Friday, March 14, 2014

Andy Morentz Published in The CCA Voice

TLP Member Andy Morentz's article on 4G Data Roaming has been featured in the 2014 Spring/Summer edition of The CCA Voice.  The article discusses the difficulties that competitive carriers face when attempting to obtain access to nationwide data roaming, particularly for 4G LTE, at reasonable rates and with reasonable terms and conditions.  Mr. Morentz outlines steps that carriers can take to lay the groundwork for a persuasive FCC complaint and further combat the unequal roaming playing field.     

Read more at: Beat 'Em or Join 'Em: Data Roaming in a 4G LTE World

Wednesday, March 5, 2014

DoD Emphasizes the Need to Share Spectrum

The Department of Defense (“DoD”) released an “Electromagnetic Spectrum Strategy” Report that provides a framework for how the DoD may increase available spectrum to meet growing demands from the commercial wireless industry while maintaining critical military capabilities.  The spectrum strategy and action plan establishes key goals and objectives that focus on developing systems that are efficient, flexible, and adaptable in their use of the spectrum; increasing the operational agility in the use of the spectrum; and participating in the development of national and international policies and regulations needed to enable these improvements.  The Report recognizes that consumer demand for commercial wireless services is continuing to rise, and “as a result of these pressures on the spectrum, in the near term, there is a high probability that DoD could lose dedicated access to portions of spectrum available to it today.”  The Report acknowledges that new technologies will provide DoD with the opportunity to leverage commercial technologies and wireless services to meet DoD requirements, and emphasizes the need to share spectrum to promote both government and commercial interests.

Goal 1: Expedite the Development of SDS Capabilities with Increased Spectrum Efficiency, Flexibility, and Adaptability. DoD “will exploit technology advances to access less-used spectrum and seek to use commercial services and technologies to meet DoD requirements where possible,” while exploring increased spectrum sharing opportunities. DoD lists several objectives to reach this goal, including:
  • DoD will identify systems that can share spectrum and/or operate compatibly with systems in adjacent spectrum bands without affecting system effectiveness or compromising operational safety. Investments will focus on this flexible spectrum usage and interference mitigation technologies
  • DoD will participate in national, international, and industry-specific standards bodies associated with wireless innovation to collaborate on emerging technologies, including national security preemption and priority mechanisms for commercial wireless systems. 
  • DoD will cultivate and adopt commercial service capabilities.
Goal 2: Increase the Agility of DoD Spectrum Operations. DoD will “improve its capabilities to plan, manage, and control all dimensions of spectrum use to preserve access to and maneuver” within the spectrum environment, and will explore sharing and other new spectrum use paradigms while advocating for exclusive spectrum access for military capabilities. The Report notes that maintaining a comprehensive spectrum database is essential to “access and maneuver.” DoD objectives to increase the agility of its spectrum operations include:
  • DoD will develop the ability to perform near-real-time spectrum operations.
  • DoD will improve its ability to identify, predict, and mitigate harmful interference.
  • DoD will identify and evaluate incentives for spectrum sharing while developing spectrum policy.
Goal 3: Sharpen the Responsiveness to On-Going Spectrum Regulatory and Policy Changes. DoD will sharpen its ability to assess, contribute to, and adjust to worldwide regulatory and policy changes being proposed (e.g., re-purposing spectrum to accommodate wireless services). DoD objectives associated with this goal include:
  • DoD will reform its ability to assess proposed national and international regulatory and policy changes.
  • DoD will expand its participation in and contributions to regulatory and policy discussions.
  • DoD will develop executable transition plans that accommodate new spectrum uses while maintaining full military capability.
Please feel free to contact TLP if you have any questions.

FCC Rural Broadband Workshop Scheduled For March 19

The FCC has announced that the Rural Broadband Workshop will be held on Wednesday, March 19, 2014.  The Workshop will focus on the importance of broadband in rural America and include presentations designed to elicit information to help develop “ideas about how to structure experiments that will inform [the Commission’s] policy decisions regarding the deployment of next generation networks in rural, high-cost areas.”  The workshop will examine different business models that have been used to deploy broadband in rural areas, including a discussion of the factors that drive investment decisions and technology choices of different types of providers in rural communities. The workshop will also explore the role that states have played, and can continue to play, in meeting the rural broadband challenge. Additional details concerning the workshop agenda and panelists will be forthcoming. 

The workshop will be free and open to the public, and may be streamed live at

Commission Establishes Comment Cycle for Technology Transitions FNPRMs and the AT&T Proposal

During the FCC's February Open Meeting, the Commission adopted an Order, Report and Order and Further Notice of Proposed Rulemaking, Report and Order, Order and Further Notice of Proposed Rulemaking, Proposal for Ongoing Data Initiative (FCC 14-5) that authorizes voluntary experiments to measure the impact of technology transitions in communications networks on customers. 
The Commission takes several initiatives:

(1)    Solicits service-based experiments to test real-world applications of planned changes in technology that are likely to have tangible effects on consumers.  Specifically, to examine the impacts of replacing existing legal services with IP-based alternatives in discrete geographic areas or way.
(2)    Adopts targeted experiments and cooperative research and development initiatives to explore the impact of technology transitions on universal access, rural areas, individuals with disabilities and number assignments in an all-IP world. 
(3)    Initiates a proposal for ongoing data initiatives and seeks feedback on a number of other efforts to improve data collection regarding the impact of technological evolutions on network values. 
(4)    Seeks further comment on numbering research.
(5)    Seeks further comment on rural broadband experiments

Deadlines and Other Important Dates

Service Experiment Proposals
Initial Round of Service Experiment Proposals Due: February 20, 2014
Comments on Service Experiment Proposals Due: March 21, 2014
Replies on Experiment Proposals Due: March 31, 2014

Rural Broadband Experiments
Rural Broadband Experiment Expressions of Interest Due: March 7, 2014
Comments on Proposal for Ongoing Data Initiative Due: March 14, 2014
Replies on Proposal for Ongoing Data Initiative Due: April 14, 2014

Further Notices of Proposed Rulemakings
Comments: March 31, 2014
Reply Comment: April 14, 2014

The AT&T Proposal
Comments:  March 31, 2014
Reply Comment:  April 10, 2014

The Commission has released a Public Notice seeking comment on AT&T’s proposal for service-based technology transitions experiments.  On February 27, 2014, AT&T submitted such a proposal for Wire Center Trials for experiments involving the transition of two wire centers – one rural and one suburban – to all IP services and, in part, to wireless-based service.

Please do not hesitate to contact us if you have any questions, or are interested in more information on this proceeding.

Monday, March 3, 2014

March Open Meeting Schedule Change

The March Open Commission Meeting has been rescheduled from Wednesday, March 19, 2014 to Monday, March 31, 2014. 

While no tentative or official agenda has been released yet, it has been reported that the extra time is needed for coordinating and finalizing rules for unlicensed use in the 5 GHz band and for the auction of the AWS-3 spectrum.

Please feel free to contact TLP if you have any questions. 

DISH Wins Big in H Block Auction

The Commission has released a Public Notice announcing “American H Block Wireless LLC” (DISH) as the single winning bidder of 176 licenses in the H Block Auction.  The auction raised a total of $1,564,000,000. 

Attachment A: lists the total winning bid amount.
Attachment B: lists down payments and final payments owed by the winning bidder and refunds due to other applicants.
Attachment C: lists bid withdrawal payments owed by bidders, if any.  

Attachment D: information for the winning bidder on how to complete the long form application and ownership disclosure report.

Please feel free to contact TLP if you have any questions.