Response of the Alliance of Telecommunication Industry Solutions to Request for 

Information of the National Institute of Standards and Technology concerning the 

Effectiveness of Federal Agency Participation in Standardization and Conformity 

Assessment Activities 

 The Alliance for Telecommunications Industry Solutions (ATIS) submits this response to 

the December 8, 2010, Request for Information of the National Institute of Standards and 

Technology (NIST) in Docket No 0909100442-0563-02, concerning the effectiveness of federal 

agency participation in standardization and conformity assessment activities. 

 For the reasons discussed below, ATIS, based on its close to thirty (30) year history as a 

US-based standards development organization (SDO) and the direct involvement of federal 

agencies in ATIS’s work efforts, respectfully submits that: 

 Federal agencies have effectively participated in the private development of standards 

in the United States.

 Great caution should be exercised not to disrupt industry standardization efforts, 

because the consensus-based processes followed by SDOs such as ATIS have 

successfully addressed public policy initiatives. ATIS, for example, is already 

pursuing important projects relating to Smart Grid, machine-to-machine, Cloud 

Services, sustainability, lawfully-authorized electronic surveillance, commercial 

mobile alert system, and network reliability. ATIS’ success in pursuing these and 

other projects, including those with significant public policy implications, has occurred 

as the result of ATIS’s ability to react to industry needs and government requirements. 

ATIS’ long-established intellectual property policy, which is based on the policy of the 

American National Standards Institute (ANSI), also has allowed for the effective and 

timely development of ATIS standards and deliverables.

 Further coordination by federal agencies with, and participation in, SDOs, including 

ATIS, should be encouraged, but with the understanding that existing private sector 

processes and procedures allow for such coordination and participation on an effective 

level. 

I. Background 

ATIS is a global standards development and technical planning organization committed 

to providing leadership for, and the rapid development and promotion of, worldwide technical 

and operations standards for information, entertainment, and communications technologies. 

ATIS has been pursuing such efforts since its establishment in 1983 under its prior name, the 

Exchange Carriers Standards Association (ECSA), and has expanded the scope of its activities 

and membership from those originally focused on traditional wireline telephone technologies to 

its current work on all manner of technologies. 
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 Thus, ATIS’s membership is now diverse, including wireline and wireless service 

providers, equipment manufacturers, competitive local exchange carriers, data local exchange 

carriers, providers of commercial mobile radio services, broadband providers, software 

developers, consumer electronics companies, digital rights management companies, and internet 

service providers. Many, if not most, of these companies are global in nature. 

 Industry subject matter experts from more than 200 organizations, including a number of 

federal agencies and local governmental authorities, actively participate in ATIS’ open technical 

committees and forums. ATIS is an ANSI-accredited standards developer, but its deliverables 

go well beyond the development of American National Standards. The output of ATIS’ 

committees and forums include all manner of standards, technical specifications and 

requirements, best practices, interoperability testing, guidelines, white papers, and technical 

analyses. These deliverables focus on a broad range of information and communications 

technology (ICT) priorities, including network architectures and platforms, the ordering and 

billing of services, E-911 an NG911, cyber security, the reliability and interoperability of current 

and next generation of technologies, the seamless delivery of converged wireline and wireless 

services such as IPTV over multimedia platforms, and the networks of the future. 

 ATIS and its committees/forums also actively engage in the larger global standards ecosystem. ATIS is a large US contributor to the International Telecommunication Union 

Telecommunication Standardization Sector (ITU-T), the UN-based treaty organization that, 

among other things, establishes specifications that foster international interconnection between 

communications systems. ATIS is also a founding organizational partner of the 3rd Generation 

Partnership Project (3GPP), which brings ATIS together with the leading ICT SDOs from 

Europe, Japan, Korea and China to develop mobile communication standards. ATIS is likewise 

a founding member of the Global Standards Collaboration (GSC), an initiative of leading global 

ICT SDOs that promotes the international harmonization of communication standards. 

II. The Effective Participation of Federal Agencies in ATIS Activities

 ATIS’ success in developing effective and implementable standards and other 

deliverables is due, at least in part, to the participation of both private sector and governmental 

stakeholders in ATIS committees and forums. Representatives from the following federal 

agencies have all participated in ATIS’ activities: the National Communication System; 

Department of Defense; Federal Bureau of Investigation; Federal Communications Commission; 

Department of Homeland Security; and Department of Commerce, through NIST and NTIA. 

Such participation is encouraged by the National Technology Transfer and Advancement Act of 

1995, Public Law 104-113 (NTTAA), as well as by the Office of Management and Budget 

(OMB) Circular A-119, Federal Participation in the Development and Use of Voluntary 

Consensus Standards in Conformity Assessment Activities. 

 ATIS has had specific success as the result of the private/public coordination encouraged 

by the NTTAA and OMB Circular A-119. One such example involves the Commercial Mobile 

Alert System (CMAS), which allows participating commercial mobile service providers (CMSP) 
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to send emergency alerts to customers’ mobile devices. Private stakeholders, together with 

representatives of, among others, the Federal Communications Commission, Department of 

Homeland Security, and the Federal Emergency Management Agency, worked through ATIS (in 

conjunction with the Telecommunications Industry Association (TIA), another SDO) 

expeditiously and cooperatively to develop a standard needed to implement the CMAS interface 

between the commercial mobile service provider and federal alert gateways. In addition, further 

coordinated efforts were undertaken and completed to develop a test specification to define the 

operational testing procedures for this interface between the gateways. 

 Other examples of such private/public coordination within ATIS can be seen in its 

Network Reliability Steering Committee (NRSC), which develops guidelines and best practices 

to foster the reliability of communications systems. The FCC and NRSC actively cooperate to 

identify and examine causes of outages and to develop recommendations that may reduce or 

mitigate future outages. Active cooperation also exists between ATIS’ Industry Numbering 

Committee (INC) and the FCC’s North American Numbering Council (NANC) Federal 

Advisory Committee, which work cooperatively to identify issues pertaining to the management 

of telephone numbering resources within the North American Numbering Plan. 

 ATIS deliverables have also been adopted by federal agencies consistent with the 

NTTAA’s principle that government agencies should use private industry-developed standards in 

lieu of developing specific governmental standards. There are many examples of ATIS 

standards being used or referenced by federal agencies, for example: 

 The FCC requires the North American Numbering Plan Administrator (NANPA) and the 

Pooling Administrator (PA) to comply with the guidelines developed by the ATIS INC 

Guidelines (47 CFR § 52.13(b)(3)). 

 In developing rules pertaining to the exchange of customer information between service 

providers, the FCC acknowledges the successful work of the ATIS Ordering and Billing 

Forum (OBF) in developing Customer Account Record Exchange (CARE) guidelines and 

encourages providers to use these guidelines and to work with the OBF to further develop 

and refine them. (See Report and Order and Further Notice of Proposed Rulemaking, 

CG Docket No. 02-386, at ¶ 59 (rel. Feb. 25, 2005). 

 The Communications Assistance for Law Enforcement Act, Public Law 103-414, also 

acknowledges industry standards by establishing that service providers may rely on 

industry-developed standards when determining compliance with CALEA. One such 

“safe harbor” standard is ATIS’s standard titled “Lawfully Authorized Electronic 

Surveillance (LAES) for Voice over Packet Technologies in Wireline 

Telecommunications Networks (ver. 2).” Another “safe harbor” standard is the joint 

TIA/ATIS standard for “Lawfully Authorized Electronic Surveillance.” 

 As described above, the Department of Homeland Security (DHS) approved the “Joint 

ATIS/TIA Commercial Mobile Alert System (CMAS) Federal Alert Gateway to 

Commercial Mobile Service Provider (CMSP) Gateway Interface Specification” as a 

DHS National Standard. 
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The Federal government has also collaborated with ATIS through the funding of joint 

projects. One such project was the National Diversity Assurance Initiative, a collaborative effort 

between ATIS and the Federal Reserve to provide an in-depth assessment of the feasibility of 

validating the existence of diversity on critical NS/EP circuits and to identify methods to assure 

that the diversity is maintained on those circuits over time. The project resulted in the 

publication of a final report in February 2006 describing both the lessons learned and 

recommendations for additional work. A follow-on project, known as the Diversity Assurance 

Initiative, was a collaborative effort between the ICT industry and the National Communications 

System to evaluate and scope potential solutions for diversity assurance in a multi-carrier 

environment. 

 Given the success of the involvement and coordination of private standards development 

and federal agencies, ATIS submits there is no need to develop a new point of contact within the 

government to coordinate the US government’s standards policy or activities. In addition, such a 

new office would be duplicative of the existing Interagency Committee on Standards Policy 

(ICSP), acting under the auspices of NIST. ICSP already effectively brings together the 

standards offices of numerous federal agencies to discuss standards issues of interest and/or 

concern to those agencies. It also addresses best practices on the part of federal agencies with 

the current standards process. Further, ICSP participates in meetings of organizations such as 

ANSI to keep the standards development community informed of issues and to suggest 

improvement to the system. The ICSP is a working example of the existing effective 

public/private industry partnership. Adding another layer of governmental involvement would 

only increase costs and slow innovation through standardization. 

 Similarly, the increasingly global nature of standardization does not compel a 

modification of the existing approach for coordinating the public and private interests in 

standards development. There continues to be effective representation of US standardization 

interests in the development of international standards, and in the harmonization of US and 

international standards. Moreover, SDOs such as ATIS have dynamically adjusted to 

international developments to ensure that the interest of ATIS’ members, including agency 

stakeholders, and industry in general, are continuously addressed internationally. 

III. The Current Voluntary, Consensus-Based Standards Approach Followed by ATIS 

Should Not Be Modified 

The open, voluntary, consensus-based standardization approach followed by ATIS and 

other SDOs has had great success. This is attributable to a number of factors. Perhaps most 

importantly, the current private standards environment allows for a wide range of stakeholders’ 

interests to be accommodated, and for standardization decisions to be based on the consensus of 

such stakeholders. This includes the interests of federal agencies through their representatives 

participating in the standards development efforts of SDOs such as ATIS. 
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 ATIS has also been responsive to the dynamic nature of standardization. Over its history, 

ATIS has evolved from the paradigm of developing “standards for standards sake” to one 

focused on “standards for business sake.” As a result of this shift, ATIS has been able to quickly 

react to industry and public policy priorities, and create standardized solutions in important areas 

of emerging technologies. 

 ATIS’ activities in relation to the Smart Grid illustrate its effectiveness. As the 

implementation of Smart Grid became a national priority, ATIS took two actions to facilitate 

standardization on this issue. First, ATIS identified existing standards, as well as 3GPP wireless 

technologies, that would be applicable to Smart Grid applications. ATIS also worked closely 

with federal agencies, including NIST, to ensure that they were aware of relevant industry work. 

In fact, ATIS has been named as a collaborator by NIST in its Framework and Roadmap for 

Smart Grid Interoperability Standards. Second, ATIS began to examine its standardization work 

to determine what needs to be done to facilitate Smart Grid applications. As part of this effort, 

ATIS has also undertaken an initiative as part of its Board of Directors’ Technology and 

Operations Council (TOPS) to examine the interrelationship between key machine-to-machine 

applications, including Smart Grid, to identify the need for new standardization efforts. 

 IP-based television (IPTV) is another example of how the existing standardization 

approach followed by ATIS is effective in reacting to new technologies. As the industry began 

to consider IPTV, ATIS formed a new committee, the IPTV Interoperability Forum (IIF), to 

examine issues surrounding the interoperability, interconnection, and implementation of IPTV 

systems/services. ATIS has been on the forefront of global standardization work on this issue, 

with ATIS’ work serving as the basis for other international standardization efforts on this topic. 

 ATIS’ collaborative and consensus-based approach has likewise been effective in directly 

addressing policy issues. ATIS has thus successfully identified specific issues that are at the 

crossroads of technology and policy and in ensuring that all appropriate stakeholders have an 

opportunity to work together in a collaborative environment. One example of this is reflected in 

ATIS’ work regarding the hearing aid compatibility (HAC) of wireless devices. All 

stakeholders, including service providers, equipment manufacturers, academic organizations, and 

representatives of consumers with hearing loss, collaborated under ATIS’ consensus-based 

processes to develop recommendations for changes to the FCC’s HAC regulations to ensure that 

these regulations were technology-neutral and technically feasible and would allow all 

consumers to benefit from the availability of cutting edge products and service offerings. 

An attempt to “fine tune” the existing US approach to standardization would risk 

inhibiting the ability of ATIS, and other SDOs, to continue effectively addressing industry and 

policy initiatives in a timely fashion. Such a government led “top down” approach, as distinct 

from the current private/public “bottom up” collaborative approach, would limit ATIS’ ability to 

react to changing industry priorities and quickly evolving technical developments. Such an 

approach would, in all events, slow ATIS’ ability to address important standardization issues by 

binding ATIS to an agenda established by regulatory authorities that may not have direct 

involvement with the actual technological issues at stake, and not by consensus of interested 
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stakeholders. This, of course, is not meant to suggest that there should be any less involvement 

of agency input into the setting of standardization priorities (and as discussed below, ATIS 

suggests that such participation should increase), but such involvement is best focused through 

the existing approach. This position is consistent with the nearly unanimous views expressed in 

the National Survey of United States Standardization Policies (August 2009), which found that 

“current United States policies for the development of private-sector technology standards are 

working well, and that no changes to those policies or the current balance of private sector/public 

sector partnership relating to standards are necessary at this time.” 

 Nor is it ATIS’ experience that any change in the current standardization approach is 

necessary because of intellectual property issues. ATIS’ IPR policy is modeled on the ANSI 

policy, and seeks the disclosure of IPR that may be essential to a standard, and for owners of 

essential IP to provide licensing undertakings stating their willingness to make licenses available. 

This policy has worked well for ATIS, which has experienced no instances where IPR has 

delayed or precluded the development of an ATIS standard or its implementation. This includes 

with respect to those standards developed for implementation by federal agencies or pursuant to 

agency direction. 

IV. Increased Agency Involvement in ATIS Activities Would Be Beneficial 

Greater participation of federal agency representatives in ATIS’ activities, and the 

coordination of agency priorities through ATIS, would be beneficial to the industry and to 

federal agencies. So long as the existing collaborative, open, consensus-based approach that 

ATIS has always followed remains undisrupted, such participation would increase the 

understanding of both the private and public sectors. Such greater agency involvement would 

allow agencies to reflect industry expertise in the setting of their priorities and would present 

opportunities for collaborative work that would leverage the efficiencies of ATIS’ standard 

setting activities. It would also allow industry to benefit from, and be responsive to, agency 

identified issues and to take advantage of the subject matter experts that work in federal 

agencies. 

V. Conclusion 

For the reasons set forth, ATIS respectfully submits that current federal agency 

involvement in standards development is effective. Benefit, however, may arise from even more 

such involvement, but with the understanding that it is necessary to maintain, and not 

compromise, the existing consensus standardization approach followed by ATIS. This approach 

has allowed for tremendous successes, including in relation to standards development directed by 

or to address, federal agency interests, and no steps should be taken that would compromise or 

constrain such existing efforts.