AT&T workers respond following Sandy. AT&T says an FCC "yardstick" for measuring how well individual wireless networks maintain service during disasters is unnecessary and misleading. 

As a way of providing an impetus for carriers to improve network resiliency during events like Superstorm Sandy, or the Boston Marathon bombing, the FCC opened a Notice of Proposed Rulemaking (NPRM) for a plan that aims to quantify the percentage of network sites in each county that are operational during and after an emergency and publish a score for each carrier based on those results. 

In response to the NPRM, AT&T said the measures were "well intended" but ultimately "unnecessary, counter-productive and potentially harmful." 

AT&T refuted the idea that such a plan would foster more competition across the market thus providing incentive for the carriers to beef up their emergency preparedness. 

"We believe this proposed regulation is unnecessary because carriers are fully motivated today by competition to make their networks reliable and resilient, hardening them against storms and other events that might tend to disrupt communications or impact facilities," AT&T wrote. "In short, competition exists and is working to make networks reliable and resilient." 

AT&T detailed the systems it already has in place, noting that the company has Meals Ready to Eat (MRE) and other provisions to create self-sufficient emergency teams that can respond to outages even when infrastructure and resources are crippled. 

AT&T shed some light on how it responded to Boston Marathon bombings. At the time there was some confusion as to whether AT&T and other carriers had shut down their networks at the request of the law enforcement. AT&T denied it had done so. In the filing, AT&T said the bombing in Boston did not impair any AT&T owned facilities. 

"Rather, although AT&T Mobility was prepared for projected additional usage during the marathon, especially at or near the finish line, the terrorist event spiked wireless usage even more than reasonably projected, placing a super-extraordinary burden on the AT&T Mobility network," AT&T wrote. "As part of its response, AT&T Mobility opened its Wi-Fi network in the affected area to allow everyone, including non-AT&T subscribers, to access the Internet."

In lieu of the FCC's proposed plan, AT&T urged the commission to foster cooperation among carriers during emergencies, saying that inter-carrier communication would go further towards helping customers stay connected than would a plan that "turn disaster recovery into a contest, undermining carrier-to-carrier cooperation."