Supporting Innovation
In Unlicensed Bands

Posted by: AT&T Blog Team on October 1, 2015 at 3:00 pm

By Stacey Black, AT&T AVP-Federal Regulatory

AT&T recently joined a coalition of high tech companies and wireless operators designed to help educate consumers and policymakers about the benefits of using unlicensed spectrum to enhance speed, service quality and coverage for consumers.  Two new unlicensed technologies – LTE-U and LTE-LAA – are being developed to harness the availability of unlicensed spectrum to complement LTE technologies deployed in licensed bands in ways that will directly benefit U.S. wireless customers.

Recent claims, however, have been made suggesting that these new technologies will cause interference with and could ultimately undermine the Wi-Fi networks that are currently broadly deployed in homes, offices and public spaces around the country.  Some have even argued that wireless companies that rely on licensed bands shouldn’t have access to unlicensed spectrum at all, particularly in the 5 GHz band.

Such arguments are contrary to public policy and the law, and fly in the face of the long history of innovation and permission-less use of unlicensed bands.

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Competition, Competition, Competition

Posted by: AT&T Blog Team on September 29, 2015 at 2:41 pm

By Caroline Van Wie, AT&T AVP-Federal Regulatory

“Competition, competition, competition” has been FCC Chairman Tom Wheeler’s rallying cry. Under his watch, the Commission’s approach has been, “When competition is high, regulation can be low.” He has stressed that, “[i]f the facts and data determine that a market is competitive, the need for FCC intervention decreases. I have zero interest in imposing new regulations on a competitive market just because we can.”

As the Commission embarks on its review of the Special Access marketplace, it must take these words to heart and avoid imposing harmful and unnecessary regulation on this highly competitive telecom sector.

The facts on the ground show that the dedicated services marketplace (both for TDM-based special access services and for IP-based dedicated services) is competitive and thriving. Competition from cable is both real and rapidly increasing. Traditional competitors are making significant investments in their networks to deploy fiber to customer premises.

Cable is actively pursuing the dedicated services market. Comcast just announced the formation of a unit that will sell business Internet and phone services to “Fortune 1000 businesses across the country” by employing wholesale purchase agreements with other cable companies to provide service even outside of its footprint. With this venture, it hopes to “steal away more customers from telecom providers like AT&T Inc. and Verizon Communications Inc.” This move is not unexpected. Cable has been targeting the enterprise market, particularly for small- and mid-sized businesses, for years – i.e. Comcast, Time Warner Cable (TWC), and Cox.

And, it would be a mistake to assume that cable only offers best-efforts services. Comcast, for example, touts its Dedicated Internet Access service as a “cost effective and flexible” alternative to DS1 circuits. Check out TWC’s DIA as well as Cox’s DIA.

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The FCC’s Enhanced
Transaction Review Standard

Posted by: Joan Marsh on September 15, 2015 at 11:49 am

Over a year ago, AT&T filed an application seeking to acquire two Lower 700 MHz B Block licenses from Club 42 CM Limited Partnership. AT&T’s ownership of 700 MHz B Block licenses is wholly uncontroversial – we purchased many in the 700 MHz auction and have been enhancing our B block footprint through small deals for some time.

As with the other B block deals before it, there is no real argument against the merits of this acquisition. The transaction involves bare spectrum that will provide AT&T with a sufficient position to support a 10 x 10 MHz LTE deployment in 700 MHz in the relevant markets. A contiguous 10 x 10 MHz configuration is more spectrally efficient and has a greater throughput than a 5 x 5 MHz deployment. The more robust LTE network made possible by this transaction will improve spectral efficiency, increase network capacity and enable us to offer faster, higher quality services to our customers. For these reasons, the Commission has repeatedly found that transactions that enable 10 x 10 MHz LTE deployments serve the public interest and has approved them.

Yet, and without offering any cogent argument or justification, CCA and T-Mobile have opposed the deal, arguing that the Commission should simply prohibit any incremental low-band spectrum aggregation by AT&T and Verizon. Period. They essentially assert that low band spectrum transactions should be deemed presumptively unlawful for any company named AT&T or Verizon.

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The British are Coming (and This Time They Want Pricing Regulation)

Posted by: Bob Quinn on September 10, 2015 at 8:10 am

The Financial Times (FT) ran a story recently highlighting British Telecom’s efforts to get the Federal Communications Commission (FCC) to re-establish stricter rate regulation over special access services sold to business customers.   The essence of BT’s position was that BT was paying more for special access service than anywhere else in the western world and getting poor performance to boot, therefore the United States should re-establish strict rate regulation like that adopted in other countries, particularly the UK.   In filings in the US, BT and others have argued for the US to abandon the bi-partisan policies adopted in the late 1990s and early 2000s  to promote investment in fiber and other technologies necessary to provide fast Internet services in the US.

By all accounts, those were wildly successful policies, stimulating massive broadband infrastructure investment in the United States, where, even today, fiber expansion is exploding – AT&T itself committed to build 12.5 million new fiber-to-the-home connections as part of the recent DIRECTV merger.  Conversely, other parts of the world, including the UK, have been left to figure out how to change their regulatory environments to promote a similar level of broadband infrastructure investment.

Where’s the Investment?

Before getting to BT’s claims that it pays more for special access services here in the U.S. than elsewhere and for poorer service, let’s first discuss the most important thing that BT did not even mention in the FT article….And, that’s investment in infrastructure.

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Getting the Incentive Auction Right

Posted by: Joan Marsh on August 6, 2015 at 1:32 pm

Today, the FCC cast a series of votes that set the stage for the incentive auction to move toward its slated March 2016 start.  The results of the votes, however, are a mixed bag and leave significant wireless industry concerns unanswered.

On the one hand, the FCC has finally resolved the protracted debate on the reserve and its triggers, putting to rest at last T-Mobile’s never-ending quest to expand the favors it will receive at auction. That decision was long over-due and essential to moving the process forward, and the Commission was right to reject T-Mobile’s demands.

On the other hand, some of the auction framework proposals adopted today raise significant questions about the value and utility of the spectrum that will be made available at auction.

First, the FCC has reserved for itself significant flexibility to affirmatively create impairments in the new wireless allocations by assigning broadcasters in-band.  In the past, FCC band plans have failed to properly account for existing interference concerns (think 700 MHz), but never in the history of FCC auctions has the Commission chosen to affirmatively create long-lasting and debilitating in-band impairments.  This not only repeats the sins of the 700 MHz band – which remains under-deployed to this day – it doubles down on them. 

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