Illuminating the Possibilities

Posted by: Joan Marsh on June 18, 2014 at 10:32 am

Yesterday, in the FCC’s Incentive Auction proceeding, AT&T filed a computational study that seeks to provide insights into some fundamental and essential auction questions – namely, for any given clearing target, what might a successful auction look like in terms of how many broadcasters must participate and in what markets?  And, how much diversity is there in the solution sets necessary for a successful outcome and, how are adjacent markets correlated?

As important and interesting as these questions are, to date scant analysis on these questions has been offered.  The research submitted today, authored by Michael Kearns and Lili Dworkin of the University of Pennsylvania, will help address that void.

The study attempts to ask and answer a series of straight-forward mathematical questions like:  how many broadcasters need to participate in the New York City designated market area (DMA) to clear 84 MHz of spectrum?  How do those numbers change if you take the FCC’s published domain constraints into consideration?  If you assume an 84 MHz clearing target, how many markets, on average, will require some level of broadcaster participation?

Given the complexity of the auction, the answers are rarely black and white.  For any clearing target, there are almost unlimited variations on possible broadcaster participation and a very large number of possible repacking solutions.  But from the research, an outline of the scope of the possible begins to emerge.

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Net Neutrality and Modern Memory

Posted by: Jim Cicconi on June 6, 2014 at 10:15 am

I saw last month’s House Commerce hearing with Chairman Wheeler and was struck once again by the animated discussion revolving around “paid prioritization,” “fast lanes/slow lanes,” and Section 706 authority versus Title II regulation.  The debate feels a bit like the movie Groundhog Day… we’ve all been here before.  And just as in 2010, there doesn’t seem to be a common understanding of “paid prioritization,” the FCC’s 706 authority, or the scope of Title II regulation.

So, if you don’t mind, I’d like to cut through some of the current debate by starting with the common understandings we all reached in 2010 after years of argument.  Let’s begin with “paid prioritization.”  According to Free Press, there were three troubling “discriminatory business models” that could create fast lanes and slow lanes on the Internet:

• “Pay-for-Play” – where an ISP might refuse to carry content unless the content company pays them “additional fees above normal transit costs.”
• “Pay-for-Priority” – where edge providers might pay ISPs for prioritizing traffic on the consumer’s broadband Internet access service.
• “Vertical Prioritization” – where an ISP might prioritize its own vertical content and services on the user’s broadband Internet access service.

In 2010, many of us noted that the net neutrality debate revolved around unlikely hypotheticals, not any actual, pending or contemplated actions.  Mind you, not a single ISP then or now has asserted a desire or right to engage in any of these practices to create “fast lanes and slow lanes.”  AT&T certainly has no plans or intent to change its position on this.

Once we were able to ground the net neutrality debate in facts and a common understanding of the problem we were trying to solve, the result was the 2010 FCC Order, which created rules the Commission asserted would virtually ban such services.  AT&T, and nearly every other ISP, supported those rules.  In addition, pursuant to a transparency rule — which was affirmed by the Verizon court — every ISP posted on their websites Statements of Broadband Practices demonstrating their compliance with the FCC rules (ours can be found here).  Pursuant to the Verizon opinion, the FCC can enforce those statements and require ISPs to perform their network management consistent with them.   More recently, as part of pending mergers, Comcast, Time Warner Cable and AT&T reinforced those commitments by promising to continue operating our networks consistent with the 2010 Rules and our current Statements of Broadband Practices, which, again, the FCC can require us to follow.

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Spectrum Sharing:
Let’s Walk Before Running

Posted by: AT&T Blog Team on May 22, 2014 at 3:16 pm

By Stacey Black, AT&T Assistant Vice President of Federal Regulatory

The FCC 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.

The FCC’s proposal is a complex model where federal incumbents would share their radio spectrum (which they use primarily for ship-borne radar) with two non-federal user categories; the first being a licensed category called “Priority Access Licensees” (“PAL”) that will obtain licenses to spectrum in geographic areas and the second called “General Authorized Access” (“GAA”) which is similar to unlicensed operations.  The three groups will operate in a prioritized hierarchy where the incumbent federal users have the highest priority, the PAL the next highest and the GAA users after that. In order to have all three groups coexist without interference, a database, or what the FCC calls a “Spectrum Access System” or “SAS” will need to be developed and implemented. The SAS will include a registry of all nodes and/or devices in the band, and will know their geo-operational status at all times, and can therefore theoretically enforce the band’s use and prevent unintentional interference.

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 WiFi networks where available. But a licensed spectrum band such as 3.5 GHz could offer an alternative and potentially even better user experience than WiFi as small cells would be connected directly to a mobile operator’s macro network.

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AT&T Statement on FCC’s Spectrum Aggregation and Auction Eligibility Order

Posted by: AT&T Blog Team on May 15, 2014 at 2:46 pm

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

“AT&T has long argued that the FCC should adopt a spectrum aggregation and incentive auction framework that will encourage all carriers to participate vigorously in the upcoming auctions.  We specifically supported broad participation in the incentive auction, as contributions from the entire industry will be necessary to make the auction a success.  And we believed that the right framework would allow the Commission to send a clear message to broadcasters that they should bring as much spectrum as possible to the auction as there will be sufficient revenue to pay for their contributed licenses.

“Today, the Commission adopted rules and an auction framework that puts the auction on the path toward success.  While many important issues remain to be resolved, we believe that the spectrum aggregation and auction rules adopted today represent a significant step forward and will demonstrate to broadcasters that the incentive auction can and will attract significant carrier interest and demand.  And while we have long opposed auction restrictions and set asides, the compromise framework will give AT&T a fair shot to participate at auction for a meaningful 600 MHz footprint.  For these reasons, we support the auction framework.

“The steps taken by the FCC today are substantial.

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AT&T Statement on FCC’s Proposed Open Internet Rulemaking

Posted by: AT&T Blog Team on May 15, 2014 at 2:38 pm


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

“AT&T is committed to an Open Internet.  We supported the Commission’s 2005 Open Internet Policy Statement, as well as the Commission’s 2010 Open Internet Rules which codified that policy.  Our network management practices are designed to comply with those rules.  Those practices are described on our website today, in accordance with FCC rules that were not vacated by the DC Circuit, and are still today fully enforceable by the FCC.  In short, broadband customers throughout the United States have access to AT&T’s open broadband networks which comply fully with Open Internet principles that have been in place for almost a decade.

“The framework adopted by the Commission in 2010 achieved a delicate balance that ensures openness, while maintaining a stable environment for investment.  As a result, infrastructure providers have invested hundreds of billions of dollars to provide American consumers with the most robust wireline and wireless broadband networks in the world.

“This debate has been falsely labeled as a debate over fast lanes and slow lanes.  It is not about that at all.  This debate is over whether we will continue to foster an investment environment that has allowed US companies to build the world’s best networks so that all consumers can have the fastest Internet lanes in the world.

“Going backwards 80 years to the world of utility regulation would represent a tragic step in the wrong direction. Utility regulation would strangle investment, hobble innovation, and put government regulators in charge of nearly every aspect of Internet-based services. It would deprive America of the world’s most robust broadband infrastructure, and place a cloud over every application or website that delivers products and content to consumers.  In short, it would place government in control of the Internet at the expense of private companies, inventors and entrepreneurs, and ultimately at the expense of the American people.

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