EX PARTE OR LATE FILED
Nextel Communications, Inc.
800 Connecticut Ave. NW., Suite 1001
Washington, DC 20006
202296-8111 FAX 202 296-8211
January 24, 1995
Mr. William F. Caton
Acting Secretary
Federal Communications Commission
1919 M Street, N.W.
Room 222
Washington, D.C. 20554
RECEIVED
rJAN2 4 f995
EX PARTE
Re: CC Docket No. 94-54
Dear Mr. Caton: DOCKET FiLf CQPYQr~lnIN~!
On behalf of Nextel Communications, Inc. and pursuant to Section 1.1206 of
the Federal Communications Commission's Rules, this letter constitutes notice that
Larry Krevor, Laura Holloway, Tamara Casey, and Rob Chimsky met today with the
following personnel in the Policy Division of the Wireless Telecommunications
Burueau: John Cimko, Chief; Michael Wack, Deputy Chief; Nancy Boocker, Attorney;
Barbara Esbin, Attorney; Judith Argentieri, Attorney; and Amy Lesh, Industry Analyst,
to discuss the above-referenced proceeding. Specifically, Nextel addressed the
technical and operational impact of imposing equal access obligations on Nextel, its
position on CMRS-to-CMRS interconnection, and issues concerning the required resale
of CMRS services. The meeting was initiated at the request of the Policy Division.
Attached are documents distributed at the meeting.
An original and one copy of this letter and attachments have been filed with the
Secretary pursuant to Section 1.1206. Should any questions arise in connection with
this notification, please do not hesitate to contact the undersigned.
Respectfully submitted,
NEXTEL COMMUNICATIONS, INC.
Lawrence R. Krevor
Director - Government Affairs
No, of COpies rec'd a /
U#tA8COE
--------
cc: (w/o attachments)
John Cimko
Michael Wack
Nancy Boocker
Barbara Esbin
Judith Argentieri
Amy Lesh
attachments
DeveloQment ImQlications
? General Considerations
o GSM not designed with regard to Equal Access
? International standard not based around competitive
access
? Any equal access developments required will be outside
GSM standard
? Except for potential PCS players, developments will be
applicable only to U.S. ESMR carriers
o Nextel current switch coverage area significantly
larger than most LATAs or MTAs
? When will use of IXC be required?
? Potential backhaul inefficiencies and increased costs
DeveloQment ImQlications
.. User dialed 10XXX Considerations
o New switch translation tables need to be
developed to associated 10XXX with trunk grouQ.
o Access to various carriers must be implemented
and maintained
o Must establish transfer of bill record information to
each carrier on each call
o Subscriber eqyjpment or network element
development must occur to automatically dial
customer 10XXX code for feature transparency
Development Implications
? Additional 10XXX Considerations
(.'; How to handle movement toward 101-XXXX
? Will multiple tables be required?
(.'; How to address intra-LATA toll equal access
(.'; lmplementation of additional translation tables is a
§jgnificant development effort
? Example: Implementation of * and # dialing
? Must verify all potential table interactions
DeveloQment ImQlications
? Presubscription Considerations
o Significant enhancement to HLR, VLR, and Switch
? New records must be created in HLR and VLR to contain
presubscribed carrier information
? New translation tables in the switch to associate user
selection with proper trunk group
o Order entry and administration system must be
enhanced
? Customer support must be able to properly input
customer selection to network elements
? Processes must be established to verify and effect
changes to customer selections
Development Implications
? Presubscription Roaming Considerations
o Significant enhancement to GSM MAP standard to
~ortroaming
? Processes and new records created to download
presubscription information to current subscriber market
o Roaming call termination requires intelligent
signalling
? Call delivery to visited market requires 55? signalling to
assure proper handling of forwarded call
? Call delivery scenarios become potential more complex
with 500 numbers
Development Implications
? Summary of Considerations
o Any requirement to sURPort equal access will
result in a major development effort
? Use of GSM requires special development
considerations
? 10XXX is less severe than presubscription but both
impose significant financial and technical burdens
o .EQual Access has impacts on the total system
? Order entry, switch, HLR, VLR, SMS, customer service
? Impacts feature functionality and seamless service
? Must consider "home" system and "roaming" impacts
Operational Implications
? Balloting Administration
{'; Initial Balloting
? 3 Rounds Minimum Requirement Under Current Equal
Access Regulations
{'; Pre-SubscriptionChan~
? Charges May Vary By Carrier
{'; No Cost Recovery Mechanism for CMRS
? Additional personnel dedicated to ballot administration
? All personnel trained on ballot administration
Operational Implications
? Billing and Customer Information Systems
o Internal Systems
? Modification Required to Support Additional Activities
o External Systems
? Additional Costs for processing records
o Customer Education
? Customer Potentially Receives Multiple Invoices
? Some Customers Can Receive Credits /Adjustments
from the CMRS, Other Customers Cannot
? Value Added Service of IXCs Difficult to Understand
? Different Billing Cycles for the "same services"
Operational Implications
? Financial Considerations
OAudit and Reconciliation Processes
? Many Carriers Involved
? Smaller Carriers Highly Susceptible to Fraud
? Different Billing Cycles Increase Complexity
o Cost Implications
? Significant Increase in Operational Expenses With No
Corresponding Revenue
? Significant Capital Outlay to Implement the Technology
and Balloting Process
? Significant Lag Time in Receiving Payments from IXC
and varying time-frames
Marketing & Competitive Issues
? Equal Access as a Competitive Advantage
OAvailability is Not a Competitive Issue
? Customers do not change providers based on availability
ofEqual Access
? Creates more customer confusion on an already
complicated sale
? Sales personnel rarely understand the complexities or
benefits of Equal Access
? Only the most sophisticated user truly benefits
? Roaming complexities are significant if different markets
provide access to different IXes
Marketing & Competitive Issues
? Training & Documentation
OTraining
? Sales Personnel Must Be Trained in the Nuances of
Various IXC Offerings
? Indirect Sources of Distribution Will Not Be Effective At
Communicating Alternatives
? Reselling Requirements Could Make The Situation Even
More Complex
o Customer Literature and Contracts
? Expansion would be required to include detailed
information on Equal Access
Customer Perspective
? Equal Access Equals Confusion
oThe Decision Process
? Many Wireless Customers Do Not Know Who Provides
Their Long Distance, Much Less How
? Customers Generally Make Wireless Decisions Based on
Price and Coverage Area
? Very Few Wireless Customers Understand How To Take
Advantage of IXC Special Offers or Special Service
Plans
? Fraudulent Subscribers Can Hide Behind the Equal
Access Process by Constantly Changing IXCs, Leaving
the Wireless Carrier to Bear the Cost of the Fraud
Business Issues --Summar~
? Does Not Result in any Additional Customer
Satisfaction
? Cost Center with no Associated Revenue
? Increased Complexity with Billing, Accounting
and Customer Information Systems
? Personnel Training Requirements Increase
Significantly
? Increases Fraud Potential
Today's CMRS Environment
? Multiple Standards for Digital Cellular
? Limited Implementation of LEC to Wireless
SS7 Trunks
? Defacto Standard for ESMR
? Multiple Standards Being Considered for PCS
? Paging on Multiple Frequencies and Multiple
Technologies
? Proprietary DATA Networks Evolving
? No Decision on Universal Equal Access
Toda}:'s CMRS Environment
? Carriers Selecting Technology
? Carriers Changing Technology
? Carriers Implementing Technology
? Carriers Acquiring Spectrum
? Carriers In Transition to Full CMRS Status
? Network Security is Precarious
? Network Reliability Varies Widely
? Interconnect Costs Vary Widely by LEC &
Area
Future Considerations
? Digital technologies are highly susceptible to
Audio Delay. Audio Delay can be reduced
slightly by eliminating unnecessary steps in
the call delivery process. This represents a
potential technical benefit to CMRS to CMRS
interconnection.
? Sharing of SS? based network elements is
another potential benefit of CMRS to CMRS
interconnection. For example, SMSC
functionality could probably be shared by
multiole networks with standards.
Future Considerations
? LEG bypass would be a natural outcome of
GMRS to GMRS interconnection. Loss of
LEG revenue could lead to unrest at the state
level due to loss of tax and universal service
revenue. No process exists to "police" this
kind of bypass activity.
? No standard has been proposed for the type
of interconnection. Allowing unlimited
technical arrangements would be costly and
inefficient. Standards would be required.
Total Federal Preemption A Must
? Technical Standards Required
o Interfaces
OSignaling
o Billing RecordExchan~
? Regulatory Guidelines Must Be Consistent
? Relief Must Be Available for Disputes
? Costing Methodologies Must Be Standardized
? Equal Access Concept Must Be
Considered/Required
Where Does It End?
? Probable Rate of Return Regulation for the
Entire Wireless Industry
? Universal Access to All Carriers
? Loss of Identity for Small, Unique Carriers
? Marketing Power Becomes the Only
Distinction, Only the Strong ($) Survive
? Largest Federally Regulated Industry
Reselling
? State by state variation in regulatory
framework
? CA is an example of extreme regulatory
support of reselling creating phenomenal
unrest among wireless carriers
? Most confusing alternative available to
subscribers
? Cost base to the facilities based carrier with
virtually no return on investment. Varies, of
course, on specific arrangements.
Reselling
~
? Unnecessary in a true free market
? Multiple facilities based carriers will provide
more than adequate competition, insuring
cost reduction to end users
? If mandated, simply another area requiring
federal regulation to control
? Lack of regulation would lead to ultimately
disadvantaging facilities based carriers