The Roaming Marketplace is Working

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

T-Mobile, which advertises itself as the “un-carrier,” has asked the FCC to “un-do” its data roaming rules, which were established in 2011 to facilitate reasonable data roaming arrangements while continuing to incent network investments.  T-Mobile now asks for a “declaratory ruling” which would effectively eviscerate that FCC decision and run afoul of the D.C. Circuit…

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‘911’ Location Accuracy: Getting to Dispatchable Addresses

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

TruePosition recently commissioned and produced a test report purporting to show that its proprietary technology can meet the FCC’s proposed benchmarks for locating wireless 911 callers horizontally and vertically indoors.  The tests were run on a test bed in Wilmington, Delaware outside the context of the established CSRIC process specifically designed to assess new “911”…

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Illuminating the Possibilities

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

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…

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More on the Low Band Spectrum Debate

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

As the debate about auction limitations and restrictions rages on, one new argument is particularly notable. CCA has for months sought low band restrictions or limits in the auction. CCA has long argued that AT&T and Verizon have somehow foreclosed their members from access to low band spectrum (a notion that I debunked in a blog some…

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More on Auction Limits

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

The word out of the FCC is that we can expect a 600 MHz auction framework item in the May timeframe.  This has set the auction restrictions drums beating (again).  Calls for large-carrier limitations and even strategic set asides are growing ever louder. In all the rhetoric, some fundamental facts are getting lost.  So, let’s ground…

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Right on in AWS-3

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

A draft order for the AWS-3 auction is circulating for a vote at the FCC, and while I have not seen the item, early reports of its recommendations suggest to me that the Commission staff has got this one exactly right. Why? The item proposes a band plan that includes two 10 x 2 MHz…

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Establishing Effective Spectrum Policy – Part III

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

When the Commission’s mobile spectrum holdings proceeding was initiated over a year ago, AT&T argued that the Commission’s basic spectrum aggregation test – as originally conceived – remained a sound approach. The test seeks to strike a balance between regulatory certainty, by assuring licensees that spectrum accumulations within a safe harbor will be approved, and regulatory…

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Facts About Low Band Spectrum Holdings

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

In an op ed last week, CCA again called for auction limits to “prevent the two dominant wireless carriers from blocking competitors’ access to low-frequency spectrum.”  The problem, according to CCA, is that AT&T and Verizon control a significant portfolio of low band spectrum.  CCA also alleges we were “handed” our 850 MHz allocations “free…

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An Interesting Auction Down Under

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Last week, T-Mobile, through its outside counsel, submitted into the incentive auction proceeding information about auction rules recently adopted in New Zealand.  Specifically, in connection with its 700 MHz auction that will offer 90 MHz of paired spectrum in nine 5 x 2 MHz blocks, the New Zealand Ministry for Communications and Information Technology ruled…

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Why T-Mobile’s “Dynamic Market Rule” Won’t Work

by Joan Marsh

Executive Vice President of Regulatory & State External Affairs

Today, AT&T is filing an analysis by two esteemed economists, Yeon-Koo Che and Philip A. Haile, of T-Mobile’s “Dynamic Market Rule” proposal for the 600 MHz Auction.    The proposal entails a complex bidding scheme that is premised on T-Mobile’s claim that low band spectrum should be subject to its own separate cap, above and beyond…

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