AT&T

AT&T filed its response to a July 27 Notice of Apparent Liability (NAL) issued by the Federal Communications Commission for alleged violations of the lowest corresponding price (LCP) requirements of the E-rate program. These rules say that in order to participate in the E-rate program, a carrier must charge a participating school, library or consortium no higher than the lowest price that it charges to any similarly situated non-residential customer for similar services. To be clear, AT&T wholeheartedly supports the E-rate goals of providing schools and libraries with affordable broadband and telecommunications services. The FCC’s arguments, however, that AT&T applied the LCP rule incorrectly are factually wrong, they deviate from the FCC’s own rules and existing precedent, and they continue the FCC Enforcement Bureau’s troubling pattern of “rulemaking through enforcement.” The facts of the case aptly demonstrate that no actual FCC rules were violated.

The latest chapter of the Wi-Fi vs. LTE-U saga unfolded this month as the Wi-Fi Alliance (WFA) announced that, after many months, it was finally closing in on an approved LTE-U coexistence test plan but surprised everyone by suggesting that the test plan should also include LTE-LAA. To understand why this is so aggravating, we need to take a little trip in the not-so-way-back machine.

Let me be clear on one point – AT&T has no interest in undermining the vibrant Wi-Fi ecosystem that exists today. Well over 100 million devices connect to our network and the vast majority of those devices include a Wi-Fi client. But with LTE-LAA, the “mother-may-I” paradigm must be rejected so the wireless industry can move forward. Make no mistake, the rest of the world is not waiting for permission – Deutsche Telecom conducted the first LTE-LAA over-the-air trials last November in Germany. With LTE-LAA, the asserted objections to LTE-U have been fully addressed. Any pending or future application for equipment authorization for a LTE-LAA device that otherwise meets the Part 15 requirements should be granted in normal course. Any other result could do permanent damage to the incredibly successful Part 15 paradigm, result in the U.S. falling behind the world in the development of LTE unlicensed technologies and deny American consumers important advancements in mobile broadband.

The Federal Communications Commission has spent the last year analyzing the data submitted in the Business Data Services proceeding to understand what is driving the BDS marketplace. It has committed to a “data-driven” rulemaking process in its analysis of whether additional BDS regulation is needed. The jury is still out as to whether that will take place.

As we explain in our reply comments, the facts show that competition in the BDS market is thriving. Even as of 2013, competitors had deployed competing facilities in more than 95% of MSA census blocks with BDS demand, and those blocks contain 97% of all BDS connections and 99% of business establishments. And, according to the NPRM, ILECs’ in-region market share was already under 50%. Undoubtedly, competition is now even more pervasive, particularly given that cable companies are now prioritizing the BDS marketplace to grow their revenues in the face of more intense competition for their core video offerings.

Imagine you’re at a concert watching your favorite band, and out of the corner of your eye you notice a tethered drone hovering nearby. But this drone isn’t taking photos or videos of the band. It's temporarily providing enhanced LTE wireless coverage at the packed venue so you, along with thousands of others in attendance, can simultaneously send photos and videos to share the moment.

While this isn’t a reality yet, we expect many different drone uses in the future. This week, we reached another milestone by launching the trial phase of our national drone program. Led by Art Pregler, our national drone program is driving innovation, and focuses on how AT&T and our customers can benefit from drone-based solutions. We expect our experiences will lay the foundation for new, exciting drone applications. Possible uses include Flying COWs (Cell on Wings) providing LTE coverage at large events or even rapid disaster response. A Flying COW may even be able to provide coverage when a vehicle is unable to drive to a designated area.

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.