NAB’s Incentive Auction Lawsuit – A Detour not a Road Block

Posted by: Joan Marsh on August 21, 2014 at 9:38 am

Earlier this week, NAB filed suit in Federal Court challenging aspects of the Commission’s May Incentive Auction Order.  NAB’s lawsuit was not a surprise – NAB had made pretty clear that it was unhappy with how the Commission was proposing to implement elements of the Spectrum Act, particularly as related to statutory protections provided to broadcasters subject to repacking.  NAB lobbied hard in the legislative process for protections on repacking so it is also not a surprise that it is continuing to vigorously pursue these issues on behalf of its members.

While the issues raised by NAB are significant and deserve careful consideration, we do not think this lawsuit will become a road block to further progress on the auction.  An incentive auction, by definition, requires the FCC to bring together competing interests and strike a delicate balance between protecting incumbent rights and freeing up new spectrum allocations sufficient to attract bidder interest.  This exercise raises complexities never before seen in an FCC auction and it is inevitable that there will be differences of opinion and occasional detours of process as we move forward.

NAB has now stated its case in a Petition that was filed on the first day of the appellate period and has sought expedited review.  Even more significantly, NAB indicated in a blog  that it was looking for a “mid-course correction” that addresses its concerns, surely a signal that NAB is willing to consider a reasonable compromise.

Compromise must continue to be the hallmark of the incentive auction proceeding.  We have to date seen a healthy and productive amount of give and take between the FCC and industry on a range of auction issues, from the band plan to the auction framework to bidding restrictions.  And we believe that the issues raised by NAB can similarly be resolved — and resolved quickly — in a manner that protects broadcasters consistent with the dictates of the statute while achieving the auction efficiencies that the FCC wants and needs to conduct a successful auction.   

 

 

 

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TOPICS: FCC, Spectrum
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TechGirls: My Day with the Next Generation of Innovators

Posted by: AT&T Blog Team on August 14, 2014 at 4:16 pm

The following may be attributed to Amy Alvarez, AT&T Executive Director of International External Affairs:

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 D.C. for a day of job-shadowing.

It’s one of my favorite days of the year. Getting to know these students and seeing their passion for technology is always inspiring.

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 U.S. Department of State Bureau of Educational and Cultural Affairs and administered by Legacy International. Following the three week program in the U.S., the TechGirls will return home and give a presentation to their schools and communities about the experiences and what they learned, and carry out a community-based project as part of transferring those skills back to their respective communities.

This week, Aria from Lebanon and Christy of Palestine joined me for a day at the office.

 

TechGirls participate in a virtual Mobile App Creation workshop.

TechGirls participate in a virtual Mobile App Creation workshop.

AT&T relies on a highly skilled workforce and we’re working to help ensure students like Aria and Christy are exposed to STEM skills. It’s a driving factor behind our $350 million Aspire program, which is AT&T’s signature education initiative aimed to help young people graduate from high school ready for college and career success.

Learning how we can monitor our homes from our cars.

Let’s keep encouraging and empowering our young girls to be creative and curious so they can lead the next generation of innovators.

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Accelerating Broadband: DAS Good

Posted by: AT&T Blog Team on August 13, 2014 at 10:33 am

The following may be attributed to Jeanine Poltronieri, AT&T Assistant Vice President of Federal Regulatory:

We write today to support proposed FCC actions to streamline and accelerate the siting of broadband infrastructure.  These steps will help get broadband services to consumers more quickly and help carriers expand their networks, and thus their services, expeditiously with as little disruption to the surrounding community as possible.  

Just last week, the FCC approved an Order streamlining and modernizing tower lighting.  The FCC is now considering a number of additional actions, including the streamlining of deployments for small cells  and Distributed Antenna System (“DAS”) technologies.  This is one area that is particularly important since it would help provide broadband for areas that might be hard to serve because of the physical environment (like a garage) or is being blocked by other structures – real mountains or urban canyons.

Like all carriers, AT&T is deploying denser vertical networks in order to accommodate the ever-increasing demand for wireless services, especially wireless broadband services like full motion video. AT&T currently operates more than 34,000 Wi-Fi hot spots nationwide and has more than 143,000 Wi-Fi access points across the country.  More than 2.7 billion Wi-Fi connections were made on AT&T network in 2013.

AT&T is also aggressively deploying DAS to address rapidly growing network traffic at large venues and other hard to serve areas.  At the 2014 Super Bowl, AT&T customers used 624 GBs of data on our in-stadium DAS – a new high for a major sporting event.

Small cells and DAS technologies also provide benefits where macro cells (the larger towers that were the only option when cellular began) are unsuitable because of zoning or leasing challenges. 

We recently filed an ex parte, which in addition to establishing the legal basis for streamlining the environmental and historical review required for small cells systems, also provides some photos of recent small cell deployments.  AT&T tried for years to deploy a “macro” site to improve our coverage in this populated residential area.   With new technology, we were able to deploy small cells directly on light poles to provide the same coverage. 

While configurations vary, small cells can be placed on sides of buildings, on all types of utility poles and sometimes the equipment can be contained within a single small enclosure.  In many of these situations, given the use of existing structures, it’s easy to see why additional environmental or historical review is unnecessary.  In fact, PCIA – The Wireless Infrastructure Association has proposed a clear and workable volume definition that provides a bright line rule for when further environmental and historical review is not needed and where the carrier or infrastructure provider can instead take advantage of a streamlined approval process.

Importantly, streamlining the local environmental and historical review does not eliminate oversight –deployment would still need to meet the National Electrical Safety Code, and local authority is preserved because any installation must still meet other health/safety/fire codes of the locality.   And it is in a carrier’s best interest to keep small cells small – smaller, lighter equipment is generally less costly to deploy since it does not require expensive replacements of poles or other structures that would be needed to bear a heavier load.

Streamlining the process for small cell deployments is just one of the actions the FCC is considering to accelerate broadband infrastructure deployment.  The FCC’s Wireless Bureau should be commended for their work in this area, and we look forward to resolution of the proceeding so we can continue to deliver broadband to our customers as expeditiously as possible.

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TOPICS: Broadband, FCC
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AT&T Statement on FCC’s Order Regarding Antenna Structures

Posted by: AT&T Blog Team on August 8, 2014 at 12:35 pm

The following statement may be attributed to Joan Marsh, AT&T Vice President of Federal Regulatory:

“Today the Commission adopted an Order updating and modernizing the Part 17 rules governing the construction, marking and lighting of antenna structures. As carriers continue to invest billions in the deployment of wireless broadband networks, unnecessary or outdated requirements on the installation and maintenance of wireless structures can create barriers that slow deployment efforts.  The Bureau Staff, under the leadership of Chief Roger Sherman, should be commended for their recent efforts to identify outdated regulations and to streamline regulatory requirements in ways that will have a significant impact on infrastructure builds.

“Today’s action is just the first in a series of proceedings underway to reduce obstacles to the deployment of wireless facilities. Increasing certainty in the FCC’s processes and removing barriers to infrastructure deployment will accelerate network investment, which will result in broader wireless coverage and capacity for wireless consumers across the country. We look forward to continuing to work with Bureau Staff on the related proceedings.”

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TOPICS: FCC
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Text-to-911: A Work In Progress

Posted by: Bob Quinn on August 7, 2014 at 10:11 am

At the August 8th Open Meeting, the FCC  is scheduled to vote an item that purports to impose text-to-911 obligations on the US wireless carriers that have not yet voluntarily agreed to provide that service and on Over the Top or OTT text providers.  As you will recall, in late 2012, the 4 major wireless carriers agreed voluntarily to implement text-to-911 capabilities on their SMS platforms.  Because public safety obligations should be platform and technology neutral, the Commission should be applauded for seeking to make text-to-911 universally available, including to Americans with disabilities that may seek to text using an OTT texting application.  But the item currently circulating misses that mark on a number of fronts.

I would start by observing that “texting services” are in the process of undergoing a significant transformation in the underlying technology of delivering those services.  Five years ago, text message services were the sole province of the wireless companies using SMS technology to send and receive consumer texts.  With three then-teenagers living under my roof, my unlimited text plan spared me from having to try to “force” my teenagers to communicate the old fashioned way (you know, talking) when the number of texts on my bill regularly exceeded 15,000.  This month, same three kids (one is no longer a teenager), but the number of “billed SMS text messages” was under 900.  They are still sending out an equal or greater number of texts mind you (they certainly haven’t started communicating the old fashioned way). It is just that those messages are sent via IP applications rather than the SMS platform.

Which brings me to the Commission Order on text-to-911.  For starters, I want to point out that AT&T committed to provide text-to-911, as well as bounce-back messages (where text-to-911 is not available), over the existing SMS technology and has implemented that commitment this year. This new Order would extend those obligations to smaller carriers and to “Interconnected” Text Messaging Applications – roughly defined as texting applications that allow a person to text anyone with a telephone number.  The problem is that a lot of the OTT apps actually used by consumers don’t use telephone numbers but are instead “closed” applications which only allow you to communicate with others who have downloaded the app.  Moreover, even the applications that have integrated with SMS, like iMessage, only fit the definition so long as the SMS technology remains in service; once that technology is retired, those apps no longer fit the definition.  So the “Interconnected Text Provider” extension doesn’t capture some of the larger applications out there and most of the OTT apps it does capture will lose those requirements when SMS technology goes away.  The Commission has put off consideration of those issues into a Further Notice.  Given that it has some hard decisions to make in that area and seeing how this market is in throes of a dramatic evolution, more analysis is probably not a bad thing.

There are two issues created by this Order, however, that potentially impact consumers’ confidence in text-to-911 actually working.  First, I think we will still have a consumer confusion issue surrounding the “Interconnected Text Provider” definition.  While smart lawyers at the agency will know which text providers fit the definition and which don’t, I am not certain those distinctions will be obvious to the hundreds of millions of consumers downloading texting applications.  Second, as explained above, the subset of OTT text services which meet the Interconnected Text Messaging Services definition satisfy their obligation by off-loading their 911 texts to the SMS platform native in the device. But unless the OTT service is integrated, like iMessage, it’s not clear at this time how or even whether this type of off-loading can be easily accomplished. 

All evidence points to the fact that texting is migrating quickly away from SMS to IP.  The Order assures SMS providers that as that migration evolves, SMS providers are permitted to retire that technology and migrate their services in a similar fashion to IP.  Our fear though is that despite those assurances, the heavy reliance on SMS technology will ultimately hinder the ability of SMS providers to retire that technology.  We fully support the Commission’s goal of ensuring that public safety obligations – including text-to-911 obligations – are platform and technology neutral.  But the FCC has much more work to do in the area of text-to-911 to actually accomplish that goal.

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