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'Working as Intended'

Wireless Industry Opposes New Rules for Wireless Emergency Alerts

The record is clear that performance measurements proposed in a Further NPRM on wireless emergency alerts are “incompatible with the existing WEA system and could raise privacy concerns,” CTIA said in reply comments. Comments were posted Wednesday in docket 15-91 on the April FNPRM (see 2204190053). In initial comments, APCO and the National Weather Service asked the agency to impose reporting requirements on carriers (see 2206220033).

The voluntary WEA system is “working as intended to save lives across the nation,” CTIA said. The 2021 national WEA test (see 2108110067) was “a resounding success,” the group said: “Moreover, the accuracy of WEA is being enhanced further through implementation of WEA 3.0 capabilities, which providers have fully activated on their networks and is now dependent on the penetration of WEA 3.0-capable devices into the market.”

The ATIS Wireless Technology and Systems Committee said some information can’t be collected “because there is no end-to-end reverse communication channel that can be used for WEA performance reporting.” Time and location reporting as proposed by the FCC would be “largely outside” carriers’ control and “require development by multiple stakeholders, including new mobile device capabilities, to capture the data and correlate it to the proper alert,” ATIS said: “This reporting could create additional challenges and complexities that could negatively impact network capacity and would require global standardization and adoption by all WEA stakeholders.”

Some proposed reporting requirements in the FNPRM aren’t feasible, Verizon said: “Wireless companies do not have access to or maintain much of the information on which the Further Notice seeks comment, due simply to the system’s design.” Verizon said as WEA matures, some kind of reporting would make sense. “An annual filing, based on coordinated annual testing or other standard data otherwise already collected and maintained, would address the Commission’s legitimate interest in WEA system performance without imposing unnecessary new paperwork and administrative burdens,” the carrier said.

The record overwhelmingly demonstrates that WEA is extremely effective in delivering emergency alerts to the public” with no need for major changes, said T-Mobile. Only three comments urge rule changes requiring the WEA system to generate performance data “and these commenters may not fully understand the design and technical capabilities of the system,” T-Mobile said.

NCTA said mobile virtual network operator shouldn’t be required to participate in alerts “because they have no ownership or control over the wireless network elements needed to support WEA and they are fully dependent on the underlying … provider.” MVNO subscribers with a WEA-capable device “receive WEA messages from the underlying facilities-based provider, and the MVNO plays no role,” cablers said.

The Colorado Council of Authorities said during an emergency, “immediate feedback or real time data as to the delivery success or confirmed rate of WEAs is not helpful to an alert originator or emergency service provider, especially at the risk of increasing traffic on already overloaded 911 facilities and infrastructure.” Information provided later could be more beneficial, the council said. Big City Emergency Managers supported APCO’s calls for changes to the rules.