March 20, 2017–T-Mobile US, Inc., has raised concerns about a notification requirement in a draft FCC order designed to tackle contraband wireless devices in correctional facilities. The item is on the agenda for the agency’s March 23 meeting.
In ex parte filings in GN docket 13-111 reporting on conversations with FCC officials, T-Mobile said that it “urged the Commission to defer consideration of the notification process – requiring CMRS licensees to notify Contraband Interdiction System (‘CIS’) operators at least 90 days prior to adding new frequency bands or air interface technologies – until a more complete record is developed on the subject. The record on this issue is in need of further development as it relies on only a handful of comments from CIS operators, with no comments from CMRS licensees on the proposed requirement.
“T-Mobile believes that a more complete record will demonstrate that the burdens associated with the notification requirement will outweigh any potential benefits,” the carrier added. “The draft Order recognizes that the notification requirement will impose costs on CMRS providers, but due to the lack of comments from CMRS providers the Commission relies only on its ‘general understanding and prediction of likely costs.’ However, when evaluating, the Commission needs to consider all potential consequences of its draft rule, with special attention provided to the detrimental effects associated with delays in deployment. At a minimum, the notification requirement will impede carrier network management flexibility and could delay the rollout of new technologies which would negatively impact consumers and carriers. Carriers should be permitted to deploy new technologies and frequencies as soon as possible, rather than delay deployments for 90 days.”
T-Mobile added that “the notification requirement will provide virtually no benefit. Best practices should include CIS providers conducting spectrum scans as part of daily operations to detect new operational bands and technologies. These scans, which also can detect air interfaces in use, obviate the need for a notification requirement. The fact that CMRS licensees and CIS providers already are coordinating and implementing scanning protocols also undermines the unsubstantiated claims of the few CIS providers urging adoption of a notification requirement.
“Based on the foregoing, T-Mobile urges the Commission to defer consideration of the notification requirement pending development of a more detailed record so that the burdens and benefits of the requirement can be properly assessed,” the filing added. -Paul Kirby, firstname.lastname@example.org