AT&T Statement on FCC’s Order Regarding Antenna Structures

Posted by: AT&T Blog Team on August 8, 2014 at 12:35 pm

The following statement may be attributed to Joan Marsh, AT&T Vice President of Federal Regulatory:

“Today the Commission adopted an Order updating and modernizing the Part 17 rules governing the construction, marking and lighting of antenna structures. As carriers continue to invest billions in the deployment of wireless broadband networks, unnecessary or outdated requirements on the installation and maintenance of wireless structures can create barriers that slow deployment efforts.  The Bureau Staff, under the leadership of Chief Roger Sherman, should be commended for their recent efforts to identify outdated regulations and to streamline regulatory requirements in ways that will have a significant impact on infrastructure builds.

“Today’s action is just the first in a series of proceedings underway to reduce obstacles to the deployment of wireless facilities. Increasing certainty in the FCC’s processes and removing barriers to infrastructure deployment will accelerate network investment, which will result in broader wireless coverage and capacity for wireless consumers across the country. We look forward to continuing to work with Bureau Staff on the related proceedings.”

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TOPICS: FCC
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Text-to-911: A Work In Progress

Posted by: Bob Quinn on August 7, 2014 at 10:11 am

At the August 8th Open Meeting, the FCC  is scheduled to vote an item that purports to impose text-to-911 obligations on the US wireless carriers that have not yet voluntarily agreed to provide that service and on Over the Top or OTT text providers.  As you will recall, in late 2012, the 4 major wireless carriers agreed voluntarily to implement text-to-911 capabilities on their SMS platforms.  Because public safety obligations should be platform and technology neutral, the Commission should be applauded for seeking to make text-to-911 universally available, including to Americans with disabilities that may seek to text using an OTT texting application.  But the item currently circulating misses that mark on a number of fronts.

I would start by observing that “texting services” are in the process of undergoing a significant transformation in the underlying technology of delivering those services.  Five years ago, text message services were the sole province of the wireless companies using SMS technology to send and receive consumer texts.  With three then-teenagers living under my roof, my unlimited text plan spared me from having to try to “force” my teenagers to communicate the old fashioned way (you know, talking) when the number of texts on my bill regularly exceeded 15,000.  This month, same three kids (one is no longer a teenager), but the number of “billed SMS text messages” was under 900.  They are still sending out an equal or greater number of texts mind you (they certainly haven’t started communicating the old fashioned way). It is just that those messages are sent via IP applications rather than the SMS platform.

Which brings me to the Commission Order on text-to-911.  For starters, I want to point out that AT&T committed to provide text-to-911, as well as bounce-back messages (where text-to-911 is not available), over the existing SMS technology and has implemented that commitment this year. This new Order would extend those obligations to smaller carriers and to “Interconnected” Text Messaging Applications – roughly defined as texting applications that allow a person to text anyone with a telephone number.  The problem is that a lot of the OTT apps actually used by consumers don’t use telephone numbers but are instead “closed” applications which only allow you to communicate with others who have downloaded the app.  Moreover, even the applications that have integrated with SMS, like iMessage, only fit the definition so long as the SMS technology remains in service; once that technology is retired, those apps no longer fit the definition.  So the “Interconnected Text Provider” extension doesn’t capture some of the larger applications out there and most of the OTT apps it does capture will lose those requirements when SMS technology goes away.  The Commission has put off consideration of those issues into a Further Notice.  Given that it has some hard decisions to make in that area and seeing how this market is in throes of a dramatic evolution, more analysis is probably not a bad thing.

There are two issues created by this Order, however, that potentially impact consumers’ confidence in text-to-911 actually working.  First, I think we will still have a consumer confusion issue surrounding the “Interconnected Text Provider” definition.  While smart lawyers at the agency will know which text providers fit the definition and which don’t, I am not certain those distinctions will be obvious to the hundreds of millions of consumers downloading texting applications.  Second, as explained above, the subset of OTT text services which meet the Interconnected Text Messaging Services definition satisfy their obligation by off-loading their 911 texts to the SMS platform native in the device. But unless the OTT service is integrated, like iMessage, it’s not clear at this time how or even whether this type of off-loading can be easily accomplished. 

All evidence points to the fact that texting is migrating quickly away from SMS to IP.  The Order assures SMS providers that as that migration evolves, SMS providers are permitted to retire that technology and migrate their services in a similar fashion to IP.  Our fear though is that despite those assurances, the heavy reliance on SMS technology will ultimately hinder the ability of SMS providers to retire that technology.  We fully support the Commission’s goal of ensuring that public safety obligations – including text-to-911 obligations – are platform and technology neutral.  But the FCC has much more work to do in the area of text-to-911 to actually accomplish that goal.

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AT&T Statement Regarding Commissioner Rosenworcel Remarks at APCO

Posted by: AT&T Blog Team on August 6, 2014 at 5:17 pm

The following may be attributed to Bob Quinn, AT&T Senior Vice President —Federal Regulatory:

“AT&T is fully supportive of finding a solution that enables 911 Emergency Responders to locate callers using cellular phones indoors.  Indoor location accuracy has been an issue that has perplexed the industry and the public safety community for years.  We believe we are making progress towards an innovative solution that will radically improve location accuracy for consumers across the United States and will fully comport with the principles enunciated by Commissioner Rosenworcel earlier today. APCO and NENA have led the effort, working with industry, to provide consumers with the most reliable 911 infrastructure in the world.  We look forward to continue working with both APCO and NENA to finally solve location accuracy for wireless 911.”

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TOPICS: FCC, Public Safety
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AT&T Statement on FCC’s AWS-3 Auction Procedures Public Notice

Posted by: AT&T Blog Team on July 23, 2014 at 6:13 pm

The following statement may be attributed to Joan Marsh, AT&T Vice President of Federal Regulatory:

“As a follow-on to the AWS-3 Coordination Public Notice released last week, the FCC today released a Public Notice outlining final AWS-3 auction procedures.  With these releases, the FCC has set the stage for this important and long-awaited auction.  We appreciate the hard work that has been necessary to bring this auction forward, including by the staff of the FCC and the NTIA, and by the DoD’s Chief Information Officer, and we are confident that those efforts will yield a successful outcome.  We look forward to reviewing the public notices in detail, as well as the DoD workbook that will hopefully be released later this month that will provide key technical information about DoD operations that are essential to assessing auction valuations.”

 

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Banning Paid Prioritization within a Viable and Sustainable Framework

Posted by: Bob Quinn on July 17, 2014 at 4:38 pm

Today, we filed comments at the FCC supporting the Commission’s attempt to re-craft the net neutrality rules that were vacated by the D.C. Circuit Court of Appeals in Verizon v. FCC.  In short, we have laid out a viable and sustainable framework utilizing Section 706 of the 1996 Telecom Act, which re-establishes the balance achieved by the 2010 Open Internet Order, including banning paid prioritization – where an ISP prioritizes packets over the consumer’s last mile broadband Internet access service without being directed to perform that prioritization by the consumer.  Paid prioritization has been at the heart of the net neutrality debate since it began in earnest over a decade ago (AT&T has blogged several times on this point in earlier iterations of this debate).  We disagree with those critics who claim that the Commission cannot ban paid prioritization under Section 706 and explain why they are wrong as well as why it would be much more difficult to justify a similar ban of paid prioritization under Title II.

AT&T also supported the FCC’s 2010 rules, including the ones which were ultimately vacated by the Verizon court.  We recognized then, and now, that those rules represented a purposeful and careful balance between ensuring the openness of the Internet and promoting the continued massive infrastructure investments necessary to deliver to American consumers the ever increasing amount of bandwidth needed by the enormously innovative products and services being created in technology communities across the United States.  The FCC reached this balance by utilizing a form of light touch regulation under Section 706 rather than decades-old Title II utility regulation requirements – requirements that would actually impose barriers to broadband infrastructure investment in contravention of Section 706.

History itself tells us that the FCC’s balanced, light touch approach was the right approach because it actually worked.  As the FCC has noted, from 2009 onwards, wireline and wireless broadband providers have invested more than $250 billion in broadband infrastructure.  On the other side of the equation, the Internet has remained open and consumers have accessed a dizzying array of new content, services and applications.  That is the environment that every public policymaker should want to preserve.

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