Facts not Fiat

Posted by: Joan Marsh on August 26, 2016 at 8:52 am

Today, AT&T filed its response to a July 27 Notice of Apparent Liability (NAL) issued by the FCC for alleged violations of the lowest corresponding price (LCP) requirements of the E-rate program.  These rules say that in order to participate in the E-rate program, a carrier must charge a participating school, library or consortium no higher than the lowest price that it charges to any similarly situated non-residential customer for similar services.  To be clear, we wholeheartedly support the E-rate goals of providing schools and libraries with affordable broadband and telecommunications services. The Bureau’s arguments, however, that we applied the LCP rule incorrectly are factually wrong, they deviate from the FCC’s own rules and existing precedent, and they continue the Enforcement Bureau’s troubling pattern of “rulemaking through enforcement.”

The facts of the case aptly demonstrate that no actual FCC rules were violated.  First, the Bureau alleges that AT&T should have provided two school districts rates based on one-year contracts despite the fact that the schools were buying services on a month-to-month basis.  Contract term is a regular and routine distinction in rates, and the Commission has previously expressed the view that length of contract is a valid basis to price services differently among customers.   In this case the school districts at issue never asked for annual contracts, never signed annual contracts and did not behave as though they had annual contracts.

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Univision Agrees to Temporarily Unblock Channels

Posted by: AT&T Blog Team on March 8, 2016 at 2:41 pm

Attribute the following to an AT&T spokesperson:

“We appreciate Univision agreeing to our request earlier today to unblock their channels temporarily during the upcoming Democratic Presidential Debate. This is the right thing to do for our Spanish-language customers as we continue working toward an agreement with Univision.”

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TOPICS: Other Thoughts
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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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‘911’ Location Accuracy:
Getting to Dispatchable Addresses

Posted by: Joan Marsh on June 27, 2014 at 11:39 am

TruePosition recently commissioned and produced a test report purporting to show that its proprietary technology can meet the FCC’s proposed benchmarks for locating wireless 911 callers horizontally and vertically indoors.  The tests were run on a test bed in Wilmington, Delaware outside the context of the established CSRIC process specifically designed to assess new “911” location technologies.  And although TruePosition claims the test relied on commercial off-the-shelf technologies, it did not and the technologies used by TruePosition are not fully supported in any wireless network today.  Moreover, the technology used would not provide complete location information in that it does not have the capability to provide a vertical estimate of location.  Indeed, TruePosition simply ignored that component of the FCC’s proposed rules as someone else’s problem to fix, while enthusiastically encouraging the FCC to adopt unachievable regulations for carriers to meet.

Beyond these significant limitations, the testing highlights even bigger concerns.  The fact is that the approach proposed by TruePosition is, at the core, antithetical to the design of modern 3G and 4G networks.  TruePosition’s proposed solution depends on hardware installed at each base station seeing the handsets being served by other base stations. Modern wireless networks are designed to minimize the number of base stations interacting with a handset to prevent interference. TruePosition simply ignores this design feature by proposing a solution, yet undefined in industry standards bodies, that would require wireless carriers to essentially “power up” a handset during a “911” call.  They also ignore the potential for the untenable interference that such an approach would likely create.

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AT&T Statement on the Congressional Trade Priorities Act of 2014

Posted by: AT&T Blog Team on January 9, 2014 at 3:15 pm

Washington, D.C. – Today, Senator Max Baucus (D-MT), Senator Orin Hatch (R-UT) and Representative Dave Camp (R-MI) introduced the Congressional Trade Priorities Act of 2014 to reauthorize Trade Promotion Authority (TPA). The following statement may be attributed to Tim McKone, AT&T Executive Vice President-Federal Relations:

“We commend Senate Finance Committee Chairman Max Baucus, Ranking Member Orrin Hatch and House Ways and Means Committee Chairman Dave Camp for their efforts to introduce a bipartisan bill that will update and renew Trade Promotion Authority (TPA). We believe the passing of this legislation will align 21st century trade agreements with 21st century TPA rules.

“Taking this critical step forward will strengthen our U.S trade policy to ensure new trade agreements provide us with the opportunity to further U.S. economic growth and investment. We look forward to working with the Congress and the Administration in order to advance U.S. trade agreements, as it will ultimately create new growth opportunities for the U.S economy.”

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