This past May, EWA suggested that the FCC clarify what registration information is required for embedded signal boosters and to provide an online database of already certified devices that meet the Consumer Signal Booster Network Protection Standard. Later, both Verizon Wireless (Verizon) and CTIA - The Wireless Association® (CTIA) filed comments opposing the EWA Petition.  Verizon acknowledged the issues that prompted the Petition and attempted to craft alternatives to the relief requested by the Alliance.  With regard to the timing of the deadlines, Verizon proposed that enterprise entities unable to register their signal boosters within the 90-day window established by a carrier should request waivers that the FCC could consider on a case-by-case basis. On the other hand, CTIA filed a response that was wildly disproportionate to the measured relief requested by EWA.   Unlike Verizon, CTIA offered no recognition of the practical issues that large enterprise users will face in complying with a regulatory scheme with which they are not opposed. Amazingly, CTIA added that EWA’s proposals would “further prolong the interference environment created by unauthorized consumer signal boosters.”

In response to Verizon’s suggestions, EWA countered that “[R]ather than establishing an uncertain and burdensome waiver process, the Alliance believes it is preferable to establish a single deadline for registering all already deployed signal boosters, both consumer and industrial.  November 1, 2014, is only eight months later than the March 1, 2014, date already adopted by the FCC and only five months later than the 90-day closing of that window. This relatively modest difference will result in a more accurate registration process, which is the primary objective of the proceeding.
In response to CTIA’s hyperbolic claim that EWA’s proposal “would strip wireless providers of th[e] discretion provided to them … establishing a November 1, 2014, registration deadline regardless of how early a wireless provider makes its registration process available to customers,” we noted that CTIA’s assertions are simply incorrect.  Wireless carriers would be free to open their registration process whenever they choose.  The proposal would simply extend the date at which the registration process for embedded equipment would close.

EWA also reminded CTIA that EWA’s members are substantial users of commercial wireless networks and are affected by interference on those networks just like all other subscribers.  They rely on public safety services that also can be adversely impacted by those rare, but exceedingly problematic, instances when consumer signal boosters cause interference to emergency provider systems. The Alliance agrees that new boosters should be labeled and registered as required by the rules.  It also supports registration of already deployed boosters – even those that have never caused interference, which is the vast majority of units in service.  The issue is establishing a reasonable path that will allow enterprise users sufficient time to provide carriers with accurate information about those long-embedded devices, an objective EWA would have expected CTIA to support.  EWA's Response