Facts not Fiat

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Today, AT&T filed its response to a July 27 Notice of Apparent Liability (NAL) issued by the FCC for alleged violations of the lowest corresponding price (LCP) requirements of the E-rate program.  These rules say that in order to participate in the E-rate program, a carrier must charge a participating school, library or consortium no…

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A Return to Permission-Less Innovation

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

The latest chapter of the Wi-Fi vs. LTE-U saga unfolded this month as the Wi-Fi Alliance (WFA) announced that, after many months, it was finally closing in on an approved LTE-U coexistence test plan but surprised everyone by suggesting that the test plan should also include LTE-LAA. To understand why this is so aggravating, we…

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Reaching a Sound 3.5 GHz Framework

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

We’ve been watching with interest as a Further Order on the 3.5 GHz band plan is being considered by the FCC’s 8th floor. The Order proposes to preserve a Priority Access License, or PALs, scheme that has been broadly rejected by almost everyone who had advocated for the PALs approach. Given this opposition, it’s hard…

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A Note from Base Camp

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Last week while speaking at a spectrum conference, Gary Epstein, Chair of the FCC’s Incentive Auction Task Force observed that progress on the incentive auction can be compared to climbing a mountain. With the rules complete and as we move toward the auction start date, the collective group of auction climbers are essentially now at…

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Another Magenta Herring

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

A few weeks ago, T-Mobile filed an ex parte suggesting that AT&T had contradicted statements made to the FCC in connection with the acquisition of certain 700 MHz licenses in a few rural markets in Kentucky, Ohio and West Virginia.  As we explain in a filing today, T-Mobile’s claims are flatly incorrect. AT&T is continuing…

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The Wi-Fi / LTE Unlicensed Debate: A Path Forward

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Much ink has been spilled to date on the question of whether and how, and under what conditions, Wi-Fi and LTE unlicensed technologies can peacefully co-exist in existing and new unlicensed bands.  I don’t propose to add to that growing body of literature.  I write instead to endorse a path forward: One that side-steps the…

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When is a Defaulter Not Really a Defaulter? And Other Auction 97 Questions

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Last week, the latest chapter of the saga that is Auction 97 unfolded in all its messy, unpredicted and unpredictable glory – Dish and its affiliate DEs surrendered over $3 billion of AWS-3 licenses back to the FCC.  Before we get to the selective default, let’s quickly review the bidding to date. First, Dish took…

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The FCC’s Enhanced Transaction Review Standard

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

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…

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Getting the Incentive Auction Right

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

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…

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Stop the Magenta Madness: A Word on the Spectrum Reserve

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

We don’t have a slick cartoon full of super heroes and telecom villains.  We aren’t generating a raft of identically-worded robo-letters.  And we aren’t tweeting apocalyptic rants about the demise of wireless choice.  But we do care about the 600 MHz spectrum auction – a lot – and we support the Chairman’s decision to deny…

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