Time for Special Access

Posted by: Frank Simone on March 23, 2015 at 3:06 pm

Net neutrality clearly dominated the Congressional hearings last week.  But it wasn’t the only issue FCC Commissioners were asked about, and it’s also not the only issue that remains in limbo after nearly a decade.  Late last month marked the filing deadline for responses to the latest chapter in the FCC’s special access proceeding – its mandatory data request. For the past 10 years, the Commission has been looking into the competitiveness of the special access marketplace and this latest data request is meant to give the FCC what it needs to conclude this proceeding.  After ten years, it can certainly be said that a lot of time and money has been spent in pursuit of figuring out whether the marketplace for 1.5 Mbps services (which did not meet the FCC’s definition for broadband services before the Commission upped those speeds to 25 Mbps last month btw) is truly in need of further regulation.  This latest request for data was by far the most time consuming and expensive given the sheer number of hours the industry, and AT&T in particular, exhausted to collect and submit the enormous volume of information requested as part of the Commission’s quest for special access nirvana.

To be clear, AT&T supports the notion that the Commission should actually have data before it takes action (unlike the non-data driven decision in 2012 to suspend the pricing flexibility rules in advance of going on this particular expedition).  The network data collected here no doubt will show that, where special access demand is concentrated, there exists an abundance of competitive alternatives to the incumbent provider.  And while the volume of nationwide facilities data collected will be sizable due to the highly competitive market for special access services, the information provided likely can be analyzed in a reasonable period of time.

But as AT&T has outlined in the record of this proceeding, the same cannot be said for the data collection requests concerning monthly pricing information at the circuit and rate element level that the Commission intends to use as the basis for analyzing existing special access prices.  Anyone familiar with telecom billing systems understands just how difficult this task can be, especially when the request involves tens of millions of circuits deployed nationwide across multiple holding companies with multiple similar, but not the same, billing systems.  As well as the numerous affiliated companies, each with their own unique billing systems.  The inevitable inconsistencies in the data among the range of providers, competitive and incumbent, submitting pricing data will make any effort by the Commission to rationalize this data at the circuit level extremely difficult, if not impractical.

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The Devil is in the Details

Posted by: Joan Marsh on March 16, 2015 at 1:54 pm

On Friday, we filed reply comments on the FCC’s proposed procedures for the 600 MHz incentive auction.  This public notice (PN) gets down to the nuts and bolts of how the auction will be run and, in many ways, the decisions made here will be some of the most important to date.

When the FCC initiated the incentive auction proceeding, it identified some core principles that would guide the proceeding.  First, to maximize participation, it sought to make the auction process as transparent and easy-to-understand as possible.  Second, it committed to a focus on engineering and economics.  Finally, although recognizing the complexity of the task at hand, there was a strong commitment to simplicity and fungibility.

In many ways, the proposals in the most recent PN stray far from that core mission.  The proposals currently on the table introduce interference into the proposed band plan where it need not exist, they contemplate a level of market variability that will be difficult and inefficient to implement, they unfairly foist impairments on the bidders facing the biggest auction restrictions, they tip the auction too far in favor of reserve-eligible bidders and they create significant opportunities for gaming.

As we explained in our opening comments and further on reply, the proposals, if not adjusted, will unnecessarily complicate the auction, devalue the spectrum being reallocated for auction, suppress auction revenues and reduce the quantity of spectrum ultimately cleared.  The proposals also raise the specter of a post-auction band plan fraught with interference that will burden the wireless industry indefinitely.

Outlined below are just a few of the issues that AT&T believes need to be addressed to return to the core goals of transparency, simplicity, fungibility and sound engineering.

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AT&T Statement on Release
Of FCC’s Net Neutrality Order

Posted by: AT&T Blog Team on March 12, 2015 at 10:18 am

The following statement may be attributed to AT&T Senior Executive Vice President-External and Legislative Affairs Jim Cicconi:

“Unfortunately, the order released today begins a period of uncertainty that will damage broadband investment in the United States. Ultimately, though, we are confident the issue will be resolved by bipartisan action by Congress or a future FCC, or by the courts.”

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AT&T Statement on
Netflix CFO Remarks

Posted by: AT&T Blog Team on March 4, 2015 at 8:03 pm

The following statement may be attributed to Jim Cicconi, AT&T Senior Executive Vice President of External and Legislative Affairs:

“Netflix has spun a lot of tales during this FCC proceeding.  But it’s awfully hard to believe their CFO would go into a major investor conference and misspeak on an issue supposedly so crucial to their future.  More likely he had an attack of candor.  At least ’til his company’s lobbyists got hold of him.  I’m sure they’ll also have some terrific spin to explain Netflix’s data cap deal in Australia.”

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Auction 97 – More Lessons
For Future Auctions

Posted by: Joan Marsh on March 4, 2015 at 1:36 pm

Additional reactions to Auction 97 are emerging with everyone putting their own spin on the results.

First, in a blog, T-Mobile offered its view, calling the auction a disaster for U.S. consumers.  Hard to figure how they can reach that result.  The auction reallocated 50 MHz of valuable paired spectrum to the wireless industry – an allocation that T-Mobile itself has long advocated for.  The spectrum is internationally harmonized and is already being standardized so it can be efficiently deployed to bring substantial additional data capacity to U.S. wireless consumers.  And the auction proceeds will fully fund FirstNet, so the country will finally realize the promise of an interoperable public safety broadband network.  These are all wins for the FCC, the wireless industry and the American public.

The Public Interest Spectrum Coalition also offered its own lessons, oddly casting the Dish entities as victims of the “continued dominance” of other bidders. But to believe them, you have to ignore the fact that the Dish entities won more licenses than any other bidder in the auction and have laid claim to a $3B subsidy from American taxpayers to boot.

Any serious analysis of the auction must be based on the facts of what actually happened in the auction – not fiction and not bluster about “twin bell” monopolies.  Consider this an addendum to my last blog, with more lessons from the auction.

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