The White Space Black Hole

Posted by: Joan Marsh on April 2, 2015 at 12:09 pm

In 2008, in the wake of the 700 MHz auction, Google held a conference call to reveal its plans for “Wi-Fi on steroids” – a broadband wireless service to be delivered coast to coast via unlicensed white space devices, all in time for the 2009 Christmas holiday.  I remember reading a blog comment around that time mocking AT&T and Verizon for “wasting” billions of dollars on licensed spectrum in the 700 MHz auction when troves of valuable unlicensed spectrum would soon be available for free.

In 2010, the FCC adopted white space rules that white space supporters argued set the stage for the next generation of wireless technologies to emerge.  One reporter declared that “there is no stopping the white space gold rush that is about to begin.”

It’s now 2015.  The licensed 700 MHz allocations that were sold in 2008 have been the bedrock for billions of dollars of investment in wireless networks that now form the catalyst for U.S. leadership in LTE wireless technologies.  And hundreds of millions of U.S. consumers now enjoy 4G LTE wireless services as a result of those investments.

On the white spaces front, an Internet search reveals only a scattering of small scale white spaces tests and deployments, with even less information available about the scope or success of those efforts.

Perhaps the most insightful evidence of white space activity comes from an emergency petition on the White Space Database recently filed by the National Association of Broadcasters (NAB).  From this petition we learn two critical facts.  First, after five years of effort, there are fewer than 1,000 devices registered in the database.  Apparently the gold rush was not even a trickle.

Read More

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.

Read More

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.

Read More

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.”

Read More

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.”

Read More