On December 13, 2011, the Michigan Legislature passed House Bill 4683, which delays the implementation of Michigan Public Service Commission (MPSC) rules governing the responsibilities of MLTS operators in ensuring that the specific location of 9-1-1 callers can be identified by emergency response personnel.  The rules, which the MPSC adopted on October 20, 2011 in Case No. U-16439, seek to prevent the delays in emergency response time likely to occur when an MLTS provides only a main telephone number and address to a public service answering point (PSAP).

“This extension will give the owners and vendors of multiline telephone systems more time to prepare for implementation,” said State 9-1-1 Administrator Harriet Miller-Brown.

To aid the compliance process, the State 9-1-1 Committee (SNC) has established a work group, which will be working with the MPSC to develop an MLTS implementation guideline for providers and owners.  The work group is seeking input from owners and vendors, which should be submitted to Ms. Miller-Brown by email at millerhr@michigan.gov.

“We encourage anyone with questions to direct them to me by email, so that I can direct them to the work group,” Ms. Miller-Brown said.

The work group is expected to begin meeting just after the first of the year.  The implementation guideline, when complete, will be posted on SNC and the MPSC web sites, http://www.michigan.gov/snc and http://www.michigan.gov/mpsc.

At present, “Enhanced 9-1-1” (E9-1-1) service, which allows a caller’s telephone number and service address to be displayed at the PSAP, is widely – although not universally – available.  However, when an MLTS serves numerous users spread out over a large building, multiple floors, or multi-building complexes, the caller may be physically remote from the central telephone number and main address identified to the PSAP.  Emergency response personnel may have significant difficulties finding a caller who is located on a different floor or even in another building, some distance from the central address.

“If the caller is unable to provide his or her location and no one else is available to provide assistance, such a lack of location information can prove fatal,” said Bob Currier, an Executive Board Member of the National Emergency Number Association (NENA).

“Fortunately, there are technical solutions to this challenge that are currently being offered by numerous service providers,” Mr. Currier said.

With the new systems in place and functioning properly, emergency response time will be significantly faster – potentially saving lives and preventing property damage.

MLTSs are widely used in settings such as businesses, university campuses, governmental properties, shopping complexes, manufacturing plants, schools, and hospitals.  The MPSC rules require operators of MLTSs to assure that their systems are capable of routing 9-1-1 calls to the PSAP in a manner that pinpoints the location of the communications device used by the caller within an identifiable portion of a structure (such as a room) that is not more than 7,000 feet.  Vendors will work out system software in conjunction with telephone service suppliers.  Individual office systems may manage their telephones in varying ways, and will develop compliant protocols appropriate to their individual needs.

MLTSs will be required to comply with the “specific location” mandate regardless of system technology. However, MLTSs that do not have access to E9-1-1 service are exempt from the rules until E9-1-1 becomes available to them.

The SNC recommended the enactment of the “specific location” requirement for MLTS systems in a report to the Legislature in late 2006.  The Legislature then passed Public Act 165 of 2007, which charged the MPSC, in consultation with the SNC, to develop rules governing implementation of the requirement.  That original legislation set the compliance deadline at December 31, 2011.  The MPSC began an informal process in May 2009, soliciting comments from interested stakeholders.  MPSC staff held informal meetings with the 9-1-1 community, including MLTS operators, industry members, and the SNC, on April 27, 2010 and June 2, 2010. On February 25, 2011, the MPSC formally opened Case No. U-16439, provided notice to interested parties, and then held public a public hearing on April 19, 2011.  The MSPC also received and considered numerous written comments.  An SNC work group actively participated with the MPSC in the development of the rules.

Ms. Miller-Brown indicated that in its 2006 report to the Legislature, the SNC recommended an 84-month compliance period. The extension provided by House Bill 4683 brings the implementation deadline “very close” to this original recommendation, she said.

The SNC holds quarterly meetings.  Meeting times are posted on the SNC web site.

“We invite anyone who has an interest to attend meetings, which are open to the public,” Ms. Miller-Brown said.   She also invites questions by telephone at 517-241-0080.

To learn more about the SNC, visit: http://www.michigan.gov/snc

To learn more about NENA, visit: http://www.nena.org.

To learn more learn more about the MPSC, visit http://www.michigan.gov/mpsc.

AT&T’s takeover of T-Mobile is illegal under the Communications Act, Public Knowledge will argue in a filing to the Federal Communications Commission (FCC).

The Communications Act (Sec. 314) bars the FCC from approving transactions that lessen competition or restrain commerce between the U.S. and foreign countries.  In its reply comments to the FCC, PK said:  “As the record shows, even under the most cramped and restrictive reading of the statute, Section 314 prohibits the transfer of facilities and assets between AT&T and Deutsche Telekom. The Commission has received numerous submissions from foreign carriers, foreign governments, and others that the combination of assets will “substantially lessen competition” in international roaming for GSM-based carriers.”

Public Knowledge noted the law creates “an absolute bar” to approving the transaction:  “Undoubtedly, a transaction that reduces the number of possible international roaming partners from 2 to 1 “has the effect” of substantially lessening competition, if not creating an unlawful monopoly, between those geographic regions and “any foreign country” in direct violation of the language of the statute.”

In its filing, PK will also argue AT&T has not been forthright with policymakers about its plans to accept further universal service fund (USF) support.  In its formal papers filed with the FCC, AT&T said the FCC should not impose any USF-related conditions.”  However, in testimony to the Senate Antitrust Subcommittee, AT&T Chairman Randall Stephenson said the company would accept a condition not to take USF funds for its promised advanced wireless build-out.   AT&T in its filing characterized Stephenson’s statement at the hearing as a “voluntary commitment.”

PK also plans to file a preliminary economic and technical report that argues AT&T is not as constrained in spectrum as the company claims, nor is T-Mobile in as bad a shape as AT&T claims.  The report argues both companies have many options to increasing their high-speed data networks.  The report also notes that AT&T’s claim to use T-Mobile spectrum to provide wireless service in rural areas should be greeted skeptically:  “T-Mobile holds no spectrum below 1 GHz, and thus would bring no additional assets to enable AT&T to expand coverage or increase capacity economically in rural areas.  In addition while Verizon has offered its 700 MHz spectrum to rural operators for them to deploy LTE in areas where it prefers not to do so, AT&T has taken no such initiative, which it could do at any time, and thereby ensure its customers access to the capacity that is deployed through reciprocal roaming agreements (assuming that it were willing to undertake such reciprocal agreements which it has been unwilling to do to this point in time).”

Contact Information

Press Contact
Art Brodsky abrodsky@publicknowledge.org
202-861-0020 (office) 301-908-7715 (cell)

For more information visit http://www.publicknowledge.org/

June 19, 2011

The Michigan Public Service Commission (MPSC) and Connect Michigan have formed a new committee to develop the availability of broadband in Michigan.

However, they will not be alone in their quest. They will also have assistance from professionals in the K-12 education, higher education, healthcare, non-profit, tourism, business, agriculture, government and broadband service sectors.

“A wide variety of Michigan businesses and organizations depend on broadband services to conduct everyday business,” said MPSC Chairman Orjiakor Isiogu.

“Joining forces with such groups makes sense as Michigan seeks to maximize economic development opportunities for job creators. The addition of these groups to the efforts of the MPSC and Connect Michigan will help expand opportunities for broadband service in Michigan,” he said.

On June 16, the new Collaborative Broadband Committee (CBC) held its initial meeting to help launch broadband as a medium to increase technological innovation in neighborhoods all over Michigan. The group is planning on having quarterly meetings.

Connect Michigan partnered with the MPSC in 2009 to begin planning an all-inclusive broadband technology project. They began the program by collecting provider data to build a statewide map, and it has proceeded to the preparation and expansion stage. At this time the project is growing to encourage community involvement in local technology, and is executing projects geared towards addressing digital literacy, improving education, providing access to global Internet resources, and stimulating economic recovery.

The Connect Michigan Residential Technology Assessment revealed in 2010 that almost 2.5 million residents did not receive broadband service – an important service and a contemporary link to quality jobs, information, and fundamental education and healthcare services.

The CBC will work with the MPSC and Connect Michigan in 2011 to recognize and offer leadership and answers that will allow both rural and urban Michigan populations to access the near-unlimited advantages of broadband technologies.

Click here to see a map of Michigan’s undeserved broadband communities.

To learn more about the MPSC visit http://www.michigan.gov/mpsc.

To learn more about Connect Michigan visit www.connectmi.org

June 19, 2011

On Thursday, June 9, 2011, the Supreme Court clarified that incumbent local exchange carriers (ILECs) have to provide access to entrance facilities to competitors at cost-based (TELRIC) rates.

According to Davis Wright Tremaine LLP, this ruling will provide economic benefits to competitive local exchange carriers (CLECs) almost immediately. It will also likely benefit their interrelated VoIP provider partners, and wireless (CMRS) carriers who lease interconnection facilities from ILECs at higher rates. The economic benefits to the receiving parties are possible because TELRIC rates are usually much lower than the tariff rates most ILECs have been charging.

The Supreme Court’s ruling reverses a ruling by Sixth Circuit Court of Appeals that said ILECs could charge high tariff rates for supposed “Entrance Facilities”. Entrance Facilities are communications hubs that go from the CLEC’s switch to an ILEC switch over which local traffic is exchanged.

In their reversal of the Sixth Circuit Court, the Supreme Court went back to the FCC’s interpretation of the Communications Act and FCC rules to decide how Entrance facilities will be priced. According to the court, the FCC’s rules demonstrate that it understood the importance that Entrance Facilities play in a pro-competitive telecommunications landscape as outlined in the Communications Act.

This means that the ruling offers an immediate opportunity for CLECs, and their VoIP partners, and CMRS providers to reduce the cost of their network interconnection costs. This also means that they can introduce new contract rates for the cost of the facilities.

There are three steps that carriers may have to take to get the lower rates:

• Carriers with interconnection agreements need to examine those contracts’ change-of-law provisions to amend Entrance Facility pricing as of June 9, 2011, at the latest;
• Carriers that have been disputing tariff charges may now qualify for refunds or credits, and need to consider the best way to approach ILECs for such refunds or credits;
• Carriers should brace themselves to use state utility complaint procedures if their ILEC balks about lowering Entrance Facilities rates prospectively or honoring past disputes.

It’s important to note that state commissions may need to hold cost proceedings to set TELRIC rates. That is because many ILECs have no approved TELRIC rates for Entrance Facilities.

915 N. Washington Ave., Lansing, MI 48906 517-913-5109

June 16, 2011

On June 7 the Michigan Public Service Commission (MPSC) released its 11th annual report on the state of telecommunications competition in Michigan.

The report is a required part of the Michigan Telecommunications Act. It mostly looks at the competition in the toll and local exchange service markets in Michigan.

Additionally it has information specific to Michigan on mobile wireless, Voice over Internet Protocol (VoIP) and broadband. Here’s a quote from the Department of Licensing and Regulatory Affairs’ press release:

“Telecommunications competition in Michigan continues to thrive, reaching the highest level ever recorded,” noted MPSC Chairman Orjiakor Isiogu. “And a stable number of competitive providers have continued to invest in providing service over their own facilities – good news for Michigan’s economy.”

The full 32-page report can be found on the MPSC website.

915 N. Washington Ave., Lansing, MI 48906 517-913-5109

Politico

June 10, 2011

AT&T is lining up support for its acquisition of T-Mobile from a slew of liberal groups with no obvious interest in telecom deals — except that they’ve received big piles of AT&T’s cash.

In recent weeks, the NAACP, the Gay & Lesbian Alliance Against Defamation and the National Education Association have each issued public statements in support of the deal.

The groups all say their public positions have nothing to do with the money they received from AT&T. And AT&T says it supports nonprofit groups because it’s the right thing to do — and not because of any quid pro quo.

Read entire article

TG Daily

June 7, 2011

AT&T is  on a mission to garner support from industry heavy hitters to help sway opinion in favor of its proposed $39 billion T-Mobile purchase.

Eight technology bigwigs, including Facebook and Microsoft, have already expressed support for the deal, and AT&T hopes it can convince legislators the purchase is indeed good for the mobile industry.

To be sure, both companies, along with ten prominent VC firms filed letters with the Federal Communications Commission (FCC) late Monday in support of the acquisition. The corporations claim the acquisition will help AT&T implement its next-generation data network to meet the growing demand for wireless broadband.

Read entire article

And here she is refuting arguments in support of the proposed AT&T/T-Mobile merger.

An AT&T and T-Mobile merger would lead to higher prices for consumers, less innovation in the industry and the loss of American jobs.

Sign the Public Knowledge petition below and tell the Obama administration that you want them to protect consumers and American jobs by rejecting this anti-free market merger.

Sign the petition!

The recent proposed merger of AT&T and T-Mobile has brought telecommunications to the headlines.

For an economist who understands the efficiency and equity of the market system, the telecom industry is interesting from a theoretical perspective. It poses the problem of how one might move from a system of government-regulated monopoly to a competitive market. Historically, the telephone industry began as a competitive market. Then Theodore Vail, mimicking the process of Samuel Insull in the electric industry, persuaded the government to grant a local monopoly over the phone industry to AT&T.

The telephone industry, by becoming a regulated monopoly, eliminated the threat of competition and guaranteed itself a profitable rate of return.

To be fair, embracing regulation was only part of a determined strategy by Vail to achieve monopoly of the telecom. The aggressive use of patents and patent litigation, as well as a merger strategy, led to Bell system dominance by the early part of the 20th century. However, the use of the courts and the regulatory agencies were a significant factor in creating the Bell monopoly.

The point here is that it was the political process that was a determining factor in the emergence of a phone monopoly. Monopolization did not occur due to a single seller dominating in an unregulated environment.

In 1982, AT&T settled an anti-trust suit pushed by MCI and agreed to split itself into seven Regional Bell Operating Companies (RBOCs) and a long distance carrier beginning in 1984. GTE then spun off its Sprint division, merged it with US Telecom and began offering long distance competition as Sprint. The subsequent competition in long distance was successful in dramatically lowering rates. This worked in good part because the owner of the infrastructure, the RBOCs, did not retail long distance and thus did not have a reason to deny access to other firms.

The sticking point began when, under the 1996 Telecommunications Act, an attempt was made to create a competitive market in all phone service.

The problem, of course, is that if I own the line into your house and sell local phone service, why would I ever allow a competitor to sell service to you over my lines? The fundamental issue is the infrastructure to provide telecommunications services was laid out under a risk free environment under a legal monopoly and this in itself has created a barrier to competition.

That created the anomaly in the telecommunications industry in that you need some government regulation in order to implement competition. The regulator has to provide the access to the infrastructure. This becomes even more complicated as new infrastructure is laid down.

For example, suppose AT&T has the legacy lines and switches, so the only way that ACME telephone can provide competition is to have use of those lines. The perhaps obvious answer is to have the government regulatory body, such as the Michigan Public Service Commission, settle disputes and require equal access to firms who are willing to pay the marginal cost of using the lines.

It becomes more difficult when AT&T has laid out new lines – say, fiber-optic lines that support broadband. Since these lines were laid after the government monopoly had been lifted, should other firms have access to these lines? And what if ACME lays out fiber optic lines but needs to connect it to an AT&T switch in order to get access to your house? Will AT&T have the incentive to develop and build infrastructure if it has to allow access to other firms even at marginal cost? Will competitive firms build infrastructure if they are not certain that they can connect to customers with it?

One might think this this problem will be solved with the movement to wireless communication. Unfortunately, this is not the case. Wireless calls travel wirelessly only from the closest tower to the cell phone. But the towers are connected to the same wireline network that connect wireline phones. There are some towers that have a powerful line of site microwave antennae, but generally the tower is connected to an underground wired T1 or T3 line. As there becomes more cell traffic – such as videos playing on cell phones – the wireline infrastructure becomes more, rather than less, important and the need to ensure quality and reliable wireline interconnections increases.

Given the intricacies specific to telecom, it is important that the legislature take the time to carefully examine changes to Michigan’s Telecommunications Act – with an eye to ensuring that the network of telecommunications does not inadvertently return to an era of monopolization.

Gary Wolfram is the William E. Simon professor in economics and public policy at Hillsdale College.

This article was re-posted with the author’s permission and originally appeared on The Michigan View, which is a product of The Detroit News.

Lansing MI – July 1, 2010

The Michigan Internet & Telecommunications Alliance ( MITA) strongly endorses the No Choke Points Coalition’s point of view enunciated in its press statement released June 29th.  The No Choke Points Coalition is a national organization that represents consumer advocates, Internet companies and competitive telecommunications providers that rely on AT&T’s high-capacity lines to connect their customers to the Internet.

The No Choke Point Coalition’s press release called attention to the fact that as of today (July 1^st ), price regulation of AT&T’s wholesale high-capacity broadband lines will be lifted and high-capacity Internet users will likely see Internet connection prices skyrocket.

High-speed broadband lines are used by nearly every sector of the U.S. economy every day, from ATMs, retail outlets, businesses, and government agencies.  MITA members provide competition in this sector of the economy which results in lower prices and innovative service.  AT&T raising of  its wholesale rates  will impact the entire sector and undoubtedly result in higher retail prices for everyone.  Removing these price controls will be a setback for the Broadband economy according to John Liskey, spokesperson for the Michigan Internet & Telecommunications Alliance.

Liskey questioned how AT&T can claim the wholesale marketplace is competitive when they raise prices in a market with declining costs.  According to Maura Corbett, spokesperson for the No Choke Points Coalition, this rate increase was announced three years ago.   (see  http://www.nochokepoints.org/latest-news )

AT&T’s wholesale rate increases will also frustrate the National Broadband Plan according to Liskey.  The Plan was intended to accelerate broadband deployment in unserved, underserved, and rural areas and to create jobs or provide significant public benefits.  In Michigan, many competitive carriers have received grants and loans to further deploy broadband networks throughout the state.  “This AT&T rate increase is tantamount to erecting a tollgate on the Information Highway.  By increasing its connection charges, AT&T increases costs to Michigan’s residents and businesses at a time they can least afford it,” Liskey said,

Relief could be on the way as current FCC Chairman, Julius Genachowski, has stated his intention to address this issue when he spoke to Congress earlier this year.  The Commission has scheduled a workshop on July 19^th to begin the process.  “Now is the time for the FCC to help Michigan create jobs and foster technological innovation by taking quick action,” Liskey concluded.

About the Michigan Internet & Telecommunications Alliance:

The Michigan Internet & Telecommunications Alliance is a group of Internet Service Providers and competitive telecommunications company that have substantial business in Michigan.  It is the goal of the Alliance to showcase the innovative technology that these companies are deploying and encourage policymakers to establish a regulatory framework for future growth that brings high-tech, communications-based jobs to Michigan and maximum choice to Michigan residents and businesses.

To learn more about the Michigan Internet and Telecommunications Alliance, please visit www.mita1.net

To learn more about the No Choke Points Coalition or the National Broadband Plan, please visit

http://www.marketwire.com/mw/release.do?id=1283439

www.NoChokePoints.org

http://www.broadband.gov

For More Information Contact:

John Liskey

Liskey@mita1.net

517-913-5109

WIRELINE COMPETITION BUREAU ANNOUNCES JULY 19, 2010
STAFF WORKSHOP TO DISCUSS THE ANALYTICAL FRAMEWORK FOR ASSESSING THE EFFECTIVENESS OF THE EXISTING SPECIAL ACCESS RULES

WC Docket No. 05-25

On July 19, 2010, from 1:00 p.m. to 4:00 p.m. (eastern daylight time), the Wireline Competition Bureau will host a workshop in the 4th Floor-South Conference room to evaluate the analytical framework the Commission should use in reviewing the current special access rules.(1)

The National Broadband Plan recommended that the Commission hold a “staff workshop to discuss the analytical framework the FCC should use to assess the effectiveness of its existing special access rules.” (2) Pursuant to that recommendation, the July 19, 2010 workshop will initiate an evaluation of the analytical framework proposals raised in the record and any associated data collection that would be required to implement such proposals.(3)

The format of the workshop will be a facilitated debate led by Commission staff, and will include presentations by economists that filed comments in response to the Notice. During the workshop, staff will solicit input from attendees on issues relating to special access, such as:

• The analytical framework that should be used in analyzing the effectiveness of the existing special access regulations;
• Specific proposals filed in the record and critiques of those proposals; and
• The types of data that should be collected by the Commission to determine whether the current rules are working as intended.

The Bureau encourages participation from a wide variety of interested parties, including representatives from, but not limited to, industry, academia, consumer advocate organizations, and state governmental entities.

For planning purposes, the Commission would like to know whether you intend to participate in the workshop. Seating is limited, although other ways to participate will be available. Further logistical details on how to participate remotely will be provided as the date approaches. If you are interested in participating please contact Pamela Arluk or Margaret Dailey, Pricing Policy Division, Wireline Competition Bureau at (202) 418-1520 (voice), or by e-mail Pamela.Arluk@fcc.gov or Margaret.Dailey@fcc.gov.

Reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need and a way we can contact you if more information is needed. Last-minute requests will be accepted, but may not be possible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), or (202) 418-0432 (tty).

(1)See Connecting America: The National Broadband Plan at 48 (rel. Mar. 16, 2010) (National Broadband Plan).
(2)Id.
(3)Parties Asked to Comment on Analytical Framework Necessary to Resolve Issues in the Special Access NPRM, WC Docket No. 05-25, Public Notice, 24 FCC Rcd 13638, 13639 (2009) (Notice).

- FCC -

For Immediate Release

Michigan Internet & Telecommunications

Alliance Applauds FCC Action

Left to Right, Commissioner Clyburn, Commissioner Copps, Chairman Chairman Genachowski, Commissioner McDowell and
Commissioner Baker. (photo taken October, 2009)

Lansing – June 25, 2010

A recent decision by the FCC may start the pendulum of telecommunications regulation swinging in the direction of more competition. On Tuesday, June 22nd, the FCC released a benchmark decision that paves the way for more investment and competition in the commercial telecommunications marketplace. More competition in the telecom wholesale market will help keep costs down for businesses connecting to the Internet, according to John Liskey, spokesperson for the Michigan Internet & Telecommunications Alliance.

In its ruling, the FCC found that there was no competition in the telecom business market in Phoenix. The agency set forth a detailed data-based analysis of market power that will help them keep a watchful eye over the incumbent carriers like AT&T and Verizon.

Michigan’s competitive telecom companies are thrilled with the ruling because it articulates a realistic analysis to be used by the FCC in future decisions. Previously the FCC was inclined to count cell phone and cable phone competition in the residential market to conclude that meaningful competition existed in all markets, including the business to business (B2B) and high-capacity broadband markets. “This decision acknowledges that there is little competition for the wholesale services that only AT&T or Verizon can provide,” said Liskey, “hopefully policymakers in Michigan will follow suit and recognize that in order for telecom investment to thrive in Michigan, similar policies will need to be adopted.”

“The FCC ruling and the agency’s commitment to using similar market-based analysis comes as welcome news for CLECs nationwide,” Liskey concluded.

Contact: John Liskey, Michigan Internet & Telecommunications Alliance, 517-913-5109

FCC Press Release

915 N. Washington Ave., Lansing, MI 48906 517-913-5109

]]> http://www.mita1.org/2010/07/june-press-release/feed/ 0 http://www.mita1.org/2010/07/911-press-release/ http://www.mita1.org/2010/07/911-press-release/#comments Thu, 01 Jul 2010 15:50:19 +0000 Marybeth http://mita1.org/?p=137

Welcome to the Michigan Internet and Telecommunications Alliance(MITA) webpage. Here you will find information about some of Michigan’s high-tech leaders in communications innovation. The organization was formed as an outgrowth of the Michigan Communications Carriers Association, Internet Service Providers, Web hosting facilities, software programmers and engineers. All of these companies have a common interest in the core value of a fast robust communications infrastructure here in Michigan.

It is the goal of this alliance to showcase the innovative technology that these companies are deploying and encourage policymakers to establish a regulatory framework for future growth that brings high-tech, communications-based jobs to Michigan and maximum choice to Michigan residents and businesses.