By AT&T Summer Interns Delaney Butler, Julian McLendon and Hilary Rosenthal

(The opinions expressed in this blog are solely those of the student authors and are not attributable to AT&T.)

As interns with AT&T’s Federal Regulatory Group, we get to work with a diverse set of issues. It is one of the benefits of working in AT&T’s D.C. office – given the size and the scope of the company, many of the issues that come before the Federal Communications Commission affect AT&T. When we discussed our respective assignments, we noticed that there was one common theme running through our workload: broadband deployment.  This comes as no surprise, given Chairman Pai’s commitment to close the digital divide.  As he has said, “[a]lmost 34 million Americans don’t have access to the broadband networks needed to fully participate in the digital economy.”

Broadband deployment spans a wide variety of issues, including wireless and wireline infrastructure deployment, license renewal, the Mobility Fund and the Connect America Fund. Each of these issues are pieces necessary to solve the puzzle of ensuring those 34 million Americans get access to broadband networks. AT&T is uniquely positioned to work with the FCC to address this problem, utilizing our expertise as one of the largest telecom companies in the United States to expand and enhance service.

Hilary worked on AT&T’s comments to the most recent wireless infrastructure Notice of Proposed Rule Making (“NPRM”). Our comments outlined how we plan to increase the availability of broadband for consumers as well as effectively deploy 5G technology. We called on the Commission to enact rules to reduce barriers for small cell deployment on the state and local levels.  Small cells will do much to improve service now, and help ensure that communities have the infrastructure to support 5G when it comes to market. These restrictions include moratoria on applications as well as the placement of the technology, charging unreasonable non-market based fees, burdensome siting restrictions, and aesthetic restrictions. Furthermore, we asked the Commission to update its approach to the National Historic Preservation Act (“NHPA”) and the National Environmental Preservation Act (“NEPA”). Looking at these issues together, the Commission is presented with the opportunity to spur broadband development, bringing us closer to the goal of providing broadband access for every American.

One of the major programs that the Commission has implemented to close the digital divide is the Mobility Fund. Under Chairman Pai, the Commission is working to ensure that money from the fund is used to expand mobile broadband coverage to unserved Americans in areas that can be cost prohibitive for carriers to cover without help from the federal government. Currently the Mobility Fund is transitioning from an old model that emphasized carrier competition in areas that are already being served to the new model that focuses on spending money to ensure that unserved Americans are targeted for expanding mobile broadband coverage. AT&T is one of the largest recipients of Mobility Fund assistance, and is committed to ensuring that the Fund is directed to providing the most Americans possible with coverage. Delaney researched the relationship between Mobility Fund support and mobile broadband coverage in several states, including Mississippi and Wisconsin. He focused on emphasizing areas where companies receive Mobility Fund support but other carriers outside of the program already provide coverage. This kind of detailed information can help the Commission as it optimizes the structure of the Mobility Fund.

Finally, Julian worked on the recent wireline infrastructure NPRM. This is a large docket which includes a multitude of proposals from the Commission on how it believes the agency can best remove the regulatory barriers which are impeding the deployment of next generation networks. Through our comments, AT&T has advocated for minimizing the timeline used to retire outdated services, which will allow us to bring new services to the market sooner. We also made arguments for ending discriminatory pole attachment rates, which put us at an unfair disadvantage when we are negotiating our attachment contracts. We gave our thoughts on how to properly reduce the amount of time needed for make-ready work and spoke to a variety of other proposals raised in the NPRM. It is our hope that by working together with the Commission, we can streamline the process through which we move on from outdated technologies, allowing us to advance America’s critical communications infrastructure and provide broadband service to all citizens.

By addressing all of the aforementioned issues, the Commission has made clear that it is striving to create a regulatory environment which will foster greater investment in the future of America’s communications infrastructure.


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