To: Alarm Industry Communications Committee

Law Offices BLOOSTON, MORDKOFSKY, DICKENS, DUFFY & PRENDERGAST, LLP 2120 L Street, NW, Suite 300 Washington, DC 20037

HAROLD MORDKOFSKY AFFILIATED SOUTH AMERICAN OFFICES (202) 659-0830 BENJAMIN H. DICKENS, JR. ESTUDIO JAUREGUI & ASSOCIATES Facsimile: (202) 828-5568 JOHN A. PRENDERGAST BUENOS AIRES, ARGENTINA GERARD J. DUFFY RICHARD D. RUBINO ROBERT M. JACKSON MARY J. SISAK OF COUNSEL D. CARY MITCHELL SALVATORE TAILLEFER, JR. PERRY W. WOOFTER LEGISLATIVE CONSULTANT ARTHUR BLOOSTON

1914 – 1999 EUGENE MALISZEWSKYJ DIRECTOR OF ENGINEERING

From: Benjamin H. Dickens, Jr. Mary J. Sisak

Re: Wireline Report

Date: March 8, 2012

Broadband Outage Reporting Requirements

The FCC issued an order requiring interconnected VoIP providers to submit network outage reports to the FCC when a complete loss of service and/or connectivity to customers has been experienced.

Under the new rules, interconnected VoIP providers must report an outage of at least 30 minutes duration on any facilities that they own, operate, lease or otherwise utilize that: 1. potentially affects a 9-1-1 special facility. 2. potentially affects at least 900,000 user minutes of interconnected VoIP service and results in a complete loss of service or potentially affects any special offices and facilities.

The FCC's network outage reporting requirements for interconnected VoIP providers are similar to the existing requirements applied to other services.

The FCC's rules will not become effective until after they are published in the Federal Register.

Broadband Universal Service and Intercarrier Compensation Reform

In December we reported that the FCC released an order and further notice of proposed rulemaking (FNPRM) radically changing the federal universal service and intercarrier compensation regimes that apply to carriers to promote broadband deployment. The result of the Order is that communications providers are seeking ways to reduce cost and increase revenue in ways that may impact the alarm industry. Some of the potential impacts are as follows:

1. Transition away from regulated telecommunications service to unregulated service. Wireline carriers have argued that IP to IP interconnection should be pursuant to unregulated commercial agreements.

2. Bundle services and seek new services to add to the bundle.

3. The price cap carriers are arguing that the FCC must relieve them of the obligation to provide voice service (and broadband service) to all consumers in all parts of their service area, if they do not receive federal universal service support.

4. Rural carriers have filed for waivers of the rules arguing that the new rules make them unable to repay existing loans for facilities.