Unlocking the Potential
Of AWS-3 Spectrum

Posted by: Joan Marsh on September 2, 2010 at 2:53 pm

Yesterday, Chairman Genachowski removed from circulation the AWS-3 draft item, ending a long and largely frustrating debate about disposition of the AWS-3 spectrum at 2155-2180 MHz.  A mountain of paper was amassed over the question of whether the spectrum should be auctioned subject to a unique set of restrictions that would have limited the use of the spectrum to a single specialized business plan proffered by M2Z.  The FCC concluded, rightfully, that M2Z’s plan “was not the best policy outcome.”  We agree, and fully support the Chairman’s decision and his continuing leadership on effective spectrum policy for the 21st century.

AT&T has long opposed the M2Z proposal at the heart of the debate, which was built on a complicated set of restrictions that would require 25% of the licensee’s “network capacity” be used to offer “free, family-friendly broadband service.”  A myriad of questions arose around how the free service would be provisioned and supported, whether the quality of the free service would be acceptable and how the licensee would demonstrate compliance with the network capacity requirements.  The top downlink speed of the free service would have been 768K, and many worried that such a service would chase other providers of affordable, low-speed broadband services from the market, relegating an entire class of users to a technological backwater.

To make matters worse, in support of its business plan, M2Z proposed service and technical rules that would allow this unpaired band to be used for the delivery of two-way broadband services using time division duplexing or “TDD” technologies.  This proposal – which would allow the licensee to combine uplink and downlink operations in a single band – created the very real potential for harmful interference in adjacent AWS-1 bands.  M2Z specifically opposed restrictions on out-of-band emissions and power limits that would have guarded against this interference, arguing that those restrictions would degrade the service.  M2Z also opposed the use of appropriate guard bands – which have long been used quite effectively to address interference problems – calling instead for “cooperation and coordination requirements” to address the issue. 

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Narrowing the Debate
On Paid Prioritization

Posted by: Hank Hultquist on September 2, 2010 at 12:37 pm

As discussed in my last blog, for many years proponents of extreme versions of net neutrality regulation have fulminated against the practice of “paid prioritization.” In a recent series of letters, Free Press argued that the Commission should in no circumstances permit ISPs to be compensated for the provision of “router-based prioritization,” and that such prioritization is not taking place today.

At the time, Free Press was responding to a letter filed by the Minority Media and Telecom Council that urged the Commission not to adopt a blanket ban on payment for prioritization. According to MMTC:

“Today, when [businesses] sign up for Internet access service, many of these businesses also enter into voluntary arrangements with their broadband providers for the provision of enhanced quality of service capabilities as part of their Internet access service as well as other specialized offerings. These agreements allow [businesses] to identify a portion of their traffic as requiring better than “best effort” handling. This capability allows these businesses to ensure that the performance sensitive applications that they wish to run, such as VoIP or IP-based video conferencing, receive the service quality needed to function properly.”

Free Press responded at the time by insisting that such compensation arrangements were inconceivable under the IETF documentation for Differentiated Services (DiffServ).

Yesterday, the New America Foundation’s Open Technology Initiative (OTI) basically endorsed the practice described by MMTC. According to OTI: “[t]he intended purpose of DiffServ is user-driven differentiation of traffic.” It would seem that Free Press owes MMTC a clarification.

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My New Phone Just Arrived…By Boat?

Posted by: AT&T Blog Team on September 1, 2010 at 2:03 pm

Authored by Joseph Marx, AT&T Assistant Vice President of Federal Regulatory

The U.S. Department of Transportation earlier this year proposed a new set of rules toughening the air shipping requirements on lithium ion batteries and devices containing these batteries.  The rationale behind this proposal focuses on a concern that these batteries could overheat or catch fire.

Every year, billions of lithium batteries are shipped via air and yet the Transportation Department has not pointed to one incident when a lithium ion battery, or a product containing such a battery, overheated or caught fire when shipped according to existing domestic and international guidelines.  Everyone agrees that safety is non-negotiable.  If the U.S. does anything, it should harmonize its existing rules with the more stringent international recommendations and enforce these regulations, not put new rules in place that would disadvantage U.S. consumers for no net benefit.

The side story that no one has focused on is what happens if the U.S. deviates from the international standard and imposes different and more burdensome rules than other countries. These new requirements could fundamentally change how every U.S. consumer electronics business, including the wireless industry, does business.  The U.S. has traditionally been the first to get every new wireless gadget that comes off the assembly line.  Well, not anymore.  If the new rules are put in place it could limit delivery of devices containing lithium ion batteries to transport methods or delivery locations other than those used with air delivery.

Can you imagine waiting three months to get delivery of new handsets from overseas while they are being delivered by boat?  It will be a great Christmas, in March.  How about waiting an additional week for a replacement for your wireless phone when it breaks?  Consumers have come to expect the quick turnaround that overnight delivery allows when it comes to replacing their broken wireless devices. 

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The Danger of Dogma

Posted by: Hank Hultquist on August 31, 2010 at 11:22 am

One of the central dogmas of the Church of Extreme Net Neutrality (CoENN) is that quality of service on the Internet, or using the preferred nomenclature of the CoENN, “paid prioritization,” is the equivalent of a deadly sin.

The CoENN creed against quality of service states that paid prioritization of Internet traffic: (1) has never been contemplated by standards organizations like the Internet Engineering Task Force (IETF); (2) does not exist on the Internet today and, to the extent it exists anywhere, is probably being used nefariously by the pagans; and (3) if it did exist on the Internet, it would be available to and affordable for only a small number of deep-pocketed hegemons.

These iniquities of paid prioritization are spelled out in a recent filing at the FCC in which Free Press preaches the old time religion of the dumb network.  But, like so many dogmas, this one turns out to be, well, not exactly true.

Which leads me to the letter we filed yesterday in the FCC’s Open Internet proceeding to correct the record with respect to paid prioritization.  In a nutshell, we point out that, contrary to the CoENN’s claims: (1) the IETF documents clearly contemplate and permit differentiated pricing of Internet traffic based on the use of prioritization; (2) paid prioritization of Internet traffic is widely available to businesses today; and (3) such prioritization is often voluntarily purchased by small and medium-sized enterprises, including minority-owned businesses and community organizations. 

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Gateway to the Future of Video

Posted by: Chris Boyer on August 30, 2010 at 10:32 am

Earlier this year, I wrote about AT&T’s plans to enable AT&T U-verse TV subscribers to use their Xbox 360 (and, potentially further down the road, Windows 7 PCs) as a U-verse set-top box (STB).  I also talked about how those plans had the potential to be responsive to FCC Chairman Genachowski’s call for more innovation in the video device marketplace, which in turn could increase broadband adoption.

In April, the FCC initiated a proceeding to review whether or not video providers, such as AT&T, should be required to install a gateway device in subscribers’ homes that would enable third party retail devices to access video services over the home network without the need for a STB on each TV.  We recently filed reply comments in this proceeding.

AT&T has long emphasized that it is not interested in serving as the exclusive provider of equipment for our U-verse TV service.  To the contrary, our goal is to maximize the inherent flexibility of offering a 100% IPTV-based service that provides cutting-edge content and applications over a broad range of devices and across multiple screens.

We have engaged in a series of discussions with the Consumer Electronics Association (CEA), spearheading the development of IPTV interoperability principles and co-chairing CEA’s IPTV Oversight and Coordination Committee.  This group included IPTV, cable and content providers, satellite operators, and consumer electronic companies, and was tasked with ensuring the development of interoperability standards for IPTV.

These efforts culminated in a proposal for a “carrier gateway device” similar to what the FCC has proposed.  However, to the extent that this model has foundered to date it has been because of an impasse over the extent to which a CE device would replicate the user interface or “look and feel” of the video service. 

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