The following may be attributed to Jeanine Poltronieri, AT&T Assistant Vice President of Federal Regulatory:

We write today to support proposed FCC actions to streamline and accelerate the siting of broadband infrastructure.  These steps will help get broadband services to consumers more quickly and help carriers expand their networks, and thus their services, expeditiously with as little disruption to the surrounding community as possible.

Just last week, the FCC approved an Order streamlining and modernizing tower lighting.  The FCC is now considering a number of additional actions, including the streamlining of deployments for small cells  and Distributed Antenna System (“DAS”) technologies.  This is one area that is particularly important since it would help provide broadband for areas that might be hard to serve because of the physical environment (like a garage) or is being blocked by other structures – real mountains or urban canyons.

Like all carriers, AT&T is deploying denser vertical networks in order to accommodate the ever-increasing demand for wireless services, especially wireless broadband services like full motion video. AT&T currently operates more than 34,000 Wi-Fi hot spots nationwide and has more than 143,000 Wi-Fi access points across the country.  More than 2.7 billion Wi-Fi connections were made on AT&T network in 2013.

AT&T is also aggressively deploying DAS to address rapidly growing network traffic at large venues and other hard to serve areas.  At the 2014 Super Bowl, AT&T customers used 624 GBs of data on our in-stadium DAS – a new high for a major sporting event.

Small cells and DAS technologies also provide benefits where macro cells (the larger towers that were the only option when cellular began) are unsuitable because of zoning or leasing challenges.

We recently filed an ex parte, which in addition to establishing the legal basis for streamlining the environmental and historical review required for small cells systems, also provides some photos of recent small cell deployments.  AT&T tried for years to deploy a “macro” site to improve our coverage in this populated residential area.   With new technology, we were able to deploy small cells directly on light poles to provide the same coverage.

While configurations vary, small cells can be placed on sides of buildings, on all types of utility poles and sometimes the equipment can be contained within a single small enclosure.  In many of these situations, given the use of existing structures, it’s easy to see why additional environmental or historical review is unnecessary.  In fact, PCIA – The Wireless Infrastructure Association has proposed a clear and workable volume definition that provides a bright line rule for when further environmental and historical review is not needed and where the carrier or infrastructure provider can instead take advantage of a streamlined approval process.

Importantly, streamlining the local environmental and historical review does not eliminate oversight –deployment would still need to meet the National Electrical Safety Code, and local authority is preserved because any installation must still meet other health/safety/fire codes of the locality.   And it is in a carrier’s best interest to keep small cells small – smaller, lighter equipment is generally less costly to deploy since it does not require expensive replacements of poles or other structures that would be needed to bear a heavier load.

Streamlining the process for small cell deployments is just one of the actions the FCC is considering to accelerate broadband infrastructure deployment.  The FCC’s Wireless Bureau should be commended for their work in this area, and we look forward to resolution of the proceeding so we can continue to deliver broadband to our customers as expeditiously as possible.

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