Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Measures Designed to Assist US Wireless )
Consumers to Avoid Bill Shock ) CG Docket No. 09-158
)
)
)
COMMENTS OF AT&T, INC.
WILLIAM ROUGHTON
MICHAEL GOGGIN
GARY L. PHILLIPS
PAUL K. MANCINI
Atorneys For:
AT&T, INC.
1120 20
th
Street, NW
Suite 1000
Washington, D.C. 20032
(202) 457-2040 ? phone
(202) 457-3073 ? facsimile
July 6, 2010
i
TABLE OF CONTENTS
Page
I. AT&T PROVIDES THE INFORMATION AND THE TOOLS CUSTOMERS NEED TO
MANAGE ACCOUNTS AND CONTROL COSTS?????????????..3
II. ROAMING?????????????????????????.. 8
III. ACCESSIBILITY??????????????????????? 9
IV. CONCLUSION???????????????????????... .9
Before the
Federal Communications Commission
Washington, D.C. 20554
)
In the Matter of )
Measures Designed to Assist US Wireless ) CG Docket No. 09-158
Consumers to Avoid Bill Shock )
)
COMMENTS OF AT&T, INC.
On May 11, 2010, the Consumer and Governmental Affairs Bureau (?the Bureau?) of the
FCC released a public notice
1
seeking comment on the feasibility of instituting usage alerts and
cut-off mechanisms that would provide wireless voice, text, and data consumers in the United
States a way to monitor, on a real-time basis, their usage of a wireless communications service,
as well as the various charges they may incur in connection with such usage.
2
The notice also
seeks to know what means wireless consumers have today to monitor their consumption of wire-
less services and to what extent consumers are aware of the consequences of exceeding their al-
locations of voice minutes, text message limits, or data usage.
3
AT&T is pleased to have this opportunity to describe the steps AT&T takes to ensure
customers understand the usage-related terms of their service plans and that they have customer-
friendly options available for monitoring and controlling their usage. From the information pro-
vided at the point of sale through the tools available to the wireless customer to check remaining
message balances or data usage from the wireless device and up to and including courtesy usage
1
DA 10-803 (Released May 11, 2010).
2
Id. at 2. The other usage includes things like roaming, voice service minute plans, text message plans, and the like.
3
Ibid.
2
alerts for text and data users, AT&T offers its customers the information and the tools
they need to control costs and avoid surprises.
Certainly, from AT&T?s perspective, there is no need for the Commission to impose
mandates like those adopted in the European Union (?EU?). AT&T already provides customers
with more and better disclosures that the EU rules require, and the imposition of mandates is
likely to restrict providers from adopting innovative new practices that customers may prefer.
4
As the comments below will show, AT&T provides customers with ample opportunity to moni-
tor and manage their usage of AT&T?s wireless services. At the store, AT&T representatives go
over a Customer Service Summary that explains the rate plan, terms of service and an itemized
estimate of the first bill before any customer commits to a service contract. Customers can
monitor their voice and data usage 24 hours a day seven days a week by entering a few numbers
on their wireless device to see how many minutes and megabytes they have used. All AT&T cus-
tomers can also manage their accounts online. In addition, AT&T provides alerts to let custom-
ers know when they approach or exceed their allotted text and data usage. For example, custom-
ers on AT&T?s smartphone data plans receive courtesy alerts when they reach 65% and 90% of
their data plan?s limit. On certain plans, if the customer exceeds his usage limit by a specified
amount without having responded to the alerts, AT&T will suspend the service until the sub-
scriber calls customer service to restore it. In short, AT&T works hard to ensure that no custom-
er need be surprised by his wireless bill.
4
The issue that EU regulators sought to address there, the shockingly high cost of intra-EU roaming, is not an issue
in the much more competitive US market. The EU regulations were designed to ensure that EU subscribers, travel-
ing within the EU, would be informed about the costly roaming charges that might apply within the EU, and get
further disclosures when they reached certain data usage thresholds. Of course, in the US, providers typically offer
roaming and long distance within the US at no additional charge.
3
I. AT&T PROVIDES THE INFORMATION AND THE TOOLS CUSTOMERS NEED TO
MANAGE ACCOUNTS AND CONTROL COSTS.
AT&T leads the industry in educating consumers about their new service. At AT&T
stores, customers receive a personalized, easy-to-read Customer Service Summary (?CSS?) to
ensure, before they sign up for service, that they fully understand any usage limitations and costs
that may apply. Each potential customer?s CSS explains the features of the rate plan he has se-
lected and the other terms of service. The CSS also includes a sample detailed, itemized esti-
mated first bill as well as a sample subsequent bill to ensure that each potential customer knows
what to expect.
5
AT&T representatives review the CSS with each potential customer before the
customer signs up for service.
Of course, AT&T recognizes that not all customers want to use the services the same
way. Some may use more voice, others are heavy texters and more and more customers enjoy
using broadband data service to surf the web, email, or stream video. Accordingly, AT&T offers
customers a wide range of service plans so that customers can choose the plan that best addresses
their needs and their budget. A growing percentage of customers choose prepaid calling plans,
which are the most direct and simple way for customers to control their wireless bill. Other cus-
tomers may choose among a variety of postpaid individual and family plans to meet their needs.
AT&T?s nationwide plans offer voice plans with different sized ?buckets? of minutes per month,
including an unlimited calling option. In addition, a number of calling features are available to
consumers, including free mobile-to-mobile calling to other AT&T wireless customers; RollOv-
er, which allows customers to carryover any unused minutes to the next month; A-List calling,
which permits unlimited calling to and from an AT&T mobility customer?s favorite U.S. phone
5
An example of a CSS is attached as Attachment 1.
4
numbers at no extra charge;
6
and unlimited Nights & Weekend calling, which is offered on most
plans.
Similarly, AT&T offers text and data users a wide variety of plans to meet their needs.
7
AT&T offers several messaging options for qualified customers that result in a customer never
having to worry about incurring overage charges for texting or MMS.
8
AT&T also offers data
plans with generous ?buckets? of data usage at very competitive price points. For smartphone
customers, AT&T?s new DataPlus plan offers 200 MB for $15 a month.
9
DataPlus appeals to
people who primarily surf the web, send email, and use social networking applications. If a cus-
tomer uses more than 200 MB in the course of a month, he will receive an additional 200 MB of
data usage for $15, replenished as often as necessary during the billing cycle for the same price.
For those customers who regularly download or stream music and video, or use other high
bandwidth applications, AT&T offers DataPro, which provides 2 GB of data for $25 a month.
10
As with DataPlus, a DataPro customer who exceeds 2 GB in the course of a month will automat-
ically receive an additional 1 GB of data for $10. Each time an additional 1 GB of data is used
up during the cycle, AT&T replenishes the customer?s account with an addition 1 GB at the
same price of $10.
11
6
A-List t allows unlimited calling to a set list of domestic telephone numbers, on any network including lan-
dlines, without using minutes from the AT&T mobility customer?s plan.
7
AT&T also provides an online data calculator that enables customers to estimate their mobile data usage and get a
better sense of which data plan is best for them. The calculator is found at www.att.com/datacalculator.
8
Examples include:
? Messaging Unlimited ? provides unlimited text, picture, video, and instant messaging for an individual line.
? Messaging Unlimited for Families ? provides unlimited text, picture, video, and instant messages for all us-
ers on a FamilyTalk account.
? Data Unlimited ? provides unlimited access to the mobile internet, search, e-mail, music, and apps. (This
service is available to quick message devices and basic phones only).
9
On average, 65% of AT&T smartphone customers use less than 200 MB a month.
10
On average, 98% of AT&T smartphone customers use less than 2 GB of data in a month.
11
For users of quick messaging devices or feature phones, the Data Unlimited option is available. Additionally,
virtually all AT&T smartphones come with Wi-Fi technology embedded in them. Wi-Fi generally provides consis-
tently fast speeds and can be used at home, at the office, or elsewhere when available without counting against a
5
While prepaid plans and unlimited voice and messaging options provide customers with
means to control costs, they are not the only tools AT&T offers. AT&T also enables parents to
set limits on their children?s wireless usage. Depending upon the level of control needed, AT&T
offers parents two solutions. AT&T Smart Limits for Wireless is an online service that enables
parent to provide their children with the freedom and security of a cell phone while setting sensi-
ble boundaries for its use. With AT&T?s Smart Limits for Wireless, parents can, for a monthly
fee, set limits online to
? Establish times of day their child?s phone can be used for mobile Web browsing,
messaging and outbound calls.
? Filter access to Internet content that is inappropriate for children.
? Define the number of text and instant messages allowed.
? Determine the amount of Web browsing usage allowed per billing cycle.
? Block or allow calls or texts to and from certain numbers (incoming and out-
going).
? Limit downloadable purchases such as ringtones, games, graphics and other con-
tent.
AT&T?s MEdia Net Parental Controls offers parents basic controls for their child?s cell phone
use. With this tool, which is included at no charge with AT&T wireless service, parents can lim-
it the types of content their child can view and restrict the purchase of premium content or sub-
scriptions. Customers can activate this control free of charge on the device or by calling an
AT&T customer care representative.
12
AT&T offers a number of free services to assist customers in keeping track of their usage
and their billing. Many of these services are accessible from the wireless phone or device itself
and let the customer know remaining minutes, data usage, account balance, upgrade eligibility
customer?s monthly data usage total. AT&T offers unlimited access to more than 20,000 AT&T Hotspots at no
additional charge to smartphone and iPad customers with qualifying data plans.
12
A compatible handset is required and small fees may apply for brief data usage if MEdia Net Parental Controls are
set directly from the handset..
6
and more 24 hours a day, seven days a week.
13
For example, by dialing *BAL# (*225#), a cus-
tomer?s account balance is delivered by text message as well as the next bill payment date and
the last payment posted for the account. Similarly, by dialing *MIN# (*646#), the remaining
minutes of the customer?s ?bucket? plan are delivered by text message. To check for data usage,
a customer can dial *DATA# (*3282#) and a text message will report a breakdown of the sub-
scriber?s data usage.
14
Customers can find more information about these self-service features by
going to www.att.com/starservices.
AT&T customers can manage their accounts online through myWireless, AT&T?s online
account management system.
15
By logging into the account, a customer can at any time view
usage of voice, text and data services, review and pay the wireless bill, check rate plans, upgrade
features, and more. With this free service, customers can know where they stand on all usage
and how many days are left in the current billing cycle.
16
Customers who have compatible
smartphones can use the free AT&T myWireless application to check data usage from their
smartphone. The free application is available for download in several smartphone app stores.
Customers can also go online to www.att.com/wireless to see all of their usage.
One particularly useful feature offered through myWireless is the customer?s ability to
make retroactive changes to his service plan. For example, if a customer discovers that he has
exceeded his monthly allowance in voice minutes, text messages or data, he can go online
17
and
13
Customers must have a device capable of sending and receiving text messages. AT&T?s *Services feature is not
available to some former customers of acquired companies.
14
See, Attachments 2 through 4.
15
AT&T provides the majority of its smartphone users (this includes all iPhone, all Blackberry Curve and Bold, and
all Android users) with a free ?MyWireless app? that, when pressed, allows customers to quickly access their ac-
counts. By saving log-in information, a customer never needs to enter it again and can then simply tap on the usage
icon to see current usage details. Thus, with only 2 taps on these smartphones, customer gets all of the information
regarding usage. AT&T plans to extend this capability to all smartphones by the end of 2010.
16
Naturally, customers may always call customer service for help or information. However, these online services,
which provide key account information, are more convenient and more rapid.
17
Or call customer service.
7
change his plan to one with a higher allotment. This change will be retroactive to the beginning
of the current bill cycle, thereby sparing the customer any overage charges.
On June 7, 2010, AT&T introduced new, less expensive data plans for smartphone us-
ers.
18
These plans, DataPlus and DataPro, offer convenient allotments of data usage designed to
meet the requirements of AT&T?s mobile data customers at affordable prices. To help these cus-
tomers keep abreast of their data usage, AT&T provides courtesy alerts
19
when a DataPlus or Da-
taPro customer reaches 65% and 90% of his allotment. These alerts not only inform the custom-
er of where he is the use of his monthly data allotment, they also give the customer the ability to
control how much data usage he wants to use in a billing cycle.
In a like manner, free, courtesy alerts go out to customers who subscribe to a messaging
plan but exceed the limits of their monthly text, picture, video, or instant messaging allotment
programs by $10 to $15. If the customer fails to respond to the alert, subsequent alerts are sent
to the customer once he reaches $50, $100, and $200 in overage charges.
20
AT&T will tempora-
rily suspend the customer?s messaging service (but not the voice service) if the customer contin-
ues messaging without contacting customer service. Similarly, AT&T will send alerts to cus-
tomers who subscribe to legacy data plans with monthly allotments if they exceed their usage
plan by $15. Should the customer fail to respond to the alert, AT&T sends subsequent alerts to
the customer once he reaches $50 and $100 in overage charges. In an effort to assist pay-per-use
customers, AT&T provides these customers with courtesy notices about their usage. For a cus-
tomer whose pay-per-use Internet-related data charges exceed $15 during the current billing
18
See, p. 4 above for a description of the new data plans.
19
Ninety-nine per cent of these alerts reach customers within 24 hours of a particular limit having been triggered.
20
For laptop or notebook data customers with a 5 GB limit, AT&T sends alerts to the customer when they have
reached 65% and 95% of that limit, and AT&T temporarily suspends their data service when they hit 100% of their
5 GB allotment. Once the customer calls customer service and is informed of the overage, service may be reinstated
at the customer?s request. Smartphone customers on DataPlus or DataPro who choose to exceed their monthly al-
lotment receive automatic additional allotments as described earlier. See, p. 4.
8
cycle, AT&T sends the subscriber a free incoming text message alerting the customer to the
usage and advising the customer to call AT&T.
21
A similar alert goes out to customers whose
pay-per-use charges for text, picture, video, or instant message usage in the current billing cycle
exceed the cost of an unlimited messaging plan.
22
II. ROAMING
Unlike the difficulties encountered by European Union wireless customers roaming out-
side of their home countries, roaming ? in particular, voice roaming ? presents far fewer prob-
lems to the American wireless customer. As noted earlier, all AT&T voice plans within the
United States include domestic coverage of the fifty states, Puerto Rico and the U. S. Virgin Is-
lands. Long distance is also included in all voice plans. In short, there is no domestic ?roaming?
for AT&T?s U. S. customers. Consequently, customers need only keep track of the minutes re-
maining in their plans and need not worry about roaming or long distance charges. Text messag-
es and data usage while roaming within the United States are also charged against the customer?s
AT&T plan, and AT&T will send alerts as described above.
For customers going abroad, AT&T provides a number of different resources at
www.att.com/global to help them plan how to use their wireless devices while travelling interna-
tionally.
23
This site includes information on how to get the best international voice and data rates
based upon planned destinations, and offers tips and tutorials for customers going abroad. The
information provided includes
? Know Before You Go: www.wireless.att.com/learn/international/roaming/know-
before-you-go.jsp
21
The message says: ?AT&T FREE MSG: ALERT! You have exceeded $15 in data/Mobile Web charges this
month. Call 1-800-894-8963 to discuss your options.? If the customer?s email address is on file, AT&T also sends
an email to the customer alerting him of the overage.
22
?AT&T FREE MSG: ALERT! You have exceeded $20 in text messaging charges this month. Call 1-800-894-
8963 to discuss your options.? If the customer?s email address is on file, AT&T also sends an email to the customer
alerting him of the overage.
23
See, Attachments 5 through 10.
9
? Verify Rates: www.wireless.att.com/learn/international/roaming/international-
roaming.jsp
? Travel Guide: www.wireless.att.com/learn/international/roaming/travel-guide.jsp
? FAQ on International Roaming:
www.wireless.att.com/learn/international/roaming/faq.jsp
Customers also have the option to call customer service at any time to have international roam-
ing blocked. To help customers track and manage data usage overseas, iPhone users can use the
device?s Usage Tracker option. Laptop users can view data usage in the Communications Man-
ager window on their screen. As with domestic service, AT&T customers will receive data
usage alerts while abroad.
III. ACCESSIBILITY
Because the usage alerts are sent by a free, text message, customers with hearing disabili-
ties are able to read these messages and take the appropriate action needed to manage their ac-
counts. Customers whose eyesight is impaired have access to the text messages by means of
software such as mobile speak, mobile magnifier or voice over for iPhone users.
CONCLUSION
AT&T is grateful for the opportunity to highlight the many ways it helps its customers
manage their costs. By providing reasonable prices, a CSS with fulsome explanations of what to
expect, tools to monitor and control usage (like the *data# service and SmartLimits services, on-
line account management that will even allow customers to adjust rate plans retroactively, and
alerts to warn customers when they are using up the data in their plans), AT&T offers the infor-
mation and the tools customers need to avoid surprises. Moreover, unlike European wireless
customers, who may pay high roaming charges to roam within the EU, AT&T customers on Na-
tion plans enjoy roaming and long distance serviced within the United States at no additional
10
cost. Moreover, AT&T already provides alerts to let data customers know when they are nearing
the amounts allotted in their plans. Thus, European-style regulation is unnecessary.
AT&T?s provision of alerts and cut-offs for data and text go far beyond what the Euro-
pean Union regulations would require (if the Commission were to imitate the EU regulators).
The European Union regulations apply only to intra-EU roaming and require usage alerts for data
roaming services only. AT&T provides alerts and cut-offs for data and messaging no matter
where the customer is located within the country. AT&T developed these tools to provide the
best customer experience in the world?s most highly competitive wireless marketplace. To re-
place such competition-driven, innovative consumer benefits with a one-size fits all European
regulations would not benefit consumers. The US wireless industry is an incredible success sto-
ry, with competition breeding innovation and consumer benefits in the form of more robust net-
works, better devices, more applications, lower prices and higher usage than wireless customers
enjoy anywhere else in the world. To the extent that the Commission adopts a static rule ?defin-
ing? part of the customer experience, it will serve as an obstacle to attempts to improve it.
11
July 06, 2010 Respectfully submitted,
/s/William Roughton
William Roughton
Gary L. Phillips
Michael Goggin
Paul K. Mancini
AT&T Inc.
1120 20th Street, N.W.
Suite 1000
Washington, D.C. 20036
(202) 457-2040 ? phone
(202) 457-3073 ? facsimile
Its Attorneys
12
Attachment 1
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Attachment 2
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Attachment 3
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Attachment 4
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Atachment 5
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Atachment 6
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Atachment 7
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Atachment 8
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Atachment 9
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Atachment 10