AT&T

For the past two years, I’ve had the privilege to host TechGirls -- an international exchange program for girls from the Middle East and North Africa -- at AT&T’s office in DC for a day of job-shadowing.

TechGirls focuses on hands-on skills development in fields such as programming, mobile application building, web design, and more for girls between ages 15 and 17.

It’s an initiative of the US Department of State Bureau of Educational and Cultural Affairs and administered by Legacy International.

T-Mobile, which advertises itself as the “un-carrier,” has asked the Federal Communications Commission to “un-do” its data roaming rules, which were established in 2011 to facilitate reasonable data roaming arrangements while continuing to incent network investments.

T-Mobile now asks for a “declaratory ruling” which would effectively eviscerate that FCC decision and run afoul of the DC Circuit case which upheld it. There is no justification for granting T-Mobile’s petition -- in fact, according to T-Mobile’s own economist, wholesale roaming rates have trended “downward strongly” in recent years, and the average wholesale roaming rates paid by T-Mobile have fallen nearly 70 percent since 2011 and continue to decline.

There is also evidence that commercial negotiations are producing a variety of terms to meet differing needs, including the highly-touted LTE roaming hub T-Mobile’s own trade association (CCA) has established with scores of rural carriers to “help Sprint and T-Mobile fill the holes in their network[s].”

TruePosition recently commissioned and produced a test report purporting to show that its proprietary technology can meet the Federal Communications Commission’s proposed benchmarks for locating wireless 911 callers horizontally and vertically indoors.

The tests were run on a test bed in Wilmington, Delaware outside the context of the established CSRIC process specifically designed to assess new “911” location technologies.

And although TruePosition claims the test relied on commercial off-the-shelf technologies, it did not and the technologies used by TruePosition are not fully supported in any wireless network today. Moreover, the technology used would not provide complete location information in that it does not have the capability to provide a vertical estimate of location.

Beyond these significant limitations, the testing highlights even bigger concerns. The fact is that the approach proposed by TruePosition is, at the core, antithetical to the design of modern 3G and 4G networks.

TruePosition’s proposed solution depends on hardware installed at each base station seeing the handsets being served by other base stations. They also ignore the potential for the untenable interference that such an approach would likely create.

[Marsh serves as the AT&T Vice President of Federal Regulatory]

The Federal Communications Commission recently released proposed rules for the 3.5 GHz proceeding, a proceeding that has received a lot of attention as it is the first attempt to apply the President’s Council of Advisors on Science and Technology (PCAST) report that promotes the sharing of federal spectrum with non-federal users.

The Commission has identified this spectrum as an “innovation band” and we applaud them for their “outside-the-box” thinking on increasing spectrum efficiency. However, it is crucial that the Commission find the right balance between implementation of this new sharing model and incentives to invest in the technology necessary to make it work.

As this 3.5 GHz spectrum is spectrally higher than what mobile broadband optimally uses, the FCC has proposed using this band for “small cell” deployments. Small cells are low-powered, low-elevation micro cells that are typically installed in office complexes, campuses and residential areas to augment the large macro cell sites that are used for main coverage areas.

Small cells are typically used to increase network capacity in areas such as stadiums or metro stations where demand for network services is concentrated in a small area. Today, this is accomplished in many areas by using Wi-Fi networks where available. But a licensed spectrum band such as 3.5 GHz could offer an alternative and potentially even better user experience than Wi-Fi as small cells would be connected directly to a mobile operator’s macro network.

[Commentary] As the debate about auction limitations and restrictions rages on, one new argument is particularly notable. The Competitive Carriers Association has for months sought low band restrictions or limits in the auction.

CCA has long argued that AT&T and Verizon have somehow foreclosed their members from access to low band spectrum (a notion that I debunked in a blog some months ago). Therefore, CCA has argued, there should be low band limits that restrict AT&T and Verizon in the 600 MHz auction while their members have free reign.

The FCC has now proposed a set of restrictions that basically gives CCA exactly what it has demanded -- it is proposing to restrict a carrier’s participation in the 600 MHz auction based on the amount of low band spectrum it holds in its portfolio.

One would think CCA would be cheering from the stands, but they are not. Why? Because the FCC’s proposal has finally forced CCA to acknowledge that there are “multiple examples” “throughout the country” of incidences where their members already have a significant portfolio of low band spectrum. Those members would therefore be restricted under the FCC’s current proposal.

AT&T announced a major initiative to expand its ultra-fast fiber network to up to 100 candidate cities and municipalities nationwide, including 21 new major metropolitan areas.

The fiber network will deliver AT&T U-verse with GigaPowerSM service, which can deliver broadband speeds up to 1 Gigabit per second and AT&T’s most advanced TV services, to consumers and businesses. AT&T will work with local leaders in these markets to discuss ways to bring the service to their communities.

Similar to previously announced metro area selections in Austin and Dallas and advanced discussions in Raleigh-Durham and Winston-Salem, communities that have suitable network facilities, and show the strongest investment cases based on anticipated demand and the most receptive policies will influence these future selections and coverage maps within selected areas.

This initiative continues AT&T’s ongoing commitment to economic development in these communities, bringing jobs, advanced technologies and infrastructure. The list of 21 candidate metropolitan areas includes: Atlanta, Augusta, Charlotte, Chicago, Cleveland, Fort Worth, Fort Lauderdale, Greensboro, Houston, Jacksonville, Kansas City, Los Angeles, Miami, Nashville, Oakland, Orlando, San Antonio, San Diego, St. Louis, San Francisco, and San Jose. With previously announced markets, AT&T now has committed to or is exploring 25 metro areas for fiber deployment.

[Commentary] The word out of the Federal Communications Commission is that we can expect a 600 MHz auction framework item in the May timeframe. This has set the auction restrictions drums beating (again).

Calls for large-carrier limitations and even strategic set asides are growing ever louder. In all the rhetoric, some fundamental facts are getting lost. So, let’s ground this debate.
Fact No. 1: It will take a lot of revenue for the incentive auction to be successful.
Fact No. 2: No one bidder can run a $30 billion table.
Fact No. 3: A set aside of any type will only exacerbate the $30 billion revenue challenge.
Fact No. 4: A low band cap will also exacerbate the $30 billion revenue challenge.
For this auction to succeed, the FCC must attract wide broadcaster participation in major markets. Period. No exceptions. And to do that, the FCC must be prepared to meet prevailing price expectations.

We are firmly convinced that scoring on any basis related to station value or revenue will undermine the very broadcaster participation that is essential to success. TV stations are selling spectrum -- not their broadcast businesses. And if broadcasters don’t show up, the question of whether the auction will raise the necessary revenue on the forward side will be moot.

When the Federal Communications Commission’s mobile spectrum holdings proceeding was initiated over a year ago, AT&T argued that the Commission’s basic spectrum aggregation test -- as originally conceived -- remained a sound approach.

The test seeks to strike a balance between regulatory certainty, by assuring licensees that spectrum accumulations within a safe harbor will be approved, and regulatory flexibility, by giving the Commission a focused tool to assess whether proposals that exceed the safe harbor screen will foreclose competition. The benefits of this balanced, consumer-focused approach have been extraordinary.

To be sure, modest steps are still needed to update the screen and restore its validity. These two steps are all that is necessary to restore the screen to its proper and intended function of addressing the potential for market foreclosure.

For one thing, the screen continues to exclude a substantial amount of spectrum that the Commission’s own reports to Congress recognize as usable for mobile wireless service and that, in fact, is being used today. Most prominently, the Commission should correct a current glaring omission by including in the screen the entire 194 MHz of BRS and EBS spectrum held almost entirely by Sprint/Clearwire, rather than the mere 55.5 MHz the Commission has included to date.

Moreover, some recent decisions have departed from longstanding precedent by no longer treating the safe harbor as “safe,” requiring divestitures even where the screen has not been exceeded.

These ad hoc departures from the Commission’s framework undermine the predictability that is critical to business planning. The Commission should make clear that its case-by-case analysis will be reserved for proposals to exceed the threshold level in any local market and that this review will be properly focused on the potential for actual foreclosure.