antiquated and abandoning the existing infrastructure, the Public Utility that was once required to maintain them will no longer be required by any regulatory agency leaving the consumer with no recourse for poor services and unreasonable cost increases, especially if the incumbent Public Utility Service Provider is the only option for Dial tone and or internet in some areas. To the consumer, this may look very appealing because hey, who does not want faster internet, or all their services like Internet, Phone, and TV on one Bill? This is ok for a residence in many cases. This could be very costly if a business has older Life Safety equipment. A panel replacement can result in a full system code update. This is extremely costly.

Some immediate current issues from this transition.

The life safety industry relies on acceptable paths of communication. The life safety code has sections dedicated to the minimum requirements for these paths. Required Battery Backup, E911, Loss of Carrier signal, Test Frequencies, and quantities of paths of communications are some of the basic requirements. The communication paths are critical for Fire Alarm, Panic Alarm, and Intrusion Detection Systems to communicate to the respective central stations allowing the appropriate authorities to be called. With the dramatic increase in VOIP services over the last four to five years, many life safety systems manufacturers have moved to newer and emerging technologies, IP-DACT, CELL-DACT, and Radio, for just a few examples. Overall, far more systems are still in the public consumer inventory that relies on plain old copper analogue lines. The very infrastructure Utility Service Providers are required to maintain as a Public Utility company up until now, classifying them as old, antiquated, and trying to abandon them. This is understandable due to the high maintenance cost, and the newer technologies are much less to maintain.??

• POT lines are under constant supervision and are monitored by the existing Utility Service Providers' central office and the consumers on Life Safety System. The Providers Central office provides a nominal 48vdc down the phone line; the Life Safety Panel is always measuring and looking for this voltage. If the voltage drops too low, the Life Safety Panel will get into trouble and alert the consumer that the safety equipment may not communicate to the respective central station.
• There is still a vast inventory of older equipment that will not communicate over an Analog Telephone Adapter (ATA). The ATA is provided with data and outputs fake dial tones and voltage to the consumer's Life Safety control equipment. The ATA converts the analogue signal to digital to send the Voice out over the internet protocol. "VOIP"??
• VOIP – does not meet the current NFPA requirements for communications on Life Safety – Fire Alarm Systems.
• The Data input to an ATA is not supervised. The ATA does not drop power to the Fire Alarm Panel on the loss of "Data" and, in turn, does not place the panel into local trouble. The Fire Panel would not be able to send any emergency communications out.?
• The ATA does not have a 24-hour battery backup with five minute alarm time capacity. Some will claim NFPA only require 8 hours, which is only an exception to the rule if approved by an AHJ, the consumer has an approved managed facilities-based voice network, and a risk analysis has been performed. This is not the concern of the VOIP provider and is never conveyed to the consumer or the cost associated with performance.
• When the ATA converts the analogue signal from the control equipment to digital, the ATA's digital compression distorts the communication protocol's analogue sound from the fire alarm panel to the receiver, in turn making the signal unintelligible and failing to communicate. I will admit this is getting much better with new codecs coming out and better ATA, but now it is far from reliable.

So why can forced transition be allowed if they can not support all existing equipment? Equipment that is in many times required by minimum state-adopted Life Safety codes.

Systems required under State and Local building and Fire codes, elderly help pendants, and Panic Button Systems, like the mentioned TSA issue we had last week. We have gas detection systems that alert when toxic gas has been released or spilt. The current POT lines are the means of communication to alert the appropriate authorities if there is a life-threatening event. We have found the same language in all the providers providing VOIP services. Below is an excerpt taken from one provider's terms and conditions.

The service providers are aware of this. The exception demonstrates that technology is not there yet in their Terms and Conditions.

?Terms and Conditions

??ii) You acknowledge that the VOIP Telephone Service may not be compatible with certain data transmission services, including but not limited to fax transmission and dial-up Internet access. Other services or equipment that may not be compatible with the VOIP Telephone Service include monitored home security systems, fire alarms, medical monitoring systems, and any such systems will not be available with your VOIP Telephone Service during any power outage. You may be required to maintain a separate telephone line or obtain separate equipment from your services provider in order to access such services.

I find portions of the above conditions ironic; many places currently are being told there will be no separate telephone lines to be maintained as all services are being migrated, leaving the defacto option to add more equipment or upgrade at additional cost to the consumer. I would also like to mention that the client is often unaware of these terms as they are buried deep in the fine print.

It would be reasonable and fair to ask the Utility Service Providers to be required to set dates, timelines, and proper registered public notices that are sent out a minimum of 180 days before the?forced?services are cut over to all affected consumers.

It is reasonable that if the Utility Service Providers act in the capacity of the incumbent Public Utility with?forced?migration, they should be regulated by the Public Utility commission. Under Title 61 Public Utility Regulation Chapter 1 61-129, The term "public utility" when used in this act includes every common carrier, pipeline corporation, gas corporation, electrical corporation,?telephone corporation?and water corporation, as those terms are defined in this chapter and each thereof is hereby declared to be a public utility and to be subject to the jurisdiction, control and regulation of the commission and to the provisions of this act. The term "public utility" as used in this act shall cover cases:

(1) Where the service is performed and the commodity delivered directly to the public or some portion thereof, and where the service is performed or the commodity delivered to any corporation or corporations, or any person or persons, who in turn, either directly or indirectly or mediately or immediately, performs the services or delivers such commodity to or for the public or some portion thereof; and (2) Where a pipeline corporation delivers the commodity to any corporation, person, their lessees, receivers or trustees regardless of whether it offers the pipeline service or commodity to the public or some portion thereof. Such pipeline shall be subject to the safety supervision and regulation of the commission only, unless and until such pipeline corporation makes an application to the commission to be regulated generally as a public utility.

Under Title 31 Chapter 48 Emergency Communications ACT, Idaho State (20), "Telecommunications provider" means any person or entity providing: (a) Exchange telephone service to a service address within this State; or (b) Any wireless carrier providing telecommunications service to any customer having a place of primary use within this State; or (c) Interconnected VoIP service to any customer having a place of primary use within this State; or (d) A provider of any other communications service that connects an individual having either a service address or a place of primary use within this State to an established public safety answering point by dialing 911.

(21) "VoIP service provider" means any person or entity providing interconnected Voice over internet protocol (VoIP) service.

(22) "Wireless carrier" means a cellular licensee, a personal communications service licensee, and certain specialized mobile radio providers designated as covered carriers by the federal communications commission in 47 CFR 20.18 and any successor to such rule.

Thank you all again for taking the time to read this. I look forward to working with any of you in any capacity to work through the issue I have outlined here. We take Life safety very seriously in our practice. It is said, unfortunately, that the Life Safety code is written in blood. In most cases, it took the loss of life to recognize that there needed to be changes in different areas of the life safety code. I truly hope we can find a middle ground before that.