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CTIA asked the FCC to change part of its May 17 text-to-911 order to drop a roaming requirement. CTIA took issue with a single paragraph in the order, requiring all carriers and providers of interconnected text message services to provide subscribers with automatic 911 bounceback messages by Sept. 30 (CD May 9 p4). That paragraph said the requirement means carriers also have to provide the message “when a consumer roaming on a network initiates a text-to-911 in an area where text-to-911 service is not available.” CTIA said it’s too early in the game to impose this requirement (http://bit.ly/11UWFo1). “The Commission should not address roaming requirements until appropriate technical organizations are able to confirm that such requirements are technically feasible,” CTIA said. “Eliminating or modifying the rules ... will help ensure that the Commission complies with its statutory obligations. As adopted, the Commission did not provide adequate notice of the roaming requirement because commenters were instructed not to address roaming during the bounce-back message portion of this proceeding. Moreover, the rule is inconsistent with the Twenty-First Century Communications & Video Accessibility Act ... because, to the extent that the Commission relies on the CVAA as the rule’s basis of authority, the rule must be ‘achievable and technically feasible.'"
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