CTIA Counters APCO Arguments on Bounceback Requirements for Roaming Customers
CTIA cited support from wireless carriers and the National Emergency Number Association in arguing that the FCC should alter the roaming requirement embedded in the commission’s May 17 text-to-911 order. CTIA responded directly to the Association of Public-Safety Communications Officials, which said earlier this month the requirement should stand as written (CD Aug 19 p4). The order requires all carriers and interconnected text messaging providers to send an automatic bounceback text message to consumers where text-to-911 service is not available, starting Sept. 30.
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"The relief CTIA’s Petition requests will not prevent consumers who are roaming from receiving the bounce-back message mandated under new rule Section 20.18(n)(3),” CTIA said. Instead, CTIA is only asking that the responsibility for the bounceback message lie with the subscriber’s home carrier, not the serving carrier, the group said. “In accordance with the weight of the evidence filed in this proceeding, the relief CTIA seeks will simply allocate carriers’ legal responsibilities in a way that aligns with technical realities,” CTIA said (http://bit.ly/14B9J3c). “The Commission’s Emergency Access Advisory Committee ... the wireless industry, and other expert organizations all have provided substantial evidence demonstrating that compliance with the Commission’s new roaming requirements is not technically feasible for serving carriers at this time."
NENA didn’t file reply comments, but reported last week on a meeting with FCC officials (CD Aug 23 p13). NENA Regulatory Counsel Telford Forgety told officials NENA “does not oppose the petition of CTIA,” according to an ex parte filing (http://bit.ly/19LUcll).
The Competitive Carriers Association filed in support of CTIA, noting that APCO’s main concern was ensuring that roaming subscribers who attempt to text 911 get a bounceback message when they're unable to do so. The “aim” of CTIA’s petition “is to provide structure and clarity as to the roles and responsibilities of both home and roaming network carriers when a subscriber is roaming, ‘in a way that aligns with technical realities,'” CCA said (http://bit.ly/13WTTl4). “CCA and its members continue to support the overarching goal of providing text-to-911 capability for the benefit of consumers,” the group said. “In addition to its policy advocacy on this issue, CCA is working on business solutions to both the Commission’s bounce-back requirements, as well as its stated goal of ubiquitous text-to-911 capability."
AT&T also filed in support of CTIA. “In our post-Bounce-Back Order discussions with the Public Safety and Homeland Security Bureau ... AT&T has made it clear that it believes the bounce-back message rule should be clarified,” the carrier said (http://bit.ly/18iGKyR). “As written, the question of which covered text provider has the obligation to provide a bounce-back message when a subscriber is roaming is at best ambiguous. In our view, the Home Carrier (and not the Host Carrier) should have the express obligation to provide a bounce-back message when the Home Carrier’s subscriber is roaming on another provider’s network, because, among other things, the present architecture of SMS texting will not allow the Host Carrier to perform this function."
"CTIA’s petition correctly describes the problems with Section 20.18(n)(7), which can be read to require serving carriers to generate a bounce-back message for subscribers roaming on their networks who attempt to reach 911 via text message,” T-Mobile said (http://bit.ly/17cYBMn). “This rule as currently written is problematic, because it is not technically feasible for serving carriers to perform this function.”