Unlocking the Potential
Of AWS-3 Spectrum

Posted by: admin on September 2, 2010 at 2:53 pm

By Joan Marsh, AT&T Vice President of Federal Regulatory 

Yesterday, Chairman Genachowski removed from circulation the AWS-3 draft item, ending a long and largely frustrating debate about disposition of the AWS-3 spectrum at 2155-2180 MHz.  A mountain of paper was amassed over the question of whether the spectrum should be auctioned subject to a unique set of restrictions that would have limited the use of the spectrum to a single specialized business plan proffered by M2Z.  The FCC concluded, rightfully, that M2Z’s plan “was not the best policy outcome.”  We agree, and fully support the Chairman’s decision and his continuing leadership on effective spectrum policy for the 21st century. 

AT&T has long opposed the M2Z proposal at the heart of the debate, which was built on a complicated set of restrictions that would require 25% of the licensee’s “network capacity” be used to offer “free, family-friendly broadband service.”  A myriad of questions arose around how the free service would be provisioned and supported, whether the quality of the free service would be acceptable and how the licensee would demonstrate compliance with the network capacity requirements.  The top downlink speed of the free service would have been 768K, and many worried that such a service would chase other providers of affordable, low-speed broadband services from the market, relegating an entire class of users to a technological backwater. 

To make matters worse, in support of its business plan, M2Z proposed service and technical rules that would allow this unpaired band to be used for the delivery of two-way broadband services using time division duplexing or “TDD” technologies.  This proposal – which would allow the licensee to combine uplink and downlink operations in a single band – created the very real potential for harmful interference in adjacent AWS-1 bands.  M2Z specifically opposed restrictions on out-of-band emissions and power limits that would have guarded against this interference, arguing that those restrictions would degrade the service.  M2Z also opposed the use of appropriate guard bands – which have long been used quite effectively to address interference problems – calling instead for “cooperation and coordination requirements” to address the issue. 

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Narrowing the Debate
On Paid Prioritization

Posted by: Hank Hultquist on September 2, 2010 at 12:37 pm

As discussed in my last blog, for many years proponents of extreme versions of net neutrality regulation have fulminated against the practice of “paid prioritization.” In a recent series of letters, Free Press argued that the Commission should in no circumstances permit ISPs to be compensated for the provision of “router-based prioritization,” and that such prioritization is not taking place today.

At the time, Free Press was responding to a letter filed by the Minority Media and Telecom Council that urged the Commission not to adopt a blanket ban on payment for prioritization. According to MMTC:

“Today, when [businesses] sign up for Internet access service, many of these businesses also enter into voluntary arrangements with their broadband providers for the provision of enhanced quality of service capabilities as part of their Internet access service as well as other specialized offerings. These agreements allow [businesses] to identify a portion of their traffic as requiring better than “best effort” handling. This capability allows these businesses to ensure that the performance sensitive applications that they wish to run, such as VoIP or IP-based video conferencing, receive the service quality needed to function properly.”

Free Press responded at the time by insisting that such compensation arrangements were inconceivable under the IETF documentation for Differentiated Services (DiffServ).

Yesterday, the New America Foundation’s Open Technology Initiative (OTI) basically endorsed the practice described by MMTC. According to OTI: “[t]he intended purpose of DiffServ is user-driven differentiation of traffic.” It would seem that Free Press owes MMTC a clarification.

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My New Phone Just Arrived…By Boat?

Posted by: admin on September 1, 2010 at 2:03 pm

 Authored by Joseph Marx, AT&T Assistant Vice President of Federal Regulatory 

The U.S. Department of Transportation earlier this year proposed a new set of rules toughening the air shipping requirements on lithium ion batteries and devices containing these batteries.  The rationale behind this proposal focuses on a concern that these batteries could overheat or catch fire. 

Every year, billions of lithium batteries are shipped via air and yet the Transportation Department has not pointed to one incident when a lithium ion battery, or a product containing such a battery, overheated or caught fire when shipped according to existing domestic and international guidelines.  Everyone agrees that safety is non-negotiable.  If the U.S. does anything, it should harmonize its existing rules with the more stringent international recommendations and enforce these regulations, not put new rules in place that would disadvantage U.S. consumers for no net benefit. 

The side story that no one has focused on is what happens if the U.S. deviates from the international standard and imposes different and more burdensome rules than other countries. These new requirements could fundamentally change how every U.S. consumer electronics business, including the wireless industry, does business.  The U.S. has traditionally been the first to get every new wireless gadget that comes off the assembly line.  Well, not anymore.  If the new rules are put in place it could limit delivery of devices containing lithium ion batteries to transport methods or delivery locations other than those used with air delivery.  

Can you imagine waiting three months to get delivery of new handsets from overseas while they are being delivered by boat?  It will be a great Christmas, in March.  How about waiting an additional week for a replacement for your wireless phone when it breaks?  Consumers have come to expect the quick turnaround that overnight delivery allows when it comes to replacing their broken wireless devices. 

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