If T-Mobile has a Beef,
It Should File a Complaint

Posted by: Joan Marsh on December 10, 2014 at 4:11 pm

A few weeks ago, a group of advocates calling themselves “T-Mobile Petition Supporters” filed an ex parte purporting to show that the Commission should grant T-Mobile’s data roaming petition.  T-Mobile itself then weighed in with yet another letter in the record.  Neither filing offers anything new of substance, much less provides any basis to grant T-Mobile’s petition.

As AT&T has previously demonstrated, T-Mobile’s petition itself shows that data roaming is available at commercially reasonable rates, which have been declining rapidly, and that the Commission’s rules are working.  Although it is evident that T-Mobile and its supporters would like a different set of rules than those adopted in the Data Roaming Order, to the extent they believe that AT&T or anyone else is not offering data roaming services on commercially reasonable terms, they have a remedy:  they can file a complaint.

In fact, the most recent ex partes filed by T-Mobile and its “supporters” underscore why that is the proper context to address their claims.  Let’s look in more detail at the supporters’ letter.  First, the parties at the meeting apparently expressed disbelief that AT&T is a net payor of data roaming expense.  They may be shocked by that, but it’s true.  AT&T currently pays more in data roaming expense than we receive in revenue from our data roaming partners.

The ex parte goes on to complain that AT&T has not provided any information or data to support these claims, “so there is no record-based way to determine the veracity of these assertions.”  Actually there is.  Again, T-Mobile or one of its supporters could file a complaint.  In that context, we could provide the exact record-based evidence that this group admits is essential for the Commission to assess commercial reasonableness.  Surely, the development of such a record is a far better way to resolve fact-based disputes than reliance on general expressions of disbelief voiced in a group advocacy session.

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AT&T Statement on FCC’s
Proposed IP Transition Rules

Posted by: AT&T Blog Team on November 21, 2014 at 2:45 pm

Please attribute the following to Bob Quinn, AT&T Senior Vice President of Federal Regulatory and Chief Privacy Officer:

“The principles the FCC’s IP Transition NPRM seeks to uphold – public safety, reliability, universal connectivity, competition and consumer protections – should be implemented in a manner that reflects the many marketplace and technological developments that today are driving the transition to next generation networks.  Customers are demanding higher speeds and more capacity, and a vibrant, competitive environment exists to provide robust, innovative options. The success of what Chairman Wheeler describes as the Fourth Network Revolution can be achieved by adapting the FCC’s technology transition framework in recognition of these realities while preserving the ability for all industry participants to continue to invest in faster and better Internet for consumers.”

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Welcome to the World
Of Title II Regulation

Posted by: Hank Hultquist on November 20, 2014 at 10:34 am

Occasionally a proponent of Title II regulation of Internet access will ask, in effect, what’s so bad about Title II? What follows is a cautionary tale about the absence of regulatory certainty in the world of Title II regulation; a world into which so many net neutrality proponents want to throw the Internet.  I think this story speaks volumes about the kind of regulatory stability – so crucial to maintaining incentives to build world class Internet infrastructure – we can expect from the FCC in the years to come.  To fully understand how the Title II world undermines regulatory stability, enables regulatory capture and ultimately harms consumer welfare and innovation, let’s go back to 2010.

Once upon a time, back in 2010, AT&T was engaged in a dispute with a company called YMax (known more widely as MagicJack) over bills that AT&T was receiving from YMax for exchanging traffic. AT&T noticed that YMax was billing it for a service called “local switching.” Local switching is basically the process of peeling individual calls off of inter-office trunks on which traffic is commingled, and placing them onto the lines, or local loops, that connect to particular subscribers. When AT&T investigated YMax’s practices, we discovered that YMax was not actually connecting trunks with lines. Instead, it was simply directing all the calls it received in a commingled fashion on to the Internet. The calls then reached their destinations through the efforts of Internet backbone providers and ISPs unrelated to YMax.

AT&T filed a complaint with the FCC and argued that YMax was charging us for a service, local switching, that it was not providing. YMax argued that in fact it was providing the equivalent of local switching by connecting trunks to a “virtual” loop created by the Internet. The FCC found in favor of AT&T and said “if this exchange of packets over the Internet is a ‘virtual,’ loop, then so too is the entire public switched telephone network – and the term ‘loop’ has lost all meaning.”

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AT&T on Industry ‘911’ Location Accuracy Consensus Plan

Posted by: AT&T Blog Team on November 18, 2014 at 6:50 pm

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

“AT&T is proud to be part of the ‘911’ Consensus Plan filed today.  We have long relied on expertise from APCO and NENA to lead the way on 911 issues, and believe the robust framework filed today will respond to public safety’s call for more accurate location information, particularly for calls originating indoors.  The framework seeks to leverage indoor location technologies increasingly available for commercial applications to deliver to first responders a ‘dispatchable’ location for indoor 911 calls – a unique civic address, including critical apartment, floor or suite information.  This approach improves on current technology as well as the solutions proposed by certain vendors that provide only a rough approximation of a caller’s location, a result that is far short of the dispatchable address that first responders need and the public deserves.

“APCO and NENA should be applauded for their continued leadership in this area and we look forward to working with the Commission on implementing the next generation of location solutions.”

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AT&T Commends FCC’s Changes to 800 MHz Licensing, PSD Rules

Posted by: AT&T Blog Team on November 11, 2014 at 10:05 am

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

“We commend the FCC for modernizing and streamlining the cellular licensing rules by transitioning from site-by-site to geographic area licensing. The site-by-site cellular licensing regime was put in place more than 30 years ago. By its actions yesterday, the FCC ensures that services in the 800 MHz band will be more aligned with the other commercial wireless mobile services, which are licensed on a geographic basis. In addition, the FCC order will lessen the administrative and paperwork burden on both licensees and Commission staff. We also look forward to prompt action on the companion notice regarding rule changes to allow the use of power spectral density (PSD) to measure power in the cellular band — changes that are urgently needed to support the continuing deployment of LTE services throughout the country.”

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