High Level Meetings on Highly Sensitive issues

 
Geographic Routing, Shared Use, and Location Based Services Among the Issues Discussed with Telecom Leaders in D.C.

MessageComm director Noah Rafalko recently met with leaders from the Wireless Telecommunications Bureau, the Consumer Government Affairs and the Office of Economics and Analytics to discuss current issues with consumer text messaging.

He also met in person with Travis Litman, Federal Communications Commissioner (FCC) Jessica Rosenworcel's senior legal advisor for wireline and consumer issues. 
 
While our goal is to provide safe and effective routing of text messages in compliance with consumer privacy laws, we believe Toll-Free service providers should be able to offer non-specific or ‘fuzzy’ geographic data routing and ‘Shared Use’ services without interference or unnecessary opt-ins. 
 
Further, we think there are better ways to manage text SPAM and finally, that consumer privacy and public safety could be at risk if and when there’s a lack of oversight or guidance over wireless operators.

Opting In Is Redundant
Consumers who consensually call a nationwide Toll-Free number are now being asked to ‘opt in’ before their call is completed. The result is that call abandonment rates have skyrocketed to over 50 percent. Messaging will eventually fall victim to the same narrow views. 

Messaging guidelines recently issued by the CTIAstate that consumers who text a Toll-Free number consent to the communication without needing to opt in. We believe requiring consumers to ‘opt in’ is not only unnecessary; it could even present a hindrance and possible safety issue. 

Let's Enable Location Based Services (LBS)
We support enabling the caller’s non-specific or ‘fuzzy’ geographic location – whether they call or message a Toll-Free number. 

When using course look-up to enable geographic routing of a Toll-Free call or message, telecommunications service providers do not store the consumer’s data, nor do they sell the data. Providers simply geographically route communications using ‘fuzzy’ locations (usually at the tower location and not the consumer’s GPS location), which doesn’t breech privacy.

‘Shared Use’ of high value numbers allows a nationwide business to use a single number such as 800-LAWYERS to provide services across a wide geographic region and have the call automatically routed according to the caller’s ‘fuzzy’ location. Shared Use is also a win for consumers who are directed to the business address closest to them. Plus, Shared Use can significantly increase the value of the most sought-after numbers in the 833 auction. 

Impeding the ability to route calls and messages to Toll-Free numbers to the business closest to the caller’s location (aka ‘Course’ Location Based Services or LBS) could even affect public safety, e.g., when callers contact help lines for poison control, domestic violence, commuter safety and so on. 

We believe the FCC could restore confidence and value to consumers by reminding mobile phone and originating carriers of their obligation to protect consumers’ precise location while providing only ‘fuzzy’ location data to Toll-Free service providers and wireless operators. 

We hope the FCC will support geographic routing and communications by rendering a positive decision on the Petition For Immediate Declaratory Relief or the Petition for Rulemaking, filed by 800 Response Information Services, LLC, CC Docket No. 96-115.

Managing SPAM 
Currently, wireless operators only use a self-managed SPAM reporting system which requires consumers to forward suspected SPAM texts to 7726 (SPAM).

However, we believe a better solution would be to provide critical SPAM data to industry policymakers and operators utilizing a neutral third party. 

By centralizing this data, this third party could alert networks of potential bad actors in real time, which could also prevent network hopping. Artificial Intelligence (AI) could then be used to better understand trends and quickly stop offenders, enabling our industry to maintain the trust consumers have in text messaging as a SPAM-free service.

Oversight Needed to Prevent a Monopoly
Within the existing Toll-Free texting space, the top four wireless operators as well as many other smaller operators use a single vendor that now enjoys a monopolistic proxy role. 

Not only is there no competition, there also is no oversight over this single gateway provider that fails to provide Reasons For Outages (RFO) that can extend for hours or any Service Level Agreements (SLAs) for this mission-critical communications service. 
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The FCC’s deregulation act protects against state and federal communications monopolies that impede interconnection rights. Last year, the FCC classified text messaging as a Title I service. However, we believe that consumer rights, privacy and public safety could be harmed if wireless operators are given complete control with no oversight or guidance.

At MessageComm, part of our mission is to advocate for the future of messaging, which has become a mission-critical communication channel for consumers, business and government alike. This blog summarizes the two Ex Partes filed with the FCC’s Consumer and Governmental Affairs Bureau, Wireless Telecommunications Bureau, and Office of Economics and Analyticsand the Office of Commissioner Jessica Rosenworcel. 
 
We will continue to keep you informed of our progress. We would love for you to join us!

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