KEN KIRSCHENBAUM, ESQ

ALARM - SECURITY INDUSTRY LEGAL EMAIL NEWSLETTER / THE ALARM EXCHANGE
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more comments on does your cs use redundant route / diverse internet pipes and single points of failure / follow up on changing emergency numbers
February 28 , 2018
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more comments on does your cs use redundant route / diverse internet pipes and single points of failure
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Ken, 
    These are good points Morgan raises with establishing dual paths of communication. One of the greatest challenges we’ve found in the third and fourth items mentioned regarding redundant ISP’s and telecom carriers is that most do not actually know the actual path of their communications or how carriers/ISP’s are interconnected and what common locations/structures they share. 
    We’ve seen several scenarios were a client was certain they had redundant carriers/ISP’s because they were using two different companies that were NOT merged or part of an affiliated group, but in reality were sharing facilities in some fashion. Jordan, our President of the telecom operation here, has spent a few years with his legal/regulatory background determining how certain data could be licensed for specific uses (i.e. life safety) in determining the actual routes of fiber, facilities, and equipment that make up the telecom and IP networks nationwide. Today, we operate a GIS that contains more than 2.5 million miles of fiber routes, 1.3 million lit buildings, along with 14 million geo identified equipment and field structures including poles, manholes, nodes, etc. 
    In putting together the many sources of this data and layering in a GIS, we’ve been successful in assembling complete “blue prints” of a communities telecom and IP infrastructure. Given the high costs of licensing and sourcing this type of data, we were a little apprehensive of its long term value to us, but have found it to be quite useful on a day-to-day basis in the projects we work on. It has helped us identify single points of failures not readily known or visible for many in the alarm industry and engineer truly diverse and redundant solutions, while giving the underlying carriers/ISP’s specific instructions of how to design, build, and route the services in question, rather than just relying on sales engineers to provide the default arrangement. 
    We’d be an advocator of making data and knowledge like this more readily available.
   Joshua J. Greko,    Security Operations
   Dice Corporation
   joshua.greko@dicecorp.com
   www.dicecorp.com
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Ken
    This is a typical response from a central station company who does not have to go into the field and work with customers to get pathways to send signals.   Yes of course the cable modem now handles both the internet and telephone service.   That’s acceptable from the last time I checked.   The alternatives do not always work depending on the area you are in.   You must work with what is practical, available and real.   With the constant changes in technology, be prepared to replace the transmitter using cell telephone every five or so years like what is now happenings with 5G cell telephone service that will in 2020 require replacement.   
    This false  believe that we are there protecting Fort Knox and must insure at all costs that signals must get out is un-real.   The truth of the matter with  this whole central station protection illusion is based upon the customer or others on their notification list taking action once notified with a call that they do not answer because the caller ID does not recognize the number or some sort of an Email or text that they may or may not see right of way due to other  things that they are doing.   The false belief that the police department is going to respond right away adds to this.   Without any of these actions on behalf of either party the central station monitoring is useless and therefore this constant concern on the pathways is over blown.   
    So stand on your high horse and discuss all this redundant stuff.   If the alarm system does not work right to begin with the notification means nothing.   To add insult to injury, with fire alarm system based upon the city you work in, may not allow you to just go out and make a changes in the transmission method without very expensive changes and an inspection like in New York City.   Perhaps it is time for you to put on your tool belt and go out with a dealer to see the real world outside the central station’s.   Start with NYC.
    Yours truly,
Tired of these high horse politicians in their ivory castles  telling others what they should do
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Response
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    The goal is better protection and that includes better communication.  With all the regulations, false alarms, fines, competition, non-payments, changing technology, competing communication pathways and cost of operations, it's easy to lose sight of the fact that alarm systems save lives and property every day; police and fire department would find it impossible to perform their services without alarm systems and without alarm dealers and central stations.
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follow up on changing emergency numbers from February 27, 2019
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Ken,
    In regard to the article on February 26, 2018 regarding emergency numbers changing in CT, this is not correct.  I spoke with a gentleman in the Department of Emergency Services & Public Protection / Statewide Emergency Telecommunications, NOTHING has changed in regard to Central Stations. Nothing has really changed period. The PSAP’s have to do with the local 911 numbers and where they are routed to.  He is very mystified as to why this was even stated.  If you would like more information regarding this I spoke with Stephen Verbil, who I’m sure would be more than happy to speak to you regarding this to clear this up.  Central Stations need not panic and continue to call the dispatch numbers they currently have for Police & Fire emergencies.
    Thank you
Diane Hall
Licensing & Permit Specialist
Select-Security
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Ken:
    Someone from one of the Central Stations [ Diane Hall] ] that services our state called me today to ask about an item she saw in an email newsletter that you send out to your subscribers.  It had to do with the possibility of 10-digit telephone number changes for towns due to a change in their PSAPs.
    We have had some changes in the State of Connecticut, with some of our larger regional PSAPs picking up a towns from another PSAP – notably, the disappearance of the Colchester, CT Regional PSAP and the absorption of its member towns by five other PSAPs; and the move of the City of Waterbury to the Northwest Public Safety Regional PSAP – and that type of activity will continue to slowly happen as time goes on.  Here at the state emergency telecomm office, we provide the 9-1-1 system and equipment for all of our PSAPs, but we don’t manage their 10-digit emergency numbers for them – those are local decisions.  Our experience has been that when a town decides to close its dispatch center and become part of a regional PSAP, for example, they make arrangements to re-connect or forward all of the numbers they need at the new center.  Part of that re-connection would be a plan for verifying every one of the lines that are moved – or translated/forwarded – is operating correctly.
    There’s always a chance that something about the system in place at the old PSAP doesn’t “translate” correctly to the new PSAP, and so a telephone number that worked for a central station before to notify a PSP of an alarm in a particular town might not work anymore.  Or, a telco employee could simply have “fat fingered” an error into a translation database.  It happens.  None of us are happy about it, but it does happen.  Every PSAP is responsible for making sure that all of their phone lines that should be working, *are* working at their (new) location, and every Central Station is responsible for making sure they have up-to-date numbers for the various types of notifications they deliver, on a schedule that meets the central station’s operational (and risk management) needs.  For PSAPs where the correct information is difficult to get, the NENA PSAP Registry is a resource that we at the state use (our need is to get the 10-digit emergency numbers for out-of-state PSAPs).  Available to private entities once NENA is convinced of your identity, it can provide a contact information that can be used to find out the correct number for a central station to use to transmit an alarm for a specific town.
    I think our experience in Connecticut is no different than that of other states, and I hope this email clarifies the situation here in Connecticut.
Sincerely,
Stephen Verbil
Emergency Telecommunications Manager
Connecticut Department of Emergency Services and Public Protection
Division of Statewide Emergency Telecommunications
1111 Country Club Road
Middletown, CT 06457
+1.860.685.8127
stephen.verbil@ct.gov
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Response
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    I was still confused, so I asked Stephen:
    Steve - I am confused.  Do central stations and dealers need to be concerned that phone numbers have changed?
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Stephen's response:
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Ken:
    Central Stations should *always* be worried about numbers – there’s nothing special about what happened here.  There should be a procedure for “what to do” when the number they’ve got programmed for a particular area doesn’t work, which could happen because the line is down, the PBX serving the number is down, any number of things, actually…. As well as that the number has changed since the last time you called in an alarm for that particular customer.
    The point I was trying to make (apparently unsuccessfully) is that towns that change PSAPs, or PSAPs that change locations, take their telephone numbers with them simply because of all the issues that a number change could cause.  They then plan for a long-term change to move all the 10-digit dialing folks over to new numbers, if that is the plan.  But that doesn’t happen at the beginning – in the PSAPs I’ve been involved with, number changes are *years* down the road because there’s just too much else that can (and will) go wrong during a cutover/consolidation into a new center to consider trying to do that at the outset. 
    For some jurisdictions, those that require pre-registration (often the localities that have charges or fines for multiple alarm calls) might depend on that list to notify the Central Stations *that the PSAP knows about* regarding any number change.  If some Central Station is “not on the radar”, so to speak, they might not get the memo.
    Hope that provides further clarity.  If it doesn’t, fell free to write back or call at your convenience.
    Sincerely,
Stephen Verbil
Emergency Telecommunications Manager
Connecticut Department of Emergency Services and Public Protection
Division of Statewide Emergency Telecommunications
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Ken Kirschenbaum,Esq
Kirschenbaum & Kirschenbaum PC
Attorneys at Law
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