WIRELESS CARRIERS URGE GRADUAL PHASE OUT OF ANALOG REQUIREMENTS

In NPRM, FCC is studying array of regulatory requirements that date to duopoly era of cellphone service. Proposal is part of agency’s 2000 biennial review of regulations. CTIA recommended Commission establish transition period before analog requirements disappeared and remove itself from standard-setting in cellular industry. “Industry standards-setting groups are better able than government to establish and maintain technical standards and modify those standards as technology evolves,” CTIA wrote. Group backed proposal to eliminate original analog cellular channelization plan, modulation types requirement and in-band emission limits. “Not only can CMRS equipment manufacturers and carriers more efficiently address these issues, the Commission’s rules have the effect of creating a static service and equipment market for cellular systems,” CTIA said. Instead, it said, industry should be allowed to establish its own standards, saying: “Carriers can be expected to continue to deploy analog technology that is interoperable with other analog systems, notwithstanding the absence of a Commission rule mandating such interoperability.”

Several groups that represent consumers with hearing disabilities expressed strong reservations about outright repeal of analog requirements. Telecommunications for the Deaf Inc. (TDI) told FCC “a long history of public policy on access to telecommunications will be undone if companies are allowed to relinquish their responsibilities to offer analog service before making their digital technology accessible.” Group said analog cellular service transmitted TTY signals at “acceptable level” of accuracy and analog handsets didn’t interfere with hearing aids. Some analog cellphones also are hearing aid compatible, group said. “These accessibility benefits cannot be found in digital wireless technology,” TDI said. It said carriers’ withdrawal of analog services should be contingent on their ability to provide digital wireless accessibility. National Assn. for the Deaf (NAD) warned that there “is no certainty that digital equipment will become compatible in the near future, despite the promises of the digital industry.” It asked that accessible analog services not be eliminated “until new digital services are fully field tested for reliability of less than 1%-2% garbling incidence in a lab and field setting.” NAD asked there be no additional delays in FCC deadline by which all digital equipment and services must be accessible to TTY users. It urged agency to implement deadline for all equipment to be compatible with hearing aids.

In other areas, CTIA proposed that its Cibernet subsidiary take over System Identification Number (SID) management. Qwest Wireless urged FCC to not “prematurely” rollback analog requirements, recommending 5-year transition, which it said would be sufficient to “avoid undue disruption to customers and to allow for their education as well as migration to different arrangements.” Qwest cited concern that analog customers not be “stranded.” Carrier cited potential impact on roaming because AMPS was main technology used for that function. “Digital roaming will not be pervasive until digital networks are more fully built out and until trimode handsets are widely deployed,” Qwest said. “The immediate elimination of analog roaming would have significant detrimental consequences for regional carriers, like Qwest, who rely more heavily on roaming than do nationwide providers.”

Cingular Wireless said doing away with analog requirement would foster competition because carriers providing analog service in rural areas would have to convert their networks to digital. “As a result, other CMRS providers will have an incentive to build out their digital networks into these rural areas rather than relying (as they do currently) on roaming arrangements with analog cellular providers in order to market nationwide coverage plans,” Cingular said. Carrier said TTY technologies were expected to become compatible with digital networks before complete transition from analog to digital. If FCC decided to eliminate analog requirement, it said, “the transition from analog to digital will not occur immediately but rather at a pace dictated by the market.” Rural Telecommunications Group (RTG) sided with several wireless carriers in advocating 5-year national phase-in for analog requirements to sunset. “If the Commission eliminated these rules on a flash-cut basis, most of the largest carriers would abandon the use of analog technology immediately,” RTG said. Gradual implementation is particularly relevant to small and rural carriers, which are more dependent than their larger counterparts on roaming, RTG said.

In backing 5-year transition, Verizon Wireless said 40 million cellular customers still used analog systems and told FCC that telematics, telemetry and data services were based on cellular digital packet data. Even if analog coverage was eliminated only in some markets, drivers with telematics equipment such as Onstar in their cars wouldn’t be able to roam in those areas, carrier said. Like other carriers, Verizon also cited extent to which most phones donated to 911 programs that aided elderly customers or battered women were analog models. One potential goal of eliminating analog requirement cited by FCC proposal is that it may free up spectrum for more efficient digital technologies. But Verizon said doing away with requirement wouldn’t turn loose “a significant amount of new spectrum.” Carrier said analog customers typically didn’t generate as many min. of use as digital customers, so not as much spectrum needed to be dedicated to AMPS users.

Verizon backed parts of proposal that weighed elimination of: (1) Requirement that licensees inform subscribers of reliable service areas. (2) Mandate that licensees notify FCC of denial of service due to lack of capacity. (3) Financial demonstration requirement, except in cases involving comparative renewal proceedings.

OnStar, which provides automatic crash notification in vehicles using analog cellular network, told FCC AMPS requirements should remain in place until phase-in plan was implemented. Such plan should take into account vehicle life cycles because OnStar system is embedded into cars, which can have average life of 8 years, company said. Company expects to have 4 million subscribers by 2003. Now, no digital equivalent exists to match ubiquity of nationwide coverage of analog networks, OnStar said. It recommended standard for communication for voice and data be developed for emergency services within digital. “The importance of standardization should not be underestimated,” OnStar said. “Without it, future systems cannot be confidently designed nor offered with the assurance that the automatic crash and emergency notification features will connect.”

Besides backing 5-year transition period, Sprint PCS recommended Commission adopt plan to ensure “orderly process for consumers and carriers,” including: (1) Creation of Web page addressing sunset data and its meaning. (2) Approaches to ensure that AMPS capability remained available to analog customers during transition. (3) Provision of AMPS credit of 10 MHz against spectrum cap for every cellular carrier providing analog services. That would give cellular carriers ability to acquire 55 MHz of CMRS spectrum in most areas, except rural areas where cap would rise to 65 MHz. “This addresses the capacity constraint concerns raised by some cellular carriers regarding maintenance of the AMPS requirement,” Sprint said.