Posted by: AT&T Blog Team on May 21, 2013 at 10:36 am
Today AT&T, the National Association of Broadcasters, and Verizon jointly posted the following blog post.
The TV broadcast spectrum incentive auction proceeding raises some of the most difficult engineering challenges the FCC has ever faced. One thing is clear: a successful auction must start with an effective band plan. A band plan must seek to mitigate interference challenges to the greatest extent possible while offering blocks of spectrum best suited for deployment by U.S. wireless carriers. Otherwise, it will drive down the value of the spectrum and likely undermine the auction’s success.
With that in mind, broadcasters, wireless carriers and equipment manufacturers have spent an enormous amount of time, energy and expense reviewing and commenting on the optimal framework for the 600 MHz band. Hundreds of pages of comments have been filed, two industry consensus letters have been submitted and the FCC just recently convened a day-long workshop to discuss this issue. The result is growing consensus for adoption of a “down from 51” framework that seeks to maximize paired allocations and build guard bands only to meet engineering necessity. This approach reflects the best collective engineering judgment of the companies most affected by the auction, including those that will spend billions of dollars to purchase 600 MHz licenses at auction and billions more to develop and deploy the spectrum in U.S. wireless networks.
Despite these significant advances, on Chairman Julius Genachowski’s last day, a Public Notice was released seeking comment on two alternative band plan frameworks, one reversing the uplink and downlink allocations and one featuring time division duplex (TDD). The first has absolutely no support in the record and the second adopts a technological approach contrary to the one proposed by the majority of U.S. carriers. A fair reading of the Public Notice suggests that the FCC feels the consensus approach constrains its ability to adjust the band plan to meet market-by-market variations. We believe, however, that this notice will consume resources better spent on dealing with other critical and as-yet-unanswered questions in this proceeding, such as how co-channel interference concerns could undermine the variability of any band plan and how the FCC plans to conduct an effective re-packing.
Each of us of course will respond to the notice, but we don’t anticipate any fundamental shift in positions we’ve already taken in the record. In the meantime, we are concerned about the apparent disconnect between the FCC and the various industries that will be critically affected by this auction. Nothing about this auction will be easy, and, if we are to succeed, we must all work together to find solutions best designed to respond to broadcast industry concerns while meeting wireless industry requirements.
Posted by: AT&T Blog Team on May 20, 2013 at 5:11 pm
Please attribute the following to Bob Quinn, AT&T Senior Vice President of Federal Regulatory and Chief Privacy Officer:
“Earlier this month, the FCC adopted an initial order on Text-to-911 services that addresses the requirement for automatic bounce-back messages where Text-to-911 service is not available. Consistent with our voluntary commitment, AT&T supports this critical public safety functionality as a necessary consumer protection and believes the FCC got it right by imposing this requirement on all providers of those services irrespective of the technology underlying the service. The FCC has clear authority to implement the recommendations of the Emergency Access Advisory Committee, and these rules fall within that authority.
“The Commission must provide guidance so that the industry can determine what types of consumer protection regulations will apply to different types of next-generation services (i.e., those that will replace POTS). Although those services should remain largely free of regulation, we recognize that there will be requirements on some IP services, such as those adopted earlier this month, that are necessary for consumer protection purposes. Knowing what will be expected and what will not is critical to those who are contemplating investment in this space.
“We hope that the Commission’s VoIP numbering proceeding will provide the platform from which the agency can lead that broader discussion and help to create a path towards accomplishing an efficient, comprehensive transition from POTS to an IP world as well as an appropriately limited, 21st Century Smart Regulatory framework for that world. Without that discussion, I fear that the current regulatory framework will continue to lag behind the natural evolution of these services in the marketplace and slow investment, innovation and the National Broadband Plan’s mission to create a broadband-enabled, high-performance America.”
Posted by: AT&T Blog Team on May 10, 2013 at 3:12 pm
The following statement may be attributed to Jim Cicconi, AT&T’s Senior Executive Vice-President, External and Legislative Affairs:
“Today’s public notice is a step forward, though we are disappointed the FCC still appears tentative about dealing with the IP transition, especially when compared with the bold and visionary goals of the National Broadband Plan. Certainly, this notice might yield some interesting information, and we will of course cooperate fully with the FCC. We also intend to provide further detail on our proposed geographic trials as requested today, though we are puzzled it took the FCC six months to decide it needed such information. We continue to believe that controlled, comprehensive geographic trials will more likely identify problems and allow the crafting of solutions. We also believe that further delays by the FCC in moving to such trials, which they themselves would control, creates more investment uncertainty. We hope the FCC will consider today’s notice as a first step, one that will ultimately be followed by the more thorough exploration of issues that its own National Broadband Plan challenges us to undertake.”