AT&T Statement on FCC’s Outage Reporting Rules for Submarine Cables

Posted by: AT&T Blog Team on June 24, 2016 at 12:29 pm

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

“Submarine cable facilities have important national security and commercial implications.  For this reason, a coalition representing cable providers sought to give the FCC constructive input on a meaningful yet reasonable cable outage reporting framework.  Today’s order, however, perpetuates flawed assumptions from the recent Part 4 Order on terrestrial facilities – such as requiring outage reports for events that simply affect redundancy of service – and woefully underestimates the costs and burdens of compliance. These new regulatory requirements and deadlines will do little to enhance the resiliency of submarine cable facilities.

“Under this new regulatory regime, providers will be required to file an initial report within eight hours of determining that an outage is reportable, decreasing to four hours over time, and an interim report within 24 hours of receiving a cable repair plan.  International undersea cables, which are often jointly managed by a large number of companies from many different countries, extend from continent to continent and are not easily accessible.  The adopted intervals for the initial report are insufficient given the logistical issues associated with international operations and the significant amount of coordination necessary amongst companies. And changing the interval over time needlessly increases the costs and complexity of implementing the new requirements.

“Further, the order’s conclusion that these new reporting requirements be implemented within six months is unreasonable and disregards industry input.  Given the amount of coordination, and investments in new technology for older submarine cables necessary to implement a new reporting system, members of the industry had sought as much as 18 months to put the new framework in place.  AT&T anticipates that it will require much longer than six months for many of our submarine cables, which are older and jointly owned with multiple foreign partners.

“This new framework will impose substantial costs and burdens on providers without identifying corresponding benefits during times when the principal objective should be repairing the undersea cable facilities, not completing unnecessary and redundant reporting to the government.”

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Special Access Doublespeak

Posted by: Frank Simone on June 22, 2016 at 10:23 am

I’m often struck by the doublespeak that takes place in DC and, particularly, at the FCC when companies come to the agency to argue that the Commission should regulate their competitors. The Special Access proceeding at the Commission is one of those special dockets that is a real breeding ground for what I like to call “both sides of our mouth” (BSOM) advocacy.  Whether it’s Verizon calling to regulate its cable competitors, BT arguing for lower special access rates than it charges its competitors in England, or Sprint-progeny Windstream arguing to re-regulate everyone’s retail rates but their own, this proceeding is a showcase for that special brand of BSOM advocacy.

But one company truly rises above the rest when it comes to saying one thing to the FCC and another to investors – Sprint.  Not even two months ago, Sprint came to the FCC and argued that it has no choice but to purchase business broadband services from incumbent carriers because only they provide those connections for the vast majority of buildings with business data service (BDS) demand in the country.

Imagine my surprise then when I saw a recent Fierce Telecom article on Sprint’s Ethernet strategy. Once again, a Sprint executive’s candid statements reveal the reality that betrays their FCC advocacy. In the article, Sprint stated that cable business data services, specifically Ethernet over DOCSIS, will provide them with a competitive alternative to existing special access services and fill out an Ethernet footprint that covers “95 percent of the country.” Yet at the Commission, Sprint continues to discredit cable DOCSIS services as an alternative to incumbent carrier special access services.

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AT&T Statement on U.S. Court of Appeals Net Neutrality Decision

Posted by: AT&T Blog Team on June 14, 2016 at 11:04 am

The following may be attributed to David McAtee, AT&T Senior Executive Vice President and General Counsel:

“We have always expected this issue to be decided by the Supreme Court, and we look forward to participating in that appeal.”

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AT&T Statement on Bogus
Set-Top Box Privacy Complaint

Posted by: AT&T Blog Team on June 9, 2016 at 12:14 pm

The following may be attributed to Jim Cicconi, AT&T’s Senior Executive Vice President of External and Legislative Affairs:

“AT&T’s use of anonymous and aggregate set-top box information is entirely consistent with the statute. Our disclosures tell our customers exactly how we use that data and provide tools for customers to opt out.  Frankly, this complaint is bogus, and seems mainly designed to distract the public from the overwhelming bipartisan opposition to the FCC’s controversial set-top box plan.  That plan itself will erode existing consumer privacy protections, not to mention its many other harms.  Because the plan’s few remaining supporters have no answer to that charge, they’ve decided to invent a false privacy claim.  This smacks of desperation, and it also carries the whiff of hypocrisy.  It’s further proof, if any is needed, that the plan’s supporters have lost the public policy debate on this issue.”

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The Privacy Misdirection

Posted by: Bob Quinn on May 27, 2016 at 8:02 am

Today, we will file our official comments in the Commission’s privacy proceeding. The fundamental message will be that the FCC should follow the FTC’s lead and adopt a notice and consent framework for privacy that is entirely consistent with the FTC framework that has governed since the inception of the Internet.  That is contrary to the FCC’s current proposal neatly summarized by FCC Chairman Wheeler at a recent hearing: “For decades, the Commission has steadfastly protected consumers against misuse of their information by [telephone companies] ….  It only makes sense that consumers should enjoy similar privacy protections in the world of broadband.”  The problem with the FCC’s current approach is that it doesn’t reflect the reality of how the internet actually works.

That “misperception” is captured by a wrong-headed conclusion in the NPRM that ISPs are uniquely in a position to develop highly detailed and comprehensive profiles of their customers.  It is just not true.  In a prior blog, I talked about Prof. Peter Swire’s paper commissioned to help educate the FCC on the different data collection capabilities of all the platforms operating in the internet ecosystem.  [Not] surprisingly, that paper was neither cited nor referenced in the NPRM.

So, it shouldn’t be a shock that a recent Future of Privacy Forum blog post explained that the FCC’s proposed rules reflect “a fundamental misunderstanding of the current online advertising ecosystem, which is fully capable of tracking individual behavior across the Internet as well as between devices.” The post visually illustrates how a consumer’s visit to a single website (WebMD.com) actually results in information being shared with, and received from, 24 third party sites. Once these connections are established, these ad networks are then able to track the consumer and link data about that consumer as she/he browses the internet. If the connection is to a party that has personal information about you (e.g., a social media or email platform), that third party can easily append this new web browsing information back to your personal profile of your internet activity. If the connection is made via a mobile device, the unique device advertising id allows the third party to add to or build a similar profile of the internet activity specific to that device.  So, when the Chairman testified that when you make a decision to access Google, WebMD or Facebook that “only one entity collects all of that information,” he was just flat out wrong.

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