AT&T Statement on FCC’s
Special Access/BDS Proposal

Posted by: AT&T Blog Team on October 7, 2016 at 12:22 pm

The following may be attributed to Bob Quinn, AT&T Senior Executive Vice President of External & Legislative Affairs:

“This proposal is little more than a wealth transfer to companies that have chosen not to invest in last mile fiber infrastructure. It will result in less fiber investment and contribute to mounting job losses at a time when our country needs just the opposite.

“Like its privacy and set-top box counterparts (which may or may not also be voted upon in three weeks), the special access proceeding seems designed to pick winners and losers rather than being an even-handed analysis based on facts and sound economics.

“While the Commission has correctly determined (for the time being) not to re-regulate the Ethernet market, there is no evidence in the record to support the Commission’s proposal to re-regulate all legacy TDM-based service without regard to the number of competitors operating in a markets. To reach such a preposterous conclusion, the Commission had to ignore facts and virtually all of the economic analysis submitted by its own ‘independent’ economist as well as all of the other economists who provided analysis in this proceeding.”

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A Personal Note

Posted by: Joan Marsh on October 3, 2016 at 1:39 pm

This week, I am privileged to take over leadership of AT&T’s Federal Regulatory team in AT&T’s DC office. I take the reins from my mentor, boss and friend, Bob Quinn, as he rises to succeed Jim Cicconi, who leaves us for the next chapter of his life and a richly-deserved retirement.

This opportunity comes to me at an important inflection point for our company, our industry and our country. We are on the precipice of a Presidential election that will, in all events, herald change during a time when communications companies are increasingly scrutinized through the lens of a dated regulatory code that is more and more untethered from the realities of today’s modern networks. We have moved well beyond trying to fit a square regulatory peg into a round regulatory hole to fundamental questions about whether pegs and holes are an adequate regulatory framework at all.

While I don’t know what issues will dominate the regulatory stage next year, I plan to proceed in my new role consistent with the high standards established by Jim and Bob – to engage in honest and fact-based debate, to listen in good faith to opposing viewpoints and to seek consensus wherever it can be found. Indeed, my many years of experience in DC teaches that the best solutions are often found not in the throes of a regulatory battle, but instead through collaboration and reasoned discussions with those most impacted by regulatory shifts. It was through collaboration that we unlocked the value of the WCS band that had been mired for a decade in regulatory limbo, that we found a workable and effective framework for improving wireless 911 location accuracy and that we resolved long-standing disputes around interoperability.

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The Next Logical Step in
Intercarrier Comp Reform

Posted by: AT&T Blog Team on October 3, 2016 at 10:42 am

By Matt Nodine, AT&T Assistant Vice President of Federal Regulatory

Turning around an aircraft carrier, if done correctly, takes lead time, requires great care and precision, and depends on a large crew with a variety of skills, all working together in harmony for a common cause.

Intercarrier compensation reform (ICC) is one such ship. Wisely, the FCC began this turn in 2011 with terminating access reform, working with a broad cross-section of industry, consumer groups and policymakers to decisively steer industry away from the arbitrage and schemes of unscrupulous actors, and toward what it termed “market discipline.” With the FCC’s course set, industry charted its path toward greater competition.

Now that we are several years into the FCC’s reforms, it is time to review the state of the marketplace, assess prior reforms, identify weaknesses and address next steps. With our petition for forbearance, which we filed Friday, the FCC can begin the next phase of reform we believe will benefit consumers, increase broadband investment and improve competition.

First, some background. In the 2011 USF/ICC Transformation Order, the FCC did its work well by adopting a regulatory regime that determined that a “uniform national bill-and-keep framework” would be the “ultimate end state” for all telecommunications traffic between carriers. The FCC’s action addressed some of the worst aspects of access arbitrage on the terminating access side, including what the Commission described as “access stimulation.” These so-called “traffic pumpers,” who consistently game the system to grossly inflate providers’ costs – and consumers’ bills – by hundreds of millions of dollars annually, were finally constrained. For many carriers, terminating end office switching rates complete the bill-and-keep transition on July 1, 2017.

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AT&T Statement on FCC’s Decision to Delay Vote on Set-Top Box Proposal

Posted by: AT&T Blog Team on September 29, 2016 at 12:06 pm

The following may be attributed to Bob Quinn, AT&T Senior Vice President of Federal Regulatory:

“In light of the limited information that has been publicly disclosed, AT&T supports the call for additional review and public comment on the FCC’s modified set-top box proposal. We have always said that this complicated technology mandate is unnecessary given the rapidly expanding applications-based marketplace.  No FCC proceeding in recent years has drawn more unified opposition and bipartisan expressions of concern. Important questions remain about the scope of the FCC’s authority as well as the complex framework proposed in this item, and about the significant impact it could have on existing statutory privacy, copyright and licensing protections.  These concerns all suggest that this proposal needs to be brought from the back rooms of the FCC into the sunlight to ensure that consumers continue to receive the innovative video products the marketplace has already been delivering.”

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Failing to Pass the Straight-Face Test

Posted by: Hank Hultquist on September 13, 2016 at 1:56 pm

Yesterday, AT&T filed comments with the Office of Management and Budget on the FCC’s woefully deficient analysis of the burdens associated with the so-called enhanced transparency requirements adopted in the 2015 Open Internet Order (OIO). The Commission’s analysis evinces a complete disregard for its responsibilities under the Paperwork Reduction Act. The FCC has not specifically identified the things Internet service providers (ISPs) must do to comply with the new transparency requirements; it has not separately estimated the burden of each requirement; it has not explained the benefits that would justify these requirements; and its lowball estimate of the overall costs is absurd on its face.

By way of background, the PRA requires agencies like the FCC to minimize the burden of required data collections. The FCC must obtain approval from OMB before any such collection can take effect. In this case, the FCC has had ample time to undertake a thorough analysis of the paperwork burdens of the OIO, yet has submitted a superficial, conclusory and slipshod analysis that OMB should reject. The treatment of just one of the new requirements, disclosure of packet loss, demonstrates the inadequacy of the FCC’s analysis.

To comply with the new transparency requirements, wireless providers will have to measure something they have not been required to measure or report previously (packet loss), in geographic areas where they do not currently take any similar performance measurements and may not have previously measured, and during undefined “peak hour” time periods. For AT&T, compliance with this requirement would cost far more than the FCC is estimating. Indeed, it could very well cost AT&T alone more than what the FCC has estimated for the entire industry to comply with all of the FCC’s transparency requirements because it could require extensive additional drive testing at a cost of many millions of dollars each year. Yet the FCC has estimated that the burden to the entire industry of all its transparency requirements, included those adopted in 2010, is only $640,000.

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