Red Herrings and Bogeymen: Setting the Record Straight on TruePosition’s Misinformation Campaign

Posted by: AT&T Blog Team on December 12, 2014 at 10:45 am

By Joe Marx, AT&T Assistant Vice President of Federal Regulatory

TruePosition and its fully-controlled FindMe911 coalition is at it again, spreading misinformation and ill-informed criticisms of the APCO, NENA, and Wireless Industry Roadmap for Improving Location Accuracy.  Others have blogged to explain the benefits and merits of the Roadmap, and it’s our experience that the more people hear about the voluntary agreement and fully understand the enormous improvements it will bring to finding wireless callers in times of emergency, the more they like it and support it.

We don’t expect to convert TruePosition, or its well-known spokesperson Jamie Barnett, but we can set the record straight on the misinformation campaign they are waging in an attempt to raise fears, uncertainties and doubts.

TruePosition alleges that the carrier approach depends entirely on “new and untested technologies.” Setting aside the fact that TruePosition did not participate in the independent test bed established by the FCC’s Communications Security, Reliability and Interoperability Council (CSRIC) and that its technologies are not mentioned even once in the FCC’s test report, this allegation is simply not true.  Wi-Fi and Bluetooth technologies have been in use for years in commercial location services, and are central to the current wireless ecosystem in ways that will drive strong incentives for further innovation and lasting relevance for years to come. By associating enhanced 911 (e911) with commercial location services, public safety can harness that innovation to its direct benefit – and the benefit of wireless consumers everywhere – rather than having to settle for proprietary 911-only location solutions that evolve only in response to new mandates. In contrast, the database approach of the Roadmap enables continual improvements in indoor location accuracy without need of a lengthy carrier-deployment process.

TruePosition also wrongly suggests that the Roadmap doesn’t require carriers to provide dispatchable address/location. Again, not true. There are specific requirements for the carriers to build a dispatchable address database and to enable 100% of handsets sold to support the dispatchable address functionality. And given this investment and increasingly difficult performance metrics, carriers will use dispatchable addresses to meet these milestones. It is a win for public safety and a win for consumers.

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AT&T Statement on New
Connect America Fund Rules

Posted by: AT&T Blog Team on December 11, 2014 at 1:48 pm

The following statement may be attributed to an AT&T spokesperson:

“In 2011, the FCC began comprehensive reform of its universal service programs to transition them from voice services to broadband. Today’s action is a significant milestone on this ambitious agenda. CAF II will target universal service subsidies to places where there is not an adequate business case for broadband. Moreover, the FCC appears to be taking significant steps toward phasing out obsolete voice obligations. We look forward to learning more details of the FCC’s action when they are available.”

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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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