Call your representatives! Support Industry Call for 3G Sunset Extension

As many of you know, AT&T and Verizon have announced sunsets for their 3G networks. AT&T is calling for a sunset date of February 22, 2022 and Verizon is calling for a sunset of December of 2022 – 10 months later. Because of the Coronavirus many of our customers have been reluctant to have alarm technicians enter their homes and businesses so that we can upgrade their equipment to make them compatible with newer networks.

We need your help especially if your business is headquartered in one of the following states:

AK, AZ, CA, CT, CO, FL, HI, IA, IL, IN, KS, LA, MA, MI, MN, MO, MS, MT, NC, NE, NJ, NM, NV, NY, OH, OR, PA, SD, TN, TX, UT, VA, VT, WA, WI, WV

The industry is seeking a longer transition period before AT&T sunsets its 3G network. We are asking elected officials to reach out to AT&T and urge them to push back their sunset to December 2022 which would make AT&T’s sunset the same time as Verizon’s proposed sunset, citing the pandemic as the reason.

Linked here is a spreadsheet that includes the staffers of all the members on the House and Senate Telecom Subcommittees. House Members appear first, scroll down to the second page to find Senators. Please use the staffer’s email to contact the Telecom Sub-committee member.

Ideally, if your business is headquartered in a Sub-Committee member’s district or state, we would urge you to reach out to that member. Even if your business is not located in the member’s district but are from his/her state, they will pay attention.

To find out who represents your district go to:

Please let me know if you have any questions. Our lobbyist Bill Signer or I will endeavor to assist you. Thank you in advance for your help in helping our industry.

We are asking you to send the message below to your elected officials:

Dear Representative/Senator:

The burglar and fire alarm industry is seeking your help in urging AT&T to delay the shutdown of its 3G cellular network which is currently scheduled for February 22, 2022 – a mere 16 months from now – to December 2022. This would then have both Verizon and AT&T shutting down their 3G network cellular networks at the same time.

Our industry protects the safety, and property of over 30 million homes and businesses. Additionally, many seniors depend upon us to monitor their personal emergency response systems allowing them to live at home. Many of these systems were installed using the 3G cellular network and must be upgraded, otherwise they will cease to communicate once the 3G networks are shutdown. Historically, AT&T recognized the need for an appropriate time period when it moved from 2G to 3G and provided 4 1/2 years for that transition. The industry estimates that we now have upwards of 3 times the number of 3G devices to change out as we did in the past transition.

Currently, the change-out requires an alarm technician to enter the premise and upgrade the existing equipment. Unfortunately, with the Coronavirus pandemic understandably many of our customers have been reluctant to have us enter their homes and businesses. For six months and counting this has curtailed what was to be a two year transition. Realistically, we are looking at least another nine months before we will be able to resume our normal ability to upgrade these systems.

While AT&T has been working with the industry for the development of equipment that will allow consumers to self-install equipment that would upgrade home security systems, to date that equipment is still in the testing stage. While we are hopeful that the equipment will work, we are not certain it will or whether the manufacturer will be able to meet the demand in a timely fashion.

Accordingly, we are asking you to speak directly with AT&T and urge them to move back their 3G cellular shutdown date to December 2022 and make it the same time as Verizon’s shutdown. Failure to do so will put millions of homes, businesses, and lives needlessly at risk.

Include your address on the emails that you send so they know you are a constituent.

 

 

Experiencing blocked or mislabeled calls?

TMA wants to hear from you! In response to the FCC request for examples, TMA seeks to learn how members’ communications with customers are being impacted by call blocking programs initiated by carriers to stop robocalls.  Please email cbesore@tms.us with your comments by Sept. 24th.

Please provide the following information for any instances:

  1. Whether the calls were blocked or mislabeled as fraud?
  2. What carrier did the blocking/mislabeling?
  3. When did the blocking/mislabeling occur?
  4. Were the blocked/mislabeled calls from the central station to the customer to verify the alarm signal or to the PSAP or other public safety entity to report the alarm?
  5. Did the central station contact or try to contact the carrier about the blocking/mislabeling?
  6. What was the response from the carrier?

Below, find the appropriate contacts for the different telecom providers to whom you should also report your experiences.

AT&T:

Contact AT&T by phone at  800-337-5373 (prompt 1) or via email at

dl-GFMOBusinessFra@att.com

Contact AT&T’s third party analytics company, Hiya, at https://hiyahelp.zendesk.com/hc/en-us/requests/new

 

T-Mobile:

Register in with T-Mobile at https://www.calltransparency.com.  According to T-Mobile, the Call Transparency list “allows legitimate businesses and other legitimate callers a place to provide their phone numbers and information about the traffic on those numbers.”

Report when a call has been incorrectly blocked or labeled at https://feedback.fosrvt.com/.

 

Verizon:

Register  with Verizon’s third party vendor, Transaction Network Services (TNS), at https://voicespamfeedback.com.

According to Verizon, it offers two robocall mitigation services:  (1) Call Filter for Verizon wireless customers and (2) Spam Alert for Verizon wireline residential customers.   Both services label calls based on analytics from TNS.   Customers and calling parties can report if telephone numbers are inadvertently being flagged as potential spam or fraud at the feedback website.

 

AICC Seeks Comment – Recent Equipment Prohibitions

AICC is evaluating the possibility of filing comments regarding the impact of recent prohibitions on use of equipment (including video surveillance) from ZTE and Huawei (and their affiliates) on its members. Comments are due September 14. Any information you can about your company in response to the following questions would be greatly appreciated:

  1. Does your company provide services or equipment to any Federal government agency, or to any entity pursuant to the Federal Acquisition Rules (FAR), either as a primary contractor or subcontractor?
  2. Does your company use equipment manufactured by or services provided by ZTE, Huawei, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company? This question is not limited to equipment or services you offer; it includes any usage of equipment or services from these companies whatsoever.
  3. If you do not know the answer to question 2 above, please provide a sense of how difficult it might be to determine the answer.

As noted, the next opportunity to provide feedback on the subject to regulators is September 14. Accordingly, we ask that you please forward your responses to Sal Taillefer (sta@bloostonlaw.com) as soon as possible.

FCC Will No Longer Issue Warnings

On May 1, the FCC adopted an Order ending its practice of warning most robocallers before issuing penalties for violating the law and for harassing consumers with unwanted robocalls. Such warnings were previously required by law until the TRACED Act was enacted in December 2019.

Specifically, under the prior statutory requirement, the FCC had to issue robocallers that did not otherwise fall within its jurisdiction warnings—formally called citations—related to their alleged violations of the Telephone Consumer Protection Act (by, for example, robocalling cell phones without prior consumer consent) before the agency was able to move forward with an enforcement action. In addition, prior to the TRACED Act, any fine the FCC proposed for TCPA violations by robocallers could be based on violations that occurred only after the warning had been issued. While caller ID spoofing violations—namely, the use of spoofing to scam consumers—did not require warnings, the act of illegal robocalling by these scammers did.

In addition, the FCC action extends the statute of limitations during which robocallers can be fined for TCPA and for spoofing violations. Until now, the FCC had either one or two years, respectively, from the day a violation took place to propose a fine, and only the violations that took place within that timeframe could be included when calculating the proposed forfeiture. With this change, the FCC has four years to propose a fine for spoofing and intentional robocall violations. The Order also increases the maximum fines for intentional robocall violations.

“Robocall scam operators don’t need a warning these days to know what they are doing is illegal, and this FCC has long disliked the statutory requirement to grant them mulligans,” said FCC Chairman Ajit Pai. “We have taken unprecedented action against spoofing violations in recent years and removing this outdated ‘warning’ requirement will help us speed up enforcement to protect consumers. With strong enforcement and policy changes like mandating STIR/SHAKEN caller ID authentication and authorizing robocall blocking, we are making real progress in our fight against fraudsters.”

UL Seeks Feedback on Revised Guidelines

On March 16th, in response to a request from TMA, UL published a statement on Monitoring Station Certifications and continued operations as communities work to contain the impact of COVID-19. An initial set of guidelines for virtual workplaces was included for stations considering at-home operators as part of their contingency planning.

Since then, it’s become clear that health risk mitigation measures will likely be required for longer than any of us had anticipated. UL now seeks feedback  from industry stakeholders that rely on UL Certifications as part of their own risk management programs to review the updated Guideline revisions, which are intended to better define virtual workplace security measures.

Review the revised draft of Virtual Workplace Guidelines that incorporate these initial suggestions. Because this version of the Guidelines is more technically specific than the original, UL would welcome industry feedback prior to publication.

Please send any input you may have directly to Steve Schmit, Senior Staff Engineer, UL.

Steve will also discuss the revised Guidelines and UL’s direction in the COVID environment during TMA’s Virtual Town Hall on Monday, April 20th.

ESA, SIA & TMA Urge Public Safety Leaders to Consider Importance of Electronic Security, Fire, Life Safety & Monitoring Services

The Electronic Security and Life Safety Industry Associations call on state leadership to ensure that essential emergency services are not suspended or impacted by the COVID-19 crisis.

The Electronic Security Association (ESA), Security Industry Association (SIA), and The Monitoring Association (TMA) have partnered to circulate a letter drawing state public safety leaders’ attention to the essential emergency services provided by electronic security, fire, life safety and monitoring companies and ensure that those who depend on them are not adversely impacted during the evolving situation with the COVID-19 pandemic.

The letter, which has already garnered more than 450 signatures from industry CEOs, company owners and leaders, highlights the critical functions of alarm response centers for monitoring, saving first responder resources, alerting businesses to potential break-ins or troubles, monitoring and notifying customers of health emergencies, following industry standard best practices and more.

The letter’s two requests for state leaders are to:

  1. Ensure that government policy reflects that companies providing essential emergency services and field service and dispatch remain operational
  2. Provide an exemption for electronic security, monitoring and life safety services as essential services in any shelter-in-place, quarantine or similar order

[Note: TMA is continuing to collect signatures from executives at firms in the security industry. To add your firm to the letter, please provide your information online. If you have any other questions, email TMA Executive Director Celia T. Besore at ceo@tma.us and affirm your consent to sign.]

DOWNLOAD

Urgent News From UL for Monitoring Centers

UL Statement on Certifications to the US Alarm Monitoring Industry

As developments around the coronavirus COVID-19 continue to evolve, UL has been asked how health risk mitigation techniques might impact Alarm Service Certifications, especially those that involve quarantine, social distancing, work from home, and similar.

At UL, our driving mission is to help create safe living and working conditions for all of our constituencies. This value shapes our Standards and program policies. The emergence of the COVID-19 virus presents a new challenge, but by working together, we can find ways forward.

As in the past, after natural disasters such as hurricane Katrina, superstorm Sandy and others, actions taken to maintain monitoring operations may temporarily be out of sync with the current language of UL827, Central Station Services. In emergency situations like these, know that UL’s primary concern is for the health and safety of your staff and customers. If circumstances prevent you from complying with the written requirements of the Standard for staffing a station, we simply ask that for now, you document your station’s alternate procedure and when it went into/out of practice.

UL is working with industry to develop reasonable guidelines and alternative operating methods for scenarios such as the current COVID-19 outbreak. An initial draft is attached to this statement and will be updated as improvements are identified. These guidelines will eventually form the basis of revisions to UL827 to address pandemic-type scenarios better.

Please note that for US based stations monitoring National Industrial Security System accounts, any deviations from UL827 language need to be discussed with and approved by the relevant US federal security agency with jurisdiction.

UL’s current understanding is that due to the high risk nature of these systems, many Federal Security Agencies will not approve of monitoring outside a UL Certified Central Station operating room. If such monitoring is not available, it is likely defense contractors will have to react in the manner prescribed by the applicable security manual for instances where monitoring is not available or not employed.

At this time, we encourage monitoring stations to make contingency plans for operating in environments where operators are not able to physically come together to monitor signals in a central station operating room. There is a meaningful risk that the rapid spread of COVID-19 could trigger governmental movement and assemble recommendations/controls that would preclude normal station operation.

If you have questions or concerns, please contact Steve Schmit, steven.a.schmit@ul.com, 847-420-8032

In the current COVID-19 mitigation environment, central stations may be challenged to operate in strict compliance with UL Standards. UL expects that stations will make every reasonable effort to exercise options available in UL standards. However, in cases where delivering ongoing monitoring services requires alternate procedures, we request that stations document those procedures and be prepared to share them with UL if/when necessary as a basis for maintaining their UL Certification.

As a last resort, some stations may be considering use of home based operators to process signals. Based on input from industry, UL recommends considering the following guidelines.
Note – For US based stations monitoring National Industrial Security System accounts, any deviations from UL827 language need to be discussed with and approved by the relevant US federal security agency with jurisdiction.

UL’s current understanding is that many Federal Security Agencies will not approve of monitoring outside a UL Certified Central Station operating room. If such monitoring is not available, it is likely defense contractors will have to react in the manner prescribed by the applicable security manual for instances where monitoring is not available or not employed.

VIRTUAL WORKPLACE GUIDELINES

These guidelines are designed to provide procedural guidance to operators who perform job duties at alternative work sites, most specifically at home offices. The virtual work arrangement requires remote operators to be self-motivated and work well with minimal supervision. The following guidelines apply to the virtual environment:

  • Virtual workplace operators should be provided with a computer. Home/personal computers shall not be used.
  • Connections between virtual workplace computers and central station automation systems shall be made through a secure, encrypted virtual private network (VPN)
  • Internet speed may be affected by others in a home using the same internet. This may require an virtual workplace operators to suspend use of the internet by other individuals in the home.
  • Multifactor authentication should be required every 24 hours.
  • When not on shift, computer should be in shutdown and put in a secure place. This is to prevent any damage of theft of the computer.
  • When processing alarms the computer should be setup as not to allow others to view the monitoring screen or any other information.
  • When walking away from computer while on shift lock the screen so others cannot gain access to the monitoring window.
  • Virtual workplace operators are expected to have an appropriate workspace that is suitably designated for work and segregated in order to eliminate distraction and noise.
  • Due to the nature of virtual work arrangement, operators may not provide primary care for a child or dependent during the on duty hours except in the case of an emergency. The focus of an operator’s core working hours must remain on job performance and meeting business demands.
  • Virtual workplace operators are advised not to release their home address and telephone number to non-employees of the company.

Download PDFs:

  1. COVID-19 Statement & Guidelines for the Alarm Monitoring Industry in US
  2. COVID-19 Statement & Guidelines for the Alarm Monitoring Industry in Canada

Coronavirus Response Toolkit – U.S. Chamber of Commerce

The U.S. Chamber has compiled CDC’s coronavirus recommendations for businesses and workers across the country. American businesses are encouraged to follow data-based guidance from the CDC and state and local officials. Visit the link below to find a shareable graphics based on the CDC’s latest guidance for businesses and employees. Share these assets on social media, websites, and other channels, and send them to your colleagues and employees. 

ACCESS THE TOOLKIT

TMA Posts Pandemic Preparedness Resources for Members

The Center for Disease Control (CDC) is now urging businesses to begin planning for what may evolve into a pandemic, as the Coronavirus Disease 2019 (COVID-19) evolves in the United States.

To assist member companies and others in planning for the protection of their business, employees, and customers, TMA has compiled and posted several resources and posted them to our website.  

To stay up-to-date on COVID-19, please visit the CDC website often.

FCC Concludes Sharing of Consumers’ Real-Time Location Data Violates Federal Law

After an extended investigation, the FCC Enforcement Bureau has concluded that at least one wireless carrier apparently violated U.S. law by improperly disclosing consumers’ location data.

FCC Chairman Ajit Pai announced the agency’s conclusion in a January 31 letter to Congress. While the letter did not identify any carriers by name, it confirmed that one or more Notice(s) of Apparent Liability for Forfeiture would be issued in the coming days in connection with the apparent violation(s). 

“I am committed to ensuring that all entities subject to our jurisdiction comply with the Communications Act and the FCC’s rules, including those that protect consumers’ sensitive information, such as real-time location data,” said Chairman Pai.

The security of consumers’ real-time location data is an issue that gained widespread attention in 2018 after press reports revealed that carriers including T-Mobile, Sprint and AT&T were selling phone geolocation services to outside companies.  While it is common knowledge that law enforcement agencies can track phones with a warrant to service providers or through the use of IMSI catchers (also known as “Stingrays”), what

journalists found was that data made available to asset tracking and other legitimate enterprise location service providers was being resold to a host of different private industries, ranging from car salesmen and property managers to bail bondsmen and bounty hunters, with little or no oversight.  Compounding this already highly unscrupulous business practice, this data was then being leaked and/or resold to black market data brokers. An investigation by Senator Ron Wyden (D-Ore.) into the commercial relationships between Verizon and a pair of obscure data vendors found that one of Verizon’s indirect corporate customers, a prison phone company called Securus, had used Verizon’s customer location data in a system that effectively let correctional officers spy on millions of Americans.

Shortly after the reports surfaced, Verizon, AT&T and Sprint announced that they would no longer share customers’ location data with third-party companies who failed to adequately protect the data. The FCC took up the matter in early 2019 after FCC Commissioner Jessica Rosenworcel sent letters to major phone companies to confirm whether they lived up to their commitments to end these location aggregation services.

Commissioner Rosenworcel criticized the agency for its delay in taking enforcement action in a written statement..

“For more than a year, the FCC was silent after news reports alerted us that for just a few hundred dollars, shady middlemen could sell your location within a few hundred meters based on your wireless phone data. It’s chilling to consider what a black market could do with this data. It puts the safety and privacy of every American with a wireless phone at risk.

Today this agency finally announced that this was a violation of the law. Millions and millions of Americans use a wireless device every day and didn’t sign up for or consent to this surveillance. It’s a shame that it took so long for the FCC to reach a conclusion that was so obvious.”

While the focus of this violation investigation is on provision of location information to third party aggregators, one can wonder whether the FCC’s crackdown will cause the cellular carriers to be more difficult to deal with on the new direct provision arrangement we understand alarm companies have worked out for location info.