FIGHT AUCTIONS OF ALARM INDUSTRY FREQUENCIES

Table of Contents

• The issue
• NEW: Talking points when talking to your Congressman/woman
• NEW: A new sample letter to send to your Congressman/woman if you have not done it or received a response to your original letter
• NEW: A letter from your Congressman/woman to the FCC
• The original sample letter
• Influential Members of Congress to Contact

The Issue

The Federal Communications Commission (FCC) is considering adopting new rules to auction private radio spectrum, which could include the radio channels used by alarm companies for dispatching and alarm signaling.

The Central Station Alarm Association is working to demonstrate to the FCC that the traditional alarm dispatch and signaling channels should be exempt from any auction.

Talking Points
Click here to download printable document. Then copy and paste into your document.

It is important to exempt alarm company radio operations from the proposed Part 90 spectrum auctions:

THE ALARM INDUSTRY SHOULD BE EXEMPT FROM SPECTRUM AUCTIONS

It is important to exempt alarm company radio operations from the proposed Part 90 spectrum auctions:

• Alarm companies protect citizens from burglary, fire, and medical emergencies, allowing them to rapidly summon help.

• The Balanced Budget Act of 1997, Pub. L. No. 105-33, instructs the FCC that private radio operations "used to protect the safety of life, health or property" should be exempt from spectrum auctions.  Alarm operations qualify for this exemption.

• Most alarm companies are small businesses.  The frequencies used by alarm companies constitute a tiny fraction of the available spectrum (approximately one fourth of one MHz), and currently are restricted to central station alarm operations only, for use in sending alarm signals and communicating with police and fire directly, as well as guard patrols.

• The spectrum auction would expose radio alarm signals to harmful interference from the auction winner, potentially blocking the report of a burglary, fire, or heart attack.

• The FCC's auction design (to sell large parcels of spectrum over a wide geographic area) does not make sense when applied to alarm operations, which generally need priority access to frequencies over a relatively confined area.

• Police and fire departments depend on alarm companies to transmit reports of emergencies, so that these agencies can focus their resources on a rapid response.  Government agencies also depend on alarm radio links for the security of sensitive government installations.

Sample letter to send to your Congressman/woman
if you have not sent one already or if you have not received a response to your original letter
Click here to download printable document. Then copy and paste into your document.

ADDRESS TO SENATOR OR REPRESENTATIVE

Dear ____________________,

As you may know, the alarm industry provides monitoring services to detect burglaries and, in many cases, fires or medical emergencies at the protected homes and businesses of many of your constituents.  The alarm central stations alert the appropriate police, fire and other governmental entities about the existence, location and nature of these emergencies, making it easier for them to respond in a timely fashion.  The alarm industry also provides private security patrols, which further ease the burden on the already strained budgets of police and fire departments.

The alarm industry uses a small number of radio frequencies licensed by the Federal Communications Commission (FCC) in carrying out these responsibilities.  Use of these radio frequencies is vital to the successful operation of our protection services.  As you may know, the FCC is in the process of deciding whether to expand its spectrum auction procedures so that the Part 90 private user spectrum can be auctioned to the highest bidder.  The FCC's auction proposal makes it clear that the winning bidder will be able to freeze any growth or modification of existing systems; can load the channels with high-volume commercial users; and may even be able to eventually force incumbent users off the spectrum.  This would have disastrous consequences for the alarm industry, and would therefore compromise the safety of many of your constituents.

Public safety radio services are the only exception to the auction scheme proposed by Congress and the FCC.  This is certainly a justified exception, given the vital role that public safety entities play in protecting life, health and property.  Fortunately, Congress drafted the exemption for "public safety radio services" to include "private internal radio services used by . . . non-government entities . . ., that are used to protect the safety of life, health or property." See 47 U.S.C. § 309(j)(2), as amended by the Balanced Budget Act of 1997, Pub. L. No. 105-33, Title III, 111 Stat. 251. This is precisely how alarm companies use their radios, whether it be for internal communications to security guards, or as low power radio links that transmit fire and burglar alarms to the central station, where it is relayed to the appropriate police or fire department.  Radio links are a more secure means to transmit alarms, since a radio signal cannot be sabotaged in the way that a phone line can.

Given the fact that the alarm industry works hand-in-hand with governmental safety organizations, and helps to reduce the financial and personnel burdens on these agencies, the alarm industry wishes to be classified (for auction purposes) as an exempt safety radio user, for the small handful of channels that are currently restricted to UL-listed central station use.  To this end, the Alarm Industry Communications Committee (AICC) of the Central Station Alarm Association (CSAA), has filed comments in WT Docket 99-87 with the FCC advocating this position. We will be glad to provide you with a copy of these comments. In making this proposal, AICC wants to make it perfectly clear to Congress, the FCC and the rest of the public safety community that the alarm companies do NOT wish to gain access to the present or future allocations of public safety spectrum used by government agencies.  Instead, we merely wish to protect the small amount of spectrum we have been allocated, so that we can continue to work hand-in-hand with the public safety community.  Nor do we expect to gain rights to participate in the very complex regional safety spectrum use planning which takes place pursuant to the FCC's rules.  We merely wish to gain status as an auction-exempt activity; if need be, this could be as a sub-category of the "public service" radio pool which the FCC has proposed to create.  We would continue to use our assigned frequencies separate from the traditional public safety users.

Given the importance of this issue to many of your constituents, we wanted to advise you of our efforts and ask for your support in this effort.  We would greatly appreciate the opportunity to sit down with you and discuss this issue further.  Hopefully, you are willing to support our position in the FCC's auction proceeding (WT Docket No. 99-87), by writing a simple letter addressed to the FCC, confirming that activities such as alarm monitoring and the reporting of burglaries, fires and medical emergencies are examples of "private internal radio systems" that use radio to protect the safety of life, health or property", and that alarm radio operations are therefore exempt from spectrum auctions under 47 U.S.C. § 309 (j)(2).

Thank you for your consideration in this matter.

                                                                                                Sincerely,

A letter from your Congressman/woman to the FCC
Click here to download printable document. Then copy and paste into your document.

William Kennard, Chairman Federal Communications Commission 445 12th Street, SW, Room 8-B201H Washington, DC 20554

Re: WT Docket No. 99-87

Dear Chairman Kennard:

It has come to my attention that the FCC is considering the auction of private radio spectrum in the above referenced proceeding. I am expressing my support for the request of the alarm industry that it be exempted from such auctions as a safety related operation. Alarm companies use radios to detect burglaries, fire alarms and medical emergencies, and to summon emergency personnel. This is the sort of private internal radio service "used to protect the safety of life, health or property" that Congress exempted from FCC auction authority, when we amended 47 U.S.C. § 309(j)(2), as part of the Balanced Budget Act of 1997, Pub. L. No. 105-33, Title III, 111 Stat. 251.

An exemption would affect only a small amount of spectrum (approximately one fourth of one megahertz), and this spectrum is already restricted by FCC Rules to use for central station alarm operations, to send alarm signals, and to "communicate with police or fire stations, or vehicles . . ." 47 CFR Section 90.75(c)(40). The alarm signaling on this small amount of spectrum already uses some of the most efficient "narrowband" equipment available, with a bandwidth of only five kilohertz, which is more efficient than the FCC currently requires. If these channels are thrown into an auction, there is a likelihood that incompatible radio users will gain access to the spectrum, causing interference and creating the risk that vital alarm signals and calls to police and fire/rescue will not get through.

To prevent this threat to safety, I strongly urge the Commission to recognize the existing central station alarm channels as precisely the types of radio operations that Congress intended to exempt from spectrum auctions when it enacted the above-quoted language amending Section 309(j)(2) of the Communications Act.

Sincerely,

(Congressperson's name and signature)

Cc: FCC Commissioners

Thomas Sugrue, Chief Wireless Telecommunications Bureau Federal Communications Commission 445 12th Street, SW, Room 3-C252 Washington, D.C. 20554

Original Sample Letter
Click HERE to download a text version of this letter. Then copy and paste into your document.

[ADDRESS TO SENATOR OR REPRESENTATIVE]

Dear ____________________,

As you may know, the alarm industry provides monitoring services to detect burglaries and, in many cases, fires or medical emergencies at the protected homes and businesses of many of your constituents. The alarm central stations alert the appropriate police, fire and other governmental entities about the existence, location and nature of these emergencies, making it easier for them to respond in a timely fashion. The alarm industry also provides private security patrols, which further ease the burden on the already strained budgets of police and fire departments.

The alarm industry uses a small number of radio frequencies licensed by the Federal Communications Commission (FCC) in carrying out these responsibilities. Use of these radio frequencies is vital to the successful operation of our protection services. As you may know, the FCC is in the process of deciding whether to expand its spectrum auction procedures so that the Part 90 private user spectrum can be auctioned to the highest bidder. The FCC's auction proposal makes it clear that the winning bidder will be able to freeze any growth or modification of existing systems; can load the channels with high-volume commercial users; and may even be able to eventually force incumbent users off the spectrum. This would have disastrous consequences for the alarm industry, and would therefore compromise the safety of many of your constituents.

Public safety radio services are the only exception to the auction scheme proposed by Congress and the FCC. This is certainly a justified exception, given the vital role that public safety entities play in protecting life, health and property. Fortunately, Congress drafted the exemption for "public safety radio services" to include "private internal radio services used by . . . non-government entities . . ., that are used to protect the safety of life, health or property." See 47 U.S.C. § 309(j)(2), as amended by the Balanced Budget Act of 1997, Pub. L. No. 105-33, Title III, 111 Stat. 251. This is precisely how alarm companies use their radios, whether it be for internal communications to security guards, or as low power radio links that transmit fire and burglar alarms to the central station, where it is relayed to the appropriate police or fire department. Radio links are a more secure means to transmit alarms, since a radio signal cannot be sabotaged in the way that a phone line can.

Given the fact that the alarm industry works hand-in-hand with governmental safety organizations, and helps to reduce the financial and personnel burdens on these agencies, the alarm industry wishes to be classified (for auction purposes) as an exempt safety radio user, for the small handful of channels that are currently restricted to UL-listed central station use. To this end, the Alarm Industry Communications Committee (AICC) of the Central Station Alarm Association (CSAA), has filed comments in WT Docket 99-87 with the FCC advocating this position. We will be glad to provide you with a copy of these comments. In making this proposal, AICC wants to make it perfectly clear to Congress, the FCC and the rest of the public safety community that the alarm companies do NOT wish to gain access to the present or future allocations of public safety spectrum used by government agencies. Instead, we merely wish to protect the small amount of spectrum we have been allocated, so that we can continue to work hand-in-hand with the public safety community. Nor do we expect to gain rights to participate in the very complex regional safety spectrum use planning which takes place pursuant to the FCC's rules. We merely wish to gain status as an auction-exempt activity; if need be, this could be as a sub-category of the "public service" radio pool which the FCC has proposed to create. We would continue to use our assigned frequencies separate from the traditional public safety users.

Given the importance of this issue to many of your constituents, we wanted to advise you of our efforts and ask for your support in this effort. We would greatly appreciate the opportunity to sit down with you and discuss this issue further. Hopefully, you are willing to support our position in the FCC's auction proceeding (WT Docket No. 99-87), by writing a simple letter addressed to the FCC, confirming that activities such as alarm monitoring and the reporting of burglaries, fires and medical emergencies are examples of "private internal radio systems" that use radio to protect the safety of life, health or property", and that alarm radio operations are therefore exempt from spectrum auctions under 47 U.S.C. § 309 (j)(2).

Thank you for your consideration in this matter.

Sincerely,

Influential Members of Congress to Contact

House

House Appropriations Commerce, Justice, State, and Judiciary Subcommittees

• Dixon, Julian C. (D-CA)
• Kolbe, Jim (R-AZ)
• Miller,Dan (R-FL)
• Rogers, Harold (R-KY)
• Roybal-Allard, Lucille (D-CA)
• Serrano, José E. (D-NY)
• Taylor, Charles H. (R-NC)
• Wamp, Zach (R-TN)

House Commerce Committee-Telecommunications, Trade, and Consumer Protection Subcommittee

• Blunt, Roy (R-MO)
• Deal, Nathan (R-GA)
• Ehrlich, Jr., Robert L. (R-MD)
• Engel, Eliot (D-NY)
• Fossella, Vito (R-NY)
• Gordon, Bart (D-TN)
• Klink, Ron (D-PA)
• Markey, Ed (D-MA)
• McCarthy, Karen (D-MO)
• Oxley, Michael G. (R-OH)
• Pickering, Charles W. "Chip" (R-MS)
• Rogan, James (R-CA)
• Rush, Bobby L. (D-IL)
• Shimkus, John (R-IL)
• Stearns, Cliff (R-FL)
• Tauzin, Billy (R-LA)
• Wilson, Heather (R-NM)
• Wynn, Albert (D-MD)

Senate

Senate Commerce Committee

• Abraham, Spencer (R-MI)

• Ashcroft, John (R-MO)

• Burns, Conrad (R-MT)

• Cleland, Max (D-GA)

• Domenici, Pete (R-NM)

• Frist, William (R-TN)

• Gregg, Judd (R-NH)

• Harkin, Tom (D-IA)

• Hutchison, Kay Bailey (R-TX)

• Hollings, Ernest (D-SC)

• Kerry, John (D-MA)

• Kyl, Jon (R-AZ)

• Lautenberg, Frank (D-NJ)

• Mikulski, Barbara (D-MD)

• Reid, Harry (D-NV)

• Specter, Arlen (R-PA)

• Snowe, Olympia (R-ME)

• Wyden, Ron (D-OR)