CRF 47 20.12(c) Manual Roaming

[carl4662]

It seams to me that AT&T is in violation of CFR 47 20.12(c) by not providing Manual Roaming.

http://frwebgate.access.gpo.gov/cgi-...=2002&TYPE=PDF

CFR 47 20.12
(c) Manual Roaming. Each carrier subject to this section must provide mobile radio service upon request to all subscribers in good standing to the services of any carrier subject to this section, including roamers, while such subscribers are located within any portion of the licensee's licensed service area where facilities have been constructed and service to subscribers has commenced, if such subscribers are using mobile equipment that is technically compatible with the licensee's base stations.

To Summarize: Carrier must provide service to all subscribers in good standing where mobile equipment is technically compatible with the base stations.

If they are not in violation, can someone please explain to me how they provide manual roaming. The CDMA carriers all offer this service to roamer exactly as defined above.

[efparri]

(3) This paragraph shall cease to be
effective five years after the last group
of initial licenses for broadband PCS
spectrum in the 1850–1910 and the 1930–
1990 MHz bands is awarded; i.e., at the
close of November 24, 2002.

This rule only applied to carrriers operating in the 800 MHz band until the 1900 MHz band was available. In any case, this rule applied to the roaming partner allowing other users to roam on its circuits. It does not apply to home carriers allowing its subscribers to roam on other networks.

[carl4662]

Originally Posted by efparri

This rule only applied to carrriers operating in the 800 MHz band until the 1900 MHz band was available. In any case, this rule applied to the roaming partner allowing other users to roam on its circuits. It does not apply to home carriers allowing its subscribers to roam on other networks.

The part that expired was paragraph B. Paragraph C is still in effect.

As a matter of fact the FCC ruled on this again on Aug 7th 2007. See http://hraunfoss.fcc.gov/edocs_publi...C-07-143A1.pdf Paragraph 74. Discussion. “We decline to sunset our existing manual roaming rule and, instead, retain it as a safety net for consumers."

The more I read about this I cannot believe that they are getting away with this non-compliance. Anyone who has even been denied manual roaming where AT&T could have provided service has a valid complaint and being denied the "safety net" that that the FCC specifies.

[Nextel32708]

Looks like over at Howard Forums they are having the same discussion... I found this posters entry very informative.

Originally Posted by FormerRuling from HowardForums

What you are saying is "Any device has to have the ability to choose which network to connect to", and they are all telling you that is not what the paragraphs you quoted state...at all.

Basically what I read is:
(c) Manual Roaming. Each carrier subject to this section (AT&T) must provide mobile radio service upon request (Must let people connect to their network) to all subscribers in good standing to the services of any carrier subject to this section, including roamers (even if they are roaming [not AT&T customers]), while such subscribers are located within any portion of the licensee's licensed service area where facilities have been constructed and service to subscribers has commenced (if they are in an AT&T covered area), if such subscribers are using mobile equipment that is technically compatible with the licensee's base stations (and their device allows them to connect to the network).

----------

So if a T-mobile customer customer wonders into an area where there isn't T-mobile coverage but theres' some AT&T coverage - They can still use their phone (Though it'll be "roaming" and subject to whatever roaming clause or charges are involved). No where does it say the customer gets to freely choose whether they want to connect to T-mobile or AT&T (in those areas where both are present).

SOURCE: HowardForums: Your Mobile Phone Community & Resource - View Single Post - AT&T in DIRECT VIOLATION of FCC LAWS! - Manual Network Selection!!

[efparri]

Originally Posted by carl4662

The part that expired was paragraph B. Paragraph C is still in effect.

As a matter of fact the FCC ruled on this again on Aug 7th 2007. See http://hraunfoss.fcc.gov/edocs_publi...C-07-143A1.pdf Paragraph 74. Discussion. “We decline to sunset our existing manual roaming rule and, instead, retain it as a safety net for consumers."

The more I read about this I cannot believe that they are getting away with this non-compliance. Anyone who has even been denied manual roaming where AT&T could have provided service has a valid complaint and being denied the "safety net" that that the FCC specifies.

You cherry picked one sentence to support your position. The document, in toto, reaches an opposite conclusion. The roaming rules only apply when the subscriber is away from his home market. That is, the rules apply to the foreign host when the subscriber is roaming in the foreign host's coverage area. The rules do not require yor home carrier to let you roam at will.

[Jay2TheRescue]

The reason HoFo's talking about it is because we are...

Okay the reason the hyperlinks aren't working is because I copied and pasted this from WirelessAdvisor and I am guessing the hyperlinks did not copy correctly.

But here is the link to the original thread at WirelessAdvisor (I am posting this soley for link-back to the URLs in this post which are not working on HoFo - but do work in the WA thread).

http://forums.wirelessadvisor.com/a...2-c-manual.html

[carl4662]

I did not cherry pick and I also did not mean to imply that the home carrier had to allow any roaming. What I am saying is that the serving carrier can not deny roaming just because they do not have an agreement with the home carrier. From the network perspective if the Serving MSC can not or does not communicate with the HLR it must offer manual roaming. Stated another way if the MNC on the SIM is not recognized by the serving system it must offer manual roaming. This is the way the CDMA carriers are doing it and AT&T has apparently chosen not to implement.

[efparri]

Originally Posted by carl4662

I did not cherry pick and I also did not mean to imply that the home carrier had to allow any roaming. What I am saying is that the serving carrier can not deny roaming just because they do not have an agreement with the home carrier. From the network perspective if the Serving MSC can not or does not communicate with the HLR it must offer manual roaming. Stated another way if the MNC on the SIM is not recognized by the serving system it must offer manual roaming. This is the way the CDMA carriers are doing it and AT&T has apparently chosen not to implement.

What does AT&T have to do with whether a foreign (not home) carrier will allow you to connect to their network? If there is no roaming agreement, you will have to pay for the call on the spot with a credit card.

[carl4662]

Originally Posted by efparri

What does AT&T have to do with whether a foreign (not home) carrier will allow you to connect to their network? If there is no roaming agreement, you will have to pay for the call on the spot with a credit card.

I am not an AT&T customer and they block access to their network to non-customers where they do not have an agreement in place with the home carrier. AT&T does not give an option to pay for the call at all. When you register they deny service and then the only call you can make is to 911. Making a call with a calling card is much better than no service at all.

By the way manual roaming on the CDMA carriers does not cost what it used to. It cost as little as $.25 per minute and does not require a contract.

[efparri]

Originally Posted by carl4662

I am not an AT&T customer and they block access to their network to non-customers where they do not have an agreement in place with the home carrier. AT&T does not give an option to pay for the call at all. When you register they deny service and then the only call you can make is to 911. Making a call with a calling card is much better than no service at all.

By the way manual roaming on the CDMA carriers does not cost what it used to. It cost as little as $.25 per minute and does not require a contract.

What GSM carrier do you have and does it have native coverage in the location where you want to roam on AT&T Mobility?

[carl4662]

Originally Posted by efparri

What GSM carrier do you have and does it have native coverage in the location where you want to roam on AT&T Mobility?

I don't currently have a problem with my current carrier. I had problems when I was with PowerTel and I know that RuralCom currently does not have an agreemnet with AT&T and their customers are not being offered manual roaming. I have a SIM with a MNC that is not currently active, with this SIM in my phone I should be directed to manual roaming. In all these examples there is (was) no native coverage. I realize that AT&T has hundreds of agreements so the problem is small.

[efparri]

Originally Posted by carl4662

I don't currently have a problem with my current carrier. I had problems when I was with PowerTel and I know that RuralCom currently does not have an agreemnet with AT&T and their customers are not being offered manual roaming. I have a SIM with a MNC that is not currently active, with this SIM in my phone I should be directed to manual roaming. In all these examples there is (was) no native coverage. I realize that AT&T has hundreds of agreements so the problem is small.

Then you have proven that the regulations work as intended. You are only entitled to SOS service with an inactive SIM card.

[carl4662]

Originally Posted by efparri

Then you have proven that the regulations work as intended. You are only entitled to SOS service with an inactive SIM card.

You are correct with an inactive SIM, AT&T does not have to provide manual roaming. As long as they verified with the home carrier that the SIM is inactive. That is a bad example on my part. I only made this bad example because I doubt that AT&T could tell the difference between a inactive or active SIM where they do not have an agreement with the home carrier. What about the other examples where the SIM is active with a home carrier and AT&T still denies service because they do not have an agreement with the home carrier. These are still valid examples of where AT&T is not providing manual roaming. If I'm wrong please show me one example on how an end user with a home carrier that does not have an agreement with AT&T is offered Manual Roaming service. The old TDMA AT&T did offer service in the scenario, the GSM AT&T does not.

[efparri]

Originally Posted by carl4662

You are correct with an inactive SIM, AT&T does not have to provide manual roaming. As long as they verified with the home carrier that the SIM is inactive. That is a bad example on my part. I only made this bad example because I doubt that AT&T could tell the difference between a inactive or active SIM where they do not have an agreement with the home carrier. What about the other examples where the SIM is active with a home carrier and AT&T still denies service because they do not have an agreement with the home carrier. These are still valid examples of where AT&T is not providing manual roaming. If I'm wrong please show me one example on how an end user with a home carrier that does not have an agreement with AT&T is offered Manual Roaming service. The old TDMA AT&T did offer service in the scenario, the GSM AT&T does not.

Since you made the assertion, the burden of proof is upon you. One cannot prove a negative.

The foreign carrier checks with the carrier indicated by the MCC-MNC combination the first time you attempt to register with the network. They determine first whether the SIM card is valid. If the SIM card is invalid, no further action is taken If the card is invalid, roaming agreements are of no consequence. The SIM card is rejected for other than SOS calling.

[carl4662]

Originally Posted by efparri

Since you made the assertion, the burden of proof is upon you. One cannot prove a negative.

The foreign carrier checks with the carrier indicated by the MCC-MNC combination the first time you attempt to register with the network. They determine first whether the SIM card is valid. If the SIM card is invalid, no further action is taken If the card is invalid, roaming agreements are of no consequence. The SIM card is rejected for other than SOS calling.

What happens if the foreign carrier can not verify the MCC-NNC combination because they have no agreement with the home carrier? They do not know if the SIM is valid or not, they only know that they do not have an agreement with the home carrier and that they have no way to verify the subscriber. This is where they must offer manual roaming. In this case AT&T blocks the call regardless of the validity of the SIM with the home carrier.

You do make a good point I need to get a service with a GSM carrier that does not have an agreement with AT&T. Then I would have a valid complaint when my phone goes SOS while camping on one of their towers.

[efparri]

Originally Posted by carl4662

What happens if the foreign carrier can not verify the MCC-NNC combination because they have no agreement with the home carrier? They do not know if the SIM is valid or not, they only know that they do not have an agreement with the home carrier and that they have no way to verify the subscriber. This is where they must offer manual roaming. In this case AT&T blocks the call regardless of the validity of the SIM with the home carrier.

You do make a good point I need to get a service with a GSM carrier that does not have an agreement with AT&T. Then I would have a valid complaint when my phone goes SOS while camping on one of their towers.

You misunderstand how the system works. Checking for a roaming agreement is done to determine how the call will be billed. The valdity of the SIM card has already been determined by that point. See these links for an explanation:

http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf

[carl4662]

Originally Posted by efparri

You misunderstand how the system works. Checking for a roaming agreement is done to determine how the call will be billed. The valdity of the SIM card has already been determined by that point. See these links for an explanation:

http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf
http://www.eventhelix.com/RealtimeMa..._Call_Flow.pdf

I understand how roaming works, I have just not presented it correctly, The normal Registration process work like this
1) When the mobile device is turned on the new "visited" network sees the device, notices that it is not registered with its own system, and attempts to identify its home network. If there is no roaming agreement between the two networks service is denied by the visited network.

2) The visited network contacts the home network (HLR) and requests service information (including whether or not the mobile should be allowed to roam) about the roaming device using the IMSI number.

3) If successful, the visited network begins to maintain a temporary subscriber record (VLR) for the device.

In the examples you sent me, for an unregister roamer, the calls will fail because there is not a VLR entry. The way I see CFR 47 20.12(c) is: if step one fails the visited network must provide manual roaming. This is what all the CDMA carriers and a few GSM carriers are doing.

[carl4662]

Does anyone which US GSM carriers do not have a roaming agreement with AT&T? I'm reasonably sure all the larger carriers have an agreement, so it would have to be a small rural carrier, maybe in Alaska or something?

[hme83]

I don't know if this answers what you are asking, but doesn't it depend on the specific location in question and whether at&t has native coverage in that area? (i.e. to my understanding - roaming agreements are location specific - only where at&t needs/wants them to provide coverage).

You could get an idea of where at&t does have roaming agreements in place with other carriers by looking at the "partner coverage" areas on their coverage viewer. (Zoom in to further define the map and then the partner coverage areas are indicated. And prepaid service has more limited roaming coverage than post paid service, so be certain you are looking at the viewer for post paid service.)

AT&T Coverage Viewer

[carl4662]

Originally Posted by hme83

You could get an idea of where at&t does have roaming agreements in place with other carriers by looking at the "partner coverage" areas on their coverage viewer.

Why didn't I think of that, lol, Thanks

[hme83]

You're welcome.