The Wireline Report Latest FCC news impacting your business

By Salvatore Taillefer, Partner, Blooston Law (sta@bloostonlaw.com)

In the event AT&T’s application is granted, the above-referenced services will continue to be available on a grandfathered basis until October 2026.

Bill

On April 7, the Maryland Senate passed by unanimous vote SB 90, known as the Stop Spam Calls Act of 2023. The next step before becoming law is the governor’s signature.

On May 30, AICC filed a formal objection to an FCC application filed by AT&T to discontinue the provision of certain services relied upon by the alarm industry. Specifically, AT&T proposed to discontinue its Access Channel Service and Inter-Office Channel Service offered at T1, T3, OC3, OC12, and OC48 speeds, as well as AT&T Toll-Free MEGACOM Service. These services are widely used in the alarm industry for inbound receiver/signaling and voice traffic to dedicated terminations.

AICC pointed out that all save one of the alternatives proposed by AT&T were IP products which are not reliable for the transmission of alarm systems due to various reasons, such as signal compression, frequency drifting, and latency. AICC also noted that its members who had tested some of these alternatives – particularly AT&T’s

IP Flexible Reach and IP Toll-Free services – determined that, as currently configured by AT&T, these services could not guarantee transmission of alarm signals.

AICC also noted that the one TDM alternative proposed by AT&T –Readyline – only allows for one routing arrangement, whereas the MEGACOM service sought to be discontinued by AT&T allowed multiple routing arrangements. Multiple routing arrangements allow for redundant alarm transmissions. AICC also demonstrated that Readyline is also scheduled for discontinuance, making it a poor replacement for MEGACOM.

If the FCC removes AT&T’s application from streamlined treatment – as AICC argued it should – it will provide an opportunity to further address the matter. Otherwise, the application will be automatically granted on June 15.

The bill is essentially a state-level Telephone Consumer Protection Act (TCPA), the federal law that governs autodialed and pre-recorded voice marketing calls. The Maryland bill requires express written consent for any prerecorded or automated marketing call, which is the same as the TCPA. However, it uses a broad definition of autodialer that covers any automated system that selects or dials telephone numbers, with no requirement of a randomizer or random number generator.

The bill provides exceptions for nonprofit organizations and business to business calls, as well as calls made in the context of an existing business relationship. A violation of the Act can result in up to $2,500 per violation in civil penalties.

At its June 8 Open Meeting, the FCC will consider a Notice of Proposed Rulemaking on facilitating the implementation of Next Generation 911 (NG911) services. The primary purpose of the NPRM is to address reports that originating service providers are refusing to connect to new