APCO, New York City Oppose CTIA’s WEA Petition But T-Mobile Supports It

January 4, 2017–The Association of Public-Safety Communications Officials-International and the New York City Emergency Management Department (NYCEM) have filed oppositions to a petition for reconsideration submitted by CTIA last month (TRDaily, Dec. 2, 2016) asking the FCC to reconsider portions of a wireless emergency alert (WEA) order adopted in September (TRDaily, Sept. 29, 2016). But T-Mobile US, Inc., supports CTIA’s petition.

In its petition filed in PS dockets 15-91 and 15-94, CTIA asked the Commission to (1) “[d]efer mandating implementation of embedded references until after feasibility testing and standards efforts are completed;” (2) “[c]larify the definition of ‘clickable’ links;” (3) “[c]larify that support for embedded references, to the extent required, need only be supported by new devices, and not older, legacy devices;” and (4) “[c]larify that, because they are inextricably connected, the compliance date for supporting Spanish-language Alert Messages will be concurrent with the compliance date for increasing the character-count of Message Alerts.”

“The enhancements to WEA should not be deferred without clear evidence of infeasibility, and if the Commission agrees to a deferral, it should be tied to a specific timeline for the industry to complete standards and testing to ensure feasibility consistent with reasonable industry practices,” APCO said in its filing. “APCO disagrees with CTIA’s proposition that the industry should instead be permitted to undertake these activities in an unspecified timeframe and rejects the suggestion that implementing embedded references might not be achievable at all.

“CTIA raises vague concerns about potential network congestion. Network congestion and potential ‘milling behavior’ were fully considered by the Commission as part of the rulemaking. CTIA does not provide evidence that circumstances have changed since the public comment period in these proceedings closed, nor does it provide specific information beyond how embedded references could impact individual websites,” APCO added. “The ability of websites to handle increased traffic is not relevant to whether or not wireless carriers require additional time to meet the implementation deadline. Indeed, when embedded URLs are available to alert originators, public safety officials will be able to take website capacities into consideration when choosing URLs to assist the public. APCO agrees with the Commission’s conclusion, based on numerous comments in the record, that embedded URLs in WEA messages would actually reduce network congestion. CTIA fails to provide new facts to refute this conclusion or explain why network congestion may not actually be worse without embedded references.”

APCO also noted that “CTIA seeks clarification of the meaning of the word ‘clickable,’ as applied to embedded URLs and phone numbers, and asks the Commission to clarify that support for embedded references is required only for ‘new, WEA-capable devices’ because certain legacy devices do not support embedded references or internet connectivity. Clarification is unnecessary, as the intent of the embedded references requirement has been clear throughout the WEA proceeding.”

In its opposition, NYCEM said the FCC should not delay for more than a year implementation of the embedded references mandate. It also said that delaying support for alerts in Spanish “would unnecessarily continue to underserve communities and if the Commission were to change the deadline to be concurrent with support for 360-character messages on 4G-LTE and future networks and devices, the deadline should be two years, not thirty months …”

“All devices, not only new devices, capable of receiving Alert Messages, should support embedded references, even if the device is not internet-capable …” NYCEM also said. “’Clickable’ has a common-sense definition and does not need to be clarified, but, if a definition is to be enumerated, the common-sense definition should be used,” it added.

But T-Mobile filed comments supporting CTIA’s petition. “Specifically, as discussed below, the Commission should: (i) defer implementation of the requirement to support embedded references in WEA messages until testing is completed demonstrating its feasibility; and (ii) limit the applicability of the embedded reference requirement to new device models,” T-Mobile said. “Moreover, the Commission should extend the deadline for complying with the Spanish-language alert requirement from two years to thirty months. Translating English-language alerts into Spanish often will increase the number of characters in a message. Extending the recently imposed deadline for Spanish-language alerts will synch the requirement with the deadline for implementing 360-character alerts and thus help minimize the potential problems associated with a lengthier Spanish-language alert message.” – Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily