FCC Acts to Improve Rural Broadband Service with $100M Fund- Census Blocks Released

Roughly 10% of the U.S., mostly in remote rural areas, is eligible to take advantage of $100 million the Federal Communications Commission is allocating for improvements in rural broadband service. The project gets its money from the FCC’s $4.5 billion Connect America Fund. The commission is providing bidding incentives for proposals that exclusively serve tribal lands.

The FCC this week released a list of the U.S. Census blocks—roughly the size of a city block [half are smaller than than a tenth of a square mile, while the largest is greater than 8,500 square miles]—that would qualify for a piece of the $100 million fund the agency created earlier this month. The objective is to get broadband service to unserved and under-served populations, which are primarily rural. The commission’s map of the eligible areas has been updated with more detailed views.

Seventy-five million is dedicated for testing the construction of networks that provide 25 Mbps down and 5 up, and another $15 million will go “to test interest in delivering service at 10:1 speeds in high cost-areas,” defined as those where the monthly cost per location of providing service is between $52.50 and $207.81. The third set of funds comprises $10 million for 10/1 service “in areas that are extremely costly to serve,” or those where service of at least 3 Mbps up and 768 kbps down is unavailable, and that would exceed $207.81 monthly.

More than 1,000 entities have expressed interest in the projects, including utilities, wireless operators, and CLEC affiliates of local telcos, according to the FCC.

The Utilities Telecom Council Inc. applauded the FCC for including utilities.

“By encouraging utilities and others to provide broadband that is robust, affordable and reliable, the FCC is creating new opportunities to promote economic growth and expanded access to health and safety, education, and essential services in our rural communities,” said Connie Durcsak, President and CEO of UTC, in a statement.

Read more at:



FCC Net Neutrality Proposal Stirs Up Controversy- Reclassify or Not?

An image of Tom Wheeler, Chairman of the FCC,.
FCC Chairman, Tom Wheeler (image courtesy of FCC.gov)

On May 15th the FCC Commissioners narrowly voted to approve a framework for rules that would create an Internet fast lane, while trying to patch up the loopholes that would make that fast lane possible.

The proposal from FCC Chairman Tom Wheeler would ban broadband providers from blocking or slowing down websites, but leaves the door open for them to strike deals with content companies for preferential treatment, or fast lanes to customers. The Democrat-majority FCC voted 3-2 along party lines to open the proposal to public comment for 120 days, with an eye toward voting on final rules later this year.  However, the timing of actual rules will depend on what the agency decides to do after the four-month comment period expires.

Frankly, we don’t understand why there are objections for content providers and consumers paying more for higher speed delivery of broadband Internet content.  Doesn’t every ISP charge more for higher speed Internet access?  Don’t pay TV providers charge more for premium content with tiered service offerings? And an extra charge for HBO, Showtime, STARZ, Cinemax, etc?

The FCC is proposing that it should use the authority that it has under Section 706 of the 1996 Telecommunications Act to regulate net neutrality, which leaves the rules open to the possibility of “paid prioritization” of Internet traffic. While FCC Chairman Tom Wheeler said that those rules don’t allow paid prioritization and is vehemently against allowing any bifurcation of the Internet, it’s also something that the agency can’t enforce if the ISPs offer a creative legal challenge to its no-blocking rules or the wording of the eventual net neutrality rules.

“The potential that there would be some kind of a fast lane has many concerned,” Wheeler said. “I don’t like the idea and I will work to see that does not happen. We specifically ask whether we can and how to prevent an internet fast lane.”

While broadband providers like  Comcast, Verizon and  AT&T are firmly against stronger regulatory oversight of the industry—a possibility that the commission opened up for comment—they have indicated that Mr. Wheeler’s proposal as it stands is something they could live with.

The content providers disagree vehemently.  Google, Facebook, Amazon.com, and many web content startups are vehemently opposed to any arrangements that allows broadband providers to charge content companies extra for preferential treatment.

Netflix, whose streaming service is responsible for a substantial share of overall Internet traffic, said it is “concerned that the proposed approach could legalize discrimination” in how broadband providers treat Web traffic, “harming innovation and punishing U.S. consumers.” The statement added, “Netflix is not interested in a fast lane” on the Internet.

Another key issue is whether the FCC should reclassify broadband as a public utility service that’s regulated.  Currently, Internet Service Providers (ISPs) are classified as information services, which means the FCC cannot regulate them as it would landline phones which are considered telecommunication utilities and under the FCC’s purview. Reclassifying ISPs as utilities (like common carrier telephone services) would potentially give the FCC far greater control over ISPs and, potentially, help the FCC ensure an open Internet.

The problem with defining broadband (not including mobile Internet access) differently than land-based common carriers, which are governed by Title II in the original 1934 U.S. Telecommunications Act, is that the FCC doesn’t have the right to regulate broadband or truly protect net neutrality.

When the FCC sought to censure Verizon’s efforts to manage its own Internet traffic, the D.C. Court of Appeals found it had overstepped its bounds and struck down the net neutrality rules the FCC essentially built as a bulwark against Internet access abuse. The rules it was applying to Verizon’s Internet services were not covered under Section 706 of the 1996 Telecommunications Act, which governed the FCC’s oversight of broadband.

Section 706 of the 1996 Telecommunications Act didn’t give the FCC that kind of power. Redefining broadband Internet services a utility would allow the FCC to bring to bear all the rules and power found in Title II of the 1934 Telecommunications act.

“The fact is that reclassification doesn’t mean any additional regulation at all,” said Free Press Research Director S. Derek Turner who added that industries like wireless and carrier Ethernet currently classified under Title II “are thriving.”  So what’s the problem?

Net neutrality proponents believe officially designating broadband as a utility to be regulated is the only way to ensure an open Internet. “It is exactly what the bulk of activists are supporting, as the recent court decision made it clear that it is the only way in which true net neutrality regulations can be applied,” said David Segal, executive director of Demand Progress.

Some would like the whole Internet designated a public utility. “The Internet is a public utility and the FCC must regulate Internet providers as common carriers. Anything short of undoing the George W. Bush-era deregulation of broadband industry is fake net neutrality, and we’re not falling for it this time,” said Becky Bond, Political Director at CREDO Mobile.

“Tom Wheeler spoke passionately about the open Internet, but his rousing rhetoric doesn’t match the reality of his proposal. The only way to accomplish the chairman’s goals is to reclassify Internet service providers as common carriers,” Craig Aaron, CEO of the open-media advocacy group Free Press said.

Broadband (wire-line) providers, though, say reclassification would be devastating for their industry.  Former FCC Chairman Michael Powell (now the CEO of National Cable and Telecommunications Association) said: “Treating broadband as a utility-like Title II service would reverse years of settled precedent, dry up investment in broadband deployment and network upgrades, and result in protracted litigation and marketplace uncertainty. We (the NCTA) will continue to reiterate our unwavering opposition to any proposals that attempt to reclassify broadband services under the heavy-handed regulatory yoke of Title II.”

The FCC’s proposal is open to months of debate before a final document is voted on at the end of this year. Whether the Title II reclassification concept survives that long is open to conjecture and debate.  Mr. Wheeler emphasized that his proposal is only a draft, and that he is open to changing it before a final vote later this year.

Mr. Wheeler has repeatedly vowed to use all tools at his disposal to prevent Internet providers from striking deals that would shut out startups and smaller companies that can’t afford to pay for preferential treatment.  He said consumers pay for a specific amount of bandwidth when they subscribe to broadband Internet access, and that the commission won’t allow broadband providers to throttle that connection or limit how consumers use it.

“The potential for there to be some kind of ‘fast lane’ available to only a few has many people concerned. Personally, I don’t like the idea that the Internet could become divided into have’s and have-nots,'” Mr. Wheeler said. “I will work to see that doesn’t happen.”

“There is one Internet. It must be fast, it must be robust, and it must be open,” Mr. Wheeler added. “The prospect of a gatekeeper choosing winners and losers on the Internet is unacceptable.”

That remains to be seen.  This is going to be one heck of a balancing act for the FCC.  For sure, they won’t be able to satisfy all the stakeholders in the broadband Internet (content providers, ISPs, consumers, public interest/ consumer advocate groups, etc).

We’ll update you with our perspective, comment and analysis as this controversial proposal and ultimate ruling progresses.  We think it will be a “battle royal.”

Here’s how to submit a comment to the FCC:

The FCC is taking comments on its proposal at OpenInternet@FCC.gov This email address is being protected from spambots. You need JavaScript enabled to view it. . The initial deadline for comments in July 15th and the deadline for reply comments is September 15th, but the agency is expected to keep the inbox open until it votes to finalize the proposal.


Everything You Ever Wanted to Know About the FCC’s Net Neutrality Proposal

Section 706 of the 1996 Telecommunications Act



Viodi View – 05/12/14

Operational and incremental improvements using cable television infrastructure as a wireless network and as an enabler of the Internet of Things were big themes of the recent four-day Cable Show confab in Los Angeles. Although 4K was prominent in multiple booths and displays at the conference, much to my surprise, there were no blockbuster announcements from any of the major TV networks announcing 4K programming. Most likely alternative sources of content will prime the market for Ultra High Definition, as can be seen in the ViodiTV exclusive video in the Korner.

Innovation of Things at the Cable Show 2014

An image of the Internet of Things display at the Cable Show 2014.
Click to view

“Everybody’s looking to innovate,” said Matt Polka of the American Cable Association. Polka explains that innovation surrounding the cable broadband ecosystem was one of the themes of the 2014 Cable Show. He stresses that innovation is an important element to giving consumers’ what they want; whether that is new ways of viewing content or apps that help make for a smarter home. The following interview with Polka features video highlights of various demonstrations, exhibits and other highlights of the Cable Show.

Click here to view and read more.

Rural America Needs Advanced Services & Competition by Gene South

Snapshot of U.S. broadband from broadbandmap.gov
Click to read more

It is an honor to publish a two-part article from Gene South, a leader in the independent telco industry for a number of years. In part one,  he outlines how the view of the telecom industry changed from one of a regulated monopoly to one where competition is encouraged. In part two, he looks at the post AT&T break-up and the importance of rural citizens at the local level being able to determine their broadband destiny.

Open Video Rules Make BB a Reality for the Unserved

Ken Pyle interviews Gary Johnson of Paul Bunyan Communications at the 2014 MTA.
Click to view

An entity that has its ear to the consumer in rural Minnesota is Paul Bunyan Communications. They have almost tripled in size since the turn of the century by aggressively expanding outside their traditional service area to serve customers where incumbents had not kept up with market needs for broadband and video service. Using a little-employed federal law they have been able to work with Minnesota Townships to expand their service with fewer barriers than traditional regulatory structures.

Click here to view and read more.

Ethernet Tech Summit Reveals Many Paths to “Open SDN” by Alan Weissberger

One expert's solution to the multiple flavors of SDN: Overlays Complete Virtualization
Click to read more.

[Editor’s Note: After giving some thought to Alan Weissberger’s cogent analysis on the state of Software Defined Networking, perhaps the SDN acronym should stand for Still Don’t kNow (apologies to whoever invented the acronym I Still Don’t Know – which many suggested was the answer to the question of the market for ISDN back in the early 1990s). Weissberger makes the case that, despite several efforts to create “open” standards, there is potential for vendor lock-in around SDN and that there are issues of compatibility and single points of failure that point to multiple flavors of SDN.]

Click here to read and to contribute to the discussion on his article.

Some Tweets and Short Thoughts:

  • “One of the most effective tools for ensuring Internet openness is competition,” FCC Chairman Thomas Wheeler recently stated. Competition in the last mile is critical to ensuring not only cost-competitive, but innovative broadband offerings. Some other commentary on the upcoming Net Neutrality discussion can be found here.
  • Good article point-counter-point about net neutrality in Monday’s WSJ. Local barriers are often the difference between a duopoly and multiple competitors; at least in urban areas.
  • Also kudos to Brett Sappington of Parks Associates for his piece in that same WSJ section arguing that it is too early to buy a 4K TV.
  • At the cable show, a respected cable operator expressed the same concerns about new LTE-Unlicensed having the potential to relegate WiFi to second-class status. Click here for the Light Reading article on this topic.
  • Create, not cover the conversation. Need to provide reason for new generation to come to cable & their goal is for to help.
  • Twitter changed the game – immediate audience feedback. Don’t need to wait for Nielsen
  • “Cable collectively is already the largest wireless operator” [in terms of bits transmitted over unlicensed WiFi]. Interesting statement made by one of the cable executives; haven’t had a chance to verify. 

The Korner – The World’s Biggest Art Museum – In Your Hand

Ken Pyle interviews Sheldon Laube of Artkick with the Monalisa painting in the background.
Click to view

The ephihany from the 2013 Cable Show was that some of the first successful content for 4K will come from sources other than the traditional video networks. One of the things that intrigued me about Artkick when they reached out to me at CES is that they are creating a channel that could easily offer compelling 4K content.+  Artkick’s approach of viewing black screens as something more than TV has a potentially big impact on the way screens are viewed in the home.

Click here to read more and to view.

FCC Set to Act on Net Neutrality at May 15th Meeting

An image of Tom Wheeler, Chairman of the FCC,.
FCC Chairman, Tom Wheeler (image courtesy of FCC.gov)

On April 23rd, Federal Communications Commission Chairman Tom Wheeler said that he’d circulate his net neutrality proposal to other commissioners on Thursday of this week, in preparation for a vote at the FCC’s May 15 meeting. The draft rules will then be formally proposed and available for public comment.

We’ve been waiting for a definitive net neutrality proposal from Wheeler for well over two months. While speaking at Silicon Flatirons/ University of CO Law School on February 10th, Wheeler said he’d be outlining his plans “in the coming days.”  Or was that “coming months?”

“In its Verizon v. FCC decision, the Court of Appeals invited the Commission to act to preserve a free and open Internet. I accept that invitation, and in the coming days, I will be outlining how I propose to proceed.”

The proposed FCC rules are expected to ensure that network operators disclose exactly how they manage Internet traffic and do not restrict consumers as they surf the Web.  In particular, the rules would prevent the service providers from blocking or discriminating against specific websites, but would allow broadband providers to give some traffic preferential treatment, so long as such arrangements are available on “commercially reasonable” terms for all interested content companies. Whether the terms are commercially reasonable would be decided by the FCC on a case-by-case approach in reviewing the practices adopted by Internet providers.

However, the FCC rules are not expected to address the issue of interconnection, or agreements in which content companies pay network providers for faster access to their sites or services.  In the past, Wheeler has said that net neutrality rules would not regulate deals between businesses on connections before they reach the user.  That’s because the scope of the net neutrality rules is limited to the “last mile” of the (broadband access) network that reaches the consumer or business customer.

The Wall Street Journal reported today that

“The FCC’s proposal would allow some forms of discrimination while preventing companies from slowing down or blocking specific websites, which likely won’t satisfy all proponents of net neutrality, the concept that all Internet traffic should be treated equally. The Commission has also decided for now against reclassifying broadband as a public utility, which would subject ISPs to much greater regulation. However, the Commission has left the reclassification option on the table at present.

In addition, the FCC plans to significantly increase the disclosure requirements for broadband providers, which could include details such as the speed and congestion of their service along the last mile. The proposal wouldn’t cover wireless carriers, but it will ask whether mobile broadband providers should be subject to a similar commercially reasonable standard when striking deals with content providers.”

Here are few recent facts related to net neutrality:

  1. This January, the U.S. Court of Appeals for the District of Columbia Circuit struck down the FCC’s previous version of the open Internet order.  It was the second time the court took such action.
  2. However, the Court ruled that the FCC has the legal authority to issue enforceable “rules of the road” to preserve Internet freedom and openness.  It affirmed that Section 706 of the Telecommunications Act of 1996  gives the FCC authority to encourage broadband deployment by, among other things, removing barriers to  infrastructure deployment and promoting competition. It also found that the goals of the Open Internet Order are within the scope of authority granted to the Commission.
  3. The court opinion specifically included that the Commission was justified in concluding that an open Internet would further the interest of broadband deployment by enabling the virtuous cycle of innovation that unites the long-term interests of end-users, broadband networks and edge-providers. After all, it explained, when edge-providers are prevented from reaching end-users, demand for both those upstream applications and for network expansion suffer.  The upshot here is that the preservation of an “open Internet” is within the FCC’s authority.
  4. Comcast, through conditions placed on its 2011 merger with NBC Universal, is the only Internet provider still bound by the earlier FCC net neutrality rules through 2018.  Comcast has now proposed to buy its biggest rival Time Warner Cable Inc and Netflix has come out in opposition of the $45.2 billion merger, arguing that the Internet provider should be banned from charging fees for delivering its content.  Comcast has said that Netflix’s opposition was “based on inaccurate claims and arguments.”
  5. Netflix, which accounts for much of Internet traffic during peak hours (some say over 50%), in February struck a deal to pay Comcast for faster online delivery of its movies and TV shows.
  6. Indeed, Netflix, Skype (now owned by Microsoft), Hulu/ Hulu +, Amazon, Google/You Tube, and other content providers that offer video, voice, or audio services that rely on broadband Internet connections could take advantage of such arrangements by paying the broadband providers to ensure that their traffic reaches consumers without disruption. Those companies would be paying for preferential treatment on the “last mile” of broadband networks that connects directly to consumers’ homes.

To reiterate, the FCC’s net neutrality proposal is not expected to address the separate issue of “back-end interconnection” or “peering” between content providers and broadband network providers.  It’s new rules will only apply to the “last mile” broadband access network.



AT&T to Test All-IP Phone Network in 2 U.S. Cities

AT&T will begin pilot testing all-digital IP phone networks in West Delray Beach, Florida, and Carbon Hill, Alabama, as part of the U.S. carrier’s push to move away from legacy switched telephone networks (PSTN and POTS) in favor of all-IP delivery of voice, data and video.

AT&T’s announcement: Testing the Next Generation of IP Networks, states that the carrier has filed plans with the FCC to conduct IP Trials in these two wire centers and that the trials will run over the next few years. These trials will provide information about the customer experience in transitioning to the faster, more advanced network that consumers and businesses are demanding.  Several sources stated that the FCC has approved these two AT&T trials (see references below), but we couldn’t find anything at fcc.gov to confirm that.

The trials will pay particular attention to the reliability of IP-based networks for accessing emergency services and connecting consumers to medical devices and home security networks.

AT&T initially will ask customers in the test areas to switch to the new technologies. In a separate phase that would require U.S. approval, the company would stop offering plain old telephone service to new customers, Hank Hultquist, AT&T vice president-federal regulatory, said today at a press briefing.

These regional experiments will help the FCC decide whether AT&T and other telecom operators (telcos) should be allowed to stop offering traditional wired phone service as customers migrate to wireless and Internet-based communications.  

More than 70 percent of residential customers in AT&T’s 22-state service area have abandoned traditional wired service, the company said in a filing last year, asking the F.C.C. to end rules preventing them from dismantling legacy systems.

At its January 31st open commission meeting, the FCC endorsed and ordered Voluntary Experiments Testing Impact of Technology Transitions

According to the FCC website,

“The Proposal for Ongoing Data Initiative (Order) kickstarts the process for a diverse set of experiments and data collection initiatives that will allow the Commission and the public to evaluate how customers are affected by the historic technology transitions that are transforming our nation’s voice communications services – from a network based on time-division multiplexed (TDM) circuit-switched voice services running on copper loops to an all-Internet Protocol (IP) network using copper, co-axial cable, wireless, and fiber as physical infrastructure. Americans have come to expect secure, reliable, and innovative communications services. The purpose of these experiments is to speed market-driven technological transitions and innovations by preserving the core statutory values as codified by Congress – public safety, ubiquitous and affordable access, competition, and consumer protection – that exist today.”

Unfortunately, the transition could leave hard-to-reach customers stranded. About 4 percent of Carbon Hill’s AT&T customers won’t be getting access to the new IP-based systems at all; while AT&T says it’s committed to finding solutions for those people, it doesn’t yet have a plan.

“We will not move to Phase 2 until everyone has a solution,” said Hank Hultquist, AT&T federal regulatory vice president.  “That solution may not come from us,” cautioned AT&T lawyer Christopher Heimann.

The IP transition trial may also hold unpredictable consequences for competition. The test area in West Delray Beach includes a residential complex that has an exclusive contract with Comcast, meaning AT&T can’t sell services to those customers. That won’t stop AT&T from trying to influence potential customers; it plans to set up informational tables at the complex to woo its residents.

Consumer advocate groups – such as Public Knowledge have warned that telcos should not inadvertently make service worse for some Americans in the pursuit of improving service for others. Phone companies have an incentive to accelerate the IP transition because maintaining the old copper system is expensive, particularly if it is being used by a declining share of customers.

Another critical issue is being able to make emergency phone calls during a power outage.  POTS inherently provides that capability via power feeding and a phone that doesn’t plug into the AC outlet. VoIP operates over a broadband Internet connection that must be powered at all times.  During a power failure, a battery backup box must be installed (and operate) on customer premises for emergency phone calls.


Viodi View – 02/06/14

Watching the Superbowl at the NTCA 2007 Convention.
Click Image to View

The first time Peyton Manning was in the Super bowl, I watched with 2,000+ others at the 2007 NTCA Annual Convention. Unfortunately for Manning, this year’s results weren’t the same and, unfortunately, for me, I didn’t get a chance to attend this week’s NTCA event, now known as RTIME.  Fortunately, we have a video from the 2007 event that provides glimpses of my rural friends who, in part, are an inspiration for an all-consuming project described below in the Korner.

Click here to view the video shot before the advent of the smartphone or tablet.

The Machine to Human Connection

An example of the Man-Machine Connection at International CES 2014. Robots being used for advertising. A new definition of the sandwich board.
Click Image to View

If the Internet of Everything is the future, then International CES 2014 is a good indication of where we are going. One word that describes CES 2014 is connected. Everything seemed to be connected in one form or another. This idea of machine-to-machine interfaces showed up in things ranging from sump pumps to door locks to automobiles.

Click here to read more and view and stay tuned for more of our exclusive coverage of CES.

A New Definition of Smart Water

An image of an Internet Connected Water shut-off valve is shown.
Click Image to View

Given the historic drought in California, finding ways to reduce water use is critical for homeowners and businesses alike. Products like the ones that Kevin Meagher, VP & GM Smart Home of Lowes, discusses a way to automatically detect water leaks and, if the leaks are really a flood, automatically shut off the water to the house. And, even better for earthquake prone Californian, Lowes has solution for detecting gas leaks and turning off gas to the home.

Click here to read more and view.

Smart Devices – Smart Network – Social Benefit

Luis Sosa of Yezz, DDM Brands discusses how SocialMesh Neworking could be a boon for various applications.
Click Image to View

Luis Sosa, CEO of DDM Brands points out that a SocialMesh network approach to wireless will bring benefits to society. He brings an interesting perspective to this topic, as his company has been serving markets with less than ideal wireless infrastructures. As a manufacturer and designer that focuses on these markets, they have introduced innovations that fit the needs of the consumers in smaller markets.

Click here to read more and view.

FCC’s “All IP” Network Transitions Trials – What to Expect

An image of a typical VoIP adapter.
Click Image to Read More

At its January 30th Open Commission Meeting, the Federal Communications Commission  (FCC) voted to approve a petition AT&T had filed (in November 2012) to conduct trials of an “all-Internet Protocol (IP) network” that would eventually replace the PSTN and TDM networks now used extensively in the U.S.  The transition will be from plain Plain Old Telephone System (POTS) delivered over 2 wire copper subscriber loops to feature-rich voice services using Internet Protocols, to be delivered over coaxial cable, fiber, or wireless networks.

Click here to read Weissberger’s thoughts on what to expect and who benefits.

Augmenting the Local Caregiver’s Abilities via Google Glass

Telemedicine with Google Glass - image courtesy of Wound Care Advantage
Click Image to Read More

Telemedicine is the kind of practical application that may make Google Glass and other wearable technologies into something revolutionary. Pristine, a company that claims to be the only company that has developed commercially available Glass-software that meets HIPPA regulations, has partnered with Wound Care Advantage (WCA) to be the first to use Google Glass to help deliver outpatient wound care.

Click here to read more.

Some Tweets and Short Thoughts:

  • @CullenHMcCarty: “FirstNet present is too vague. Partner how? I don’t see it. You’re not selling me here. Message fail. #RTIME14
  • @AjitPaiFCC “Can I text in my vote” on the Text to 911 order. Laughter ensues.
  • “Response from PSAPs has been underwhelming” w/regard to text-911 capabilities. “Time for them to do their part” FCC Wheeler
  • Produced too late for last Sunday’s Super Bowl, check out this 30 second spot.
  • Just got the heads up that TV white spaces pioneer Adaptrum will soon launch their ACS 2.0 product line, which allows for point-to-point or point-to-multipoint operation with up to 13 Mb/s throughput using a single 6 MHz channel over a frequency range of 400 MHz to 1 GHz. From the preview this reporter has seen, this could be a great tool for an operator to extend broadband to locations that would otherwise not be economically feasible. A good primer on deployment of technology in real-world conditions can be found here.

The Korner – Building a Playground – Building a Community

An image showing the Wienermobile and the fundraising table next to it.
Click Image to Read More

Readers and viewers who follow Viodi on various social outlets may have seen some somewhat odd messages lately about dancing bunnies, wiener dogs meeting Wienermobiles and S.J. Sharkie mixing it up with a bunch of kids. Let me explain the background and the bigger picture behind these seemingly off-topic dispatches.

One of the things that inspires me about the people who work for independent communications companies in rural America is how deeply woven they are into the fabric of their communities; the technician may be the mayor, the marketing person may sit on the economic development board and the owner might be a volunteer fire fighter. As locally owned telecommunications’ companies, these businesses become sort of commercial anchors connecting their communities both electronically and physically by their employees’ presence.

In the rural areas served by my telecom friends, the economics don’t support the same level of paid employees that one finds in urban areas, so citizen volunteers are essential to a thriving community. As a result, there appears to be less of divide between the governed and the local government in rural America, as compared to urban America.

A fun video showing a hidden gem in America's heartland.
Click Image to Read More

And though income levels may vary widely in small town America, they don’t divide like they do in the urban areas. When you are in a town of 2,000 people, there isn’t much choice as to the restaurants you go to, the schools your kids attend or the church where you pray. People of different incomes are forced to live together and help each other out when disaster strikes.  Kids grow up knowing that adults are looking after them, as well as watching them to make sure they are on the straight and narrow (see Search Institute’s 40 Assets).

Click here to read what the above has to do with building a playground in the nation’s 10th largest city.

FCC's "All IP" Network Transitions Trials – What to Expect


At its January 30th Open Commission Meeting, the Federal Communications Commission  (FCC) voted to approve a petition AT&T had filed (in November 2012) to conduct trials of an “all-Internet Protocol (IP) network” that would eventually replace the PSTN and TDM networks now used extensively in the U.S.  The transition will be from plain Plain Old Telephone Service (POTS) delivered over 2 wire copper subscriber loops to feature-rich voice services using Internet Protocols, to be delivered over coaxial cable, fiber, or wireless networks. The TDM network that transports POTS and digital switched voice/data would be replaced by an IP based packet switched network.

The FCC press release on this initiative can be read here. The FCC says: “This is an unofficial announcement of Commission action. Release of the full text of a Commission order constitutes official action.”  But that FCC order has not yet been published.

Service Provider Trial Proposal Schedule and Requirements:

Described as a “set of voluntary experiments,” the FCC asked service providers to submit proposals for the IP transition trials. Such proposals are due by Feb. 20, 2014, followed by a public comment and reply period ending on March 31, 2014, with a final decision on the proposals to be made at the FCC’s May 2014 meeting.

The FCC’s evaluation of the trial proposals will be based on what it calls the “enduring values” underlying its stewardship of the nation’s communications networks:

  • Public Safety communications must be available, no matter what underlying network technology providers use;
  • Universal access so that all Americans must have access to affordable communications services;
  • Competition to ensure choices for consumers and businesses; and
  • Consumer protection: Service providers must accurately describe the terms on which they offer service and must treat consumers fairly.

The FCC hopes the trials will enable it to gather information in the following areas:

  • Service-based experiments: Providers are invited to submit proposals to initiate tests of IP-based alternatives to existing services in discrete geographic areas or situations;
  • Rural America: Experiments will focus on ways to deliver robust broadband service to rural areas. While most of the trial is focused on ILEC services, based on the news release and statements at the meeting, this component may permit competitive providers to obtain universal service funding to build broadband networks, separate from the “Connect America Fund” process under Section 254’s “Universal Service” mandate. The details of this aspect of the trial will be important, and will not be available until the formal order is released;
  • Disability access: Experiments will explore how to ensure that speech- and hearing-impaired Americans, and those with other disabilities, will continue to have access to quality communications services in an all-IP environment; and
  • Telephone numbering plan in all-IP network: a numbering test bed will address concerns raised about how to handle number assignment and the operation and maintenance of numbering databases (such as the local number portability database) in an all-IP world, without disrupting current systems.’
  • Data improvement including reform of the FCC’s consumer complaint and inquiry process to collect better data on how technological change is impacting consumer values.  Intergovernmental collaboration (state, local and tribal governments) is encouraged to better understand consumer impact. Collection and analysis of data on next-generation 911 systems in coordination with the U.S. Department of Transportation’s National 911 office and public safety associations.

The FCC stated, “The data gathered in these experiments will ensure that the ongoing public dialogue about technology transitions is based on solid facts and data. This discussion will guide the FCC as it makes complex legal and policy choices that advance and accelerate the technology transitions while ensuring that consumers and the enduring values are not adversely affected.”

What to Expect from the All IP Transition Trials:

In AT&T’s January 21st Notice of Ex Parte – IP Transition, GN Docket No. 13-5 a two stage process for service provider trials is described. In the first stage, participating carriers would file detailed plans that identify their existing TDM services, the IP network based replacements for those services; and when those IP networks would be available. As part of the first phase, the participating service provider would file petitions for authority to discontinue the affected interstate TDM based-service(s). After approval by the Commission, the provider would be permitted in the first phase of the trial to “grandfather” existing TDM services and allow existing customers to continue receiving those services, while permitting the carrier to fulfill all new orders for service in the relevant wire center using IP-based wireline and wireless alternative networks.

During Phase 2, the participating service provider could file a second application to withdraw the grandfathered interstate TDM services for existing customers. That application would identify how many customers remain for each TDM service to be discontinued and would provide a retirement plan, including the notice(s) to be provided to customers, the available wireline and wireless IP replacement services, and the timeframe for when the conversion of the wire center to all-IP services would be complete. Under this proposal, the FCC would have the opportunity to evaluate the results of the first phase of the trial before granting participating carriers approval to proceed with the withdrawal of TDM services for existing customers.

AT&T Reaction to FCC Sanctioned “All IP” Network Trials:

AT&T praised the FCC for moving forward with the IP transition experiments. The decision is “important and profound,” Jim Cicconi, AT&T Senior Vice President for External and Legislative Affairs, wrote in a blog post. “All Americans should applaud the FCC’s action, because all Americans, and generations yet unborn, will benefit from it.”

But AT&T will benefit a whole lot more. That’s because it would be alleviated of the burden of maintaining its POTs/PSTN/TDM network, which continues to lose subscribers with revenue steadily shrinking. In his blog post, Cicconi wrote, “The cost of maintaining the legacy architecture, with its rapidly declining subscriber base, was unsustainable for any company, and was pulling significant dollars away from broadband investment. That decline has only accelerated over the past fifteen months – AT&T’s consumer POTS access lines decreased from 15.7 to 12.4 million lines between 2012 and 2013, proving the truth of the FCC’s conclusions in stark numbers.”

Mr. Cicconi endorsed the FCC’s protection agenda by his closing comments:

“We need to make this transition in a way that preserves universal service, competition (including interconnection), public safety, network reliability and consumer protection. Chairman Wheeler has referred to this process as a Values Trial, and has stressed that our new IP communications system should reflect these underlying values as we transition to newer and better technologies. We agree, and are committed to work with the Commission and all other stakeholders to ensure that we preserve those values throughout this transition. We’re now embarking on a task that’s of vital importance to our Nation.  We have an obligation to do it right. And we will.”

Stay tuned for future coverage of this hugely important telecom transition initiative.


All-IP Network Transition Plan at FCC's Jan 30th Open Commission Meeting


[dropshadowbox align=”right” effect=”raised” width=”270px” height=”” background_color=”#ffffff” border_width=”1″ border_color=”#dddddd” ][/dropshadowbox]During his January 8th speech at the Computer History Museum (CHM) , FCC Chairman Tom Wheeler told the CHM audience that the U.S. was in a transition to a “4th Network Revolution” that would be led by a transition to an “all-IP” network.   The 4th Network is actually a multi-faceted revolution based on  IP based packet communications (for voice, data and video) replacing digital circuit switching and analog transmission. Communications protocols are moving from circuit-switched Time-division Multiplexing (or TDM) to IP packet switching.  At the same time, 3G and 4G wireless access networks are increasingly prevalent, empowering consumers to connect at the place and time of their choosing.

Wheeler said, “The transition to an all-IP network is important in its own right, but it also is important because it demonstrates that the Commission (FCC) will adapt its regulatory approach to the networks and markets of the 21st century.”

The FCC Chairman then said that no one would use a network without being able to make a 911 phone call (to report emergencies and seek help from law enforcement). That implies that the all-IP network must support 911 calls in a consistent manner.

From the FCC Web site, an image of FCC Chairman, Tom Wheeler
FCC Chairman, Tom Wheeler (image courtesy of FCC.gov)

Wheeler told the CHM audience:

“The best way to speed technology transitions is to incent network innovation while preserving the enduring values that consumers and businesses have come to expect. Those values are all familiar: public safety, interconnection, competition, consumer protection and, of course, universal access. They are familiar, and they are fundamental.”

Continuing, he said: “At the January 30th Commission meeting, we will invite proposals for a series of experiments utilizing all-IP networks. We hope and expect that many proposed experiments, wired and wireless, will be forthcoming. Those experiments will allow the networks, their users, the FCC and the public to assess the impact and potential of all-IP networks on consumers, customers and businesses in all parts of our country, including rural America.”

All-IP Network Topic at the FCC’s January 30th Open Commission Meeting:

The all-IP network transition will be the number one agenda item at the FCC’s January 30th Open Commission Meeting  Advancing Technology Transitions While Protecting Network Values is all about the transition to an all-IP network.  “The Commission will consider a Report and Order, Notice of Proposed Rule making, and Notice of Inquiry that invites diverse technology transitions experiments to examine how to best accelerate technology transitions by preserving and enhancing the values consumers have come to expect from communication networks.”

In a November 19, 2013 blog post Wheeler provided an overview of the all-IP network migration.  He wrote: “The way forward is to encourage technological change while preserving the attributes of network services that customers have come to expect – that set of values we have begun to call the Network Compact.”

Wheeler noted various FCC Commissioner comments in that blog post:

  • “Commissioner Pai said that the FCC should ‘Embrace the future by expediting the IP Transition.’
  • Commissioner Rosenworcel told us that, ‘As we develop a new policy framework for IP networks, we must keep in mind the four enduring values that have always informed communications law — public safety, universal access, competition, and consumer protection.’
  • Commissioner Clyburn has called upon the Commission, ‘To carefully examine and collect data on the impact of technology transitions on consumers, public safety and competition.’”

AT&T Petition and FCC Technology Transitions Task Force are encouraging trials:

On November 7, 2012, AT&T petitioned the FCC to “Launch a Proceeding Concerning the TDM-to-IP Transition,” GN Docket No. 12-353 (AT&T Wire Center Trials Petition).

That document requested the FCC to “open a new proceeding to conduct, for a number of select wire centers, trial runs for a transition from legacy to next-generation services, including the retirement of TDM facilities and offerings” and that “the Commission should also seek public comment on how best to implement specific regulatory reforms within those wire centers on a trial basis.”

AT&T requested that the FCC consider conducting trials where certain equipment and services are retired and IP-based services are offered. These geographically limited trial runs, conducted after a public comment period on how they should be carried out, would help “guide the Commission’s nationwide efforts to facilitate the IP transition.” Such an approach, AT&T notes, will “enable the Commission to consider, from the ground up and on a competitively neutral basis, what, if any, legacy regulation remains appropriate after the IP transition.”

AT&T has set a date of 2020 to retire its TDM network and has been upgrading its IP-based service capabilities in its wireline markets via Project Velocity IP (VIP).  AT&T presented a progress report on the Project VIP at the June 2013 IEEE ComSocSCV meeting.  It can be read on pages 3-4 of this article: Telco Tours & Seminars Top ComSoc-SCV Activities.

Technology Transitions Policy Task Force” which was tasked to move forward with real-world trials to obtain data that will be helpful to the Commission. The goal of any trials would be to gather a factual record to help determine what policies are appropriate to promote investment and innovation, while protecting consumers, promoting competition, and ensuring that emerging all-Internet Protocol (IP) networks remain resilient.   The FCC task force is seeking public comment on several potential trials relating to the ongoing transitions from copper to fiber, from wireline to wireless, and from time-division multiplexing (TDM) to IP based packet switched networks.

Technology Trials Proposed:

The FCC task force has proposed the following trials related to the all-IP network transition:

  • VoIP Interconnection
  • Public Safety – NG911
  • Wireline to Wireless
  • Geographic All-IP Trials
  • Additional trials: numbering and related data bases, copper-to-fiber transition, retirement of copper?

 The US Telecom Association was very supportive of such trials as well as the previously referenced AT&T petition. In comments submitted on January 28, 2013, the trade organization wrote:

“The idea that the Commission should conduct real-world trials in order to better inform itself as to the technological and policy implications of the IP-transition is a way the Commission can continue its commitment to data-driven policy making. The Commission itself has urged carriers to ‘begin planning for the transition to IP-to-IP interconnection’ and the Commission-guided trials urged by AT&T would facilitate this effort.”

“In particular, the AT&T Petition offers an opportunity for the Commission and state regulators to conduct informative, but geographically limited, trial runs for regulatory reform in discrete wire centers. AT&T correctly notes that such an approach will enable the Commission to consider, from the ground up and on a competitively neutral basis, what, if any, legacy regulation remains appropriate after the IP transition.”

US Telecom’s comments can be read here.

Important Unanswered Issues for an all-IP network:

Transition to an “all-IP” network implies retiring the PSTN/POTs, TDM/circuit switching and all wireless networks other than 4G with VoIP over LTE. That is a huge undertaking that will be incredibly disruptive and take many years, if not decades, in our opinion.  Here are just a few points to ponder about this monumental transition:

  • Telcos and MSOs must universally deploy broadband for wireline VoIP to be ubiquitous. Currently, they make their deployment/build out decisions strategically- based on reasonable ROI.  Not every area in the U.S. has or will have wired broadband as a result.
  • Many rural areas have little or no wireless coverage and certainly not 4G-LTE.  What happens to people who live in those areas, e.g. Arnold, CA?
  • Even if wired or wireless broadband is available in many regions, there is likely to be only one or two network providers at most.  Hence, there is little or no choice in service which is effectively a monopoly. Santa Clara, CA is in the heart of Silicon Valley, yet we now have only two choices for wired broadband – AT&T or Comcast.
  • There is currently no Universal Service Fund/Lifeline or discounted rate (for low income folks) for VoIP service.  Lifeline service is ONLY available for the PSTN/POTS.
  • If an individual or family doesn’t want or can’t afford high speed Internet and/or broadband TV service, then it will most likely be uneconomical for the Telco/MSO to ONLY provide VoIP service over broadband access. This is the case for many poor people and older Americans!
  • Battery backup is required for an all-IP network to make emergency phone calls when power is lost.  There is a substantial monthly charge for a battery backup box for AT&T’s U-Verse VoIP service. An AT&T subscriber must also have battery backup power for the Wi-Fi gateway to enable your AT&T U-verse services to function during a power outage.
  • There will be a huge impact on business customers that use digital circuit switched networks if the proposed all-IP changes happen soon in the affected areas or “wire centers.” What if a company’s main or branch office site(s) are located in an all-IP wire center coverage area?  In that case, the business customer would have to give up it’s digital PBXs or hosted ISDN PRI voice trunks and move to SIP trunks–even though the company is not nearly ready for a total enterprise-wide transition to an IP voice network.
  • What happens to faxes, which are still overwhelmingly based on the analog PSTN and not IP fax? The death of fax has been predicted for over a decade, yet it is still alive and kicking!
  • There will be a huge impact on business customers that use digital circuit switched networks if the proposed all-IP changes happen soon in the affected areas or “wire centers.” What if a company’s main or branch office site(s) are located in an all-IP wire center coverage area?  In that case, the business customer would have to give up it’s digital PBXs or hosted ISDN PRI voice trunks and move to SIP trunks–even though the company is not nearly ready for a total enterprise-wide transition to an IP voice network.
  • The transition from the classic PSTN to an all IP infrastructure will mandate the end of Signaling System 7 and the entire infrastructure that supports it. This is a substantial undertaking, the consequences of which are not fully understood. Can SS7-based functions be replicated on a broadband IP-based network? What would be the equivalent of a “voice grade” circuit? Is a SIP connection a functional equivalent for the key functionalities of SS7 switches? What about SMS/texts?
  •  The telephone numbering system provides a way for callers served by virtually any service provided in the world to reach one another. What will replace that system has yet to be determined. It surely won’t be an IP address which is often dynamic and allocated for temporarily reaching IP endpoints.
  •  Interconnection and Inter-operability between IP and TDM networks is a work in progress-for both voice and data.
  •  Quality of Service/Reliability/Resiliency is largely unknown with an all IP network, which would need to scale to replace and reach all PSTN/TDM endpoints. What would constitute an “outage,” and how should “outage” data be collected and evaluated? Here again, the battery back-up on power fail would need to be made mandatory and low cost or no cost to consumers and enterprises.

For sure, the above issues will challenge equipment vendors, regulators, business and consumers. We think the transition from PSTN/TDM/digital circuit switched to an all-IP packet network will take much, much longer than many expect.

Net Neutrality Ruling – The Beginning of the End or the End of the Beginning?

In his January 8th speech at the Computer History Musuem (CHM), F.C.C. Chairman Tom Wheeler said we were in the midst of a transition to a “4th Generation Network” which had an “Open Internet” as it’s foundation. The concept of net neutrality– where there are no privileges or added costs or special deals for high bandwidth media/content delivery companies- was clearly implied.

”Not unlike how the radio stations of the 1920s needed to be protected from technical interference, today’s entrepreneurs need to have a fair opportunity to reach their customers over the biggest technological channel of them all—the Internet,” Wheeler said during his prepared remarks at the CHM.

”No one in Silicon Valley needs to be convinced of the importance for innovation and overall societal welfare of our broadband networks. Keeping them open for any and all lawful uses is a major policy imperative.  It is essential in the public interest of our
country that the government, and by government I mean the FCC, have the power to oversee the broadband networks and to intervene to forestall their exploitation by unacceptable acts,” Wheeler added.

That Open Internet policy is now in jeopardy. On January 14th a federal appeals court tossed out the FCC’s Open Internet rules, permitting Internet Service Providers (ISPs) to make deals with streaming media and web content companies (Netflix, Amazon, Apple, or Google) for faster content delivery at a higher price.

The US Court of Appeals for the DC Circuit ruling stated that the FCC’ s Open Internet Order is invalid and that the regulator had overstepped its authority when (in 2010) it classified broadband as an ‘information service,’ not a ‘telecommunications service.’  Having done that, the FCC could not then impose its “anti-discrimination” and “anti-blocking” rules on ISPs, the court ruling stated.

The court stated: “Even though the Commission has general authority to regulate in this arena, it may not impose requirements that contravene express statutory mandates. Given that the Commission has chosen to classify broadband providers in a manner that exempts them from treatment as common carriers, the Communications Act expressly prohibits the Commission from nonetheless regulating them as such. Because the Commission has failed to establish that the anti-discrimination and anti-blocking rules do not impose per se common carrier obligations, we vacate those portions of the Open Internet Order.”

The FCC had tried to prevent those deals, saying they would give large, rich content/media companies an unfair edge in reaching consumers. But since the Internet is not considered a utility under federal law, the court said, it is not subject to regulations banning such arrangements. That paves the way for ISPs like Verizon to cut a deal with Netflix, Amazon or other content providers for higher speed Internet delivery services.

For consumers, the ruling could usher in an era of tiered Internet service, in which they get some content at full speed while other websites appear slower because their owners chose not to pay up.

According to the NY Times broadband Internet providers (like Verizon) that have spent billions of dollars building their networks, said the ruling confirmed their right to manage their networks as they saw fit.

“Verizon has been and remains committed to the open Internet, which provides consumers with competitive choices and unblocked access to lawful websites and content when, where and how they want,” the company said in a statement. “This will not change in light of the court’s decision.”

Much of the argument over net neutrality has been theoretical. Verizon noted in its court papers that the F.C.C. documented only four examples over six years of purported blocking of Internet content by service providers. The issue came into focus in the agency’s review of the purchase of NBC Universal by Comcast. As a condition of approving the deal, the F.C.C. made Comcast promise that it would abide by the Open Internet rules for seven years, even if the rules were modified by the courts.

Consumer advocates warned that higher costs to content providers could be passed on to the public, and called the ruling a serious blow against the concept of a free and opens Internet. “It leaves consumers at the mercy of a handful of cable and phone providers that can give preferential treatment to the content they profit from,” said Delara Derakhshani, policy counsel for Consumers Union.

“I would not be surprised if business development folks in ISP’s around the country were now looking for ways to partner with content creators,” said Michael Weinberg, acting co-president of Public Knowledge, a consumer advocacy group. The companies’ goal is “to make sure their unpartnered service is bad enough that a paid partnership is attractive.”

“It takes the Internet into completely uncharted territory,” said Tim Wu, a Columbia University law professor who coined the term “net neutrality.”

Mr. Wheeler said the FCC might appeal the ruling. In a statement, he wrote that he was “committed to maintaining our networks as engines for economic growth, test beds for innovative services and products, and channels for all forms of speech protected by the First Amendment.” He added, “We will consider all available options, including those for appeal, to ensure that these networks on which the Internet depends continue to provide a free and open platform for innovation and expression, and operate in the interest of all Americans.”

A January 15th NY Times editorial called the ruling “a disappointing Internet decision.” 

“If this ruling stands, broadband providers would be free to strike deals with companies like Netflix and Apple to pay to have their movies, software and other data streamed to customers faster than or ahead of other content. Such deals would hurt smaller businesses or start-ups that cannot afford to pay for preferential treatment.”

“Ideally, Congress would pass a law prohibiting broadband companies from discriminating or blocking content, but that is unlikely to happen given industry opposition. That’s why it’s important for the commission to reclassify broadband as a telecommunications service.”

Craig Aaron of Free Press told PBS he was very much against the court ruling.

“I really think this court decision puts at risk so much of what we love about the Internet. With these rules being invalidated, it really leaves consumers at the mercy of phone and cable companies, who are now free to block websites if they want to, interfere with traffic, favor certain sites and services over other sites and services. And I think that’s bad news for the average Internet user, that the agency that is supposed to be protecting them has been told it has no oversight of the most important communications network of the 21st century.”

But not everyone dissented. Former F.C.C. Commissioner Robert M. McDowell (who voted against adopting the Open Internet rules in 2010) told the WSJ: “The Internet was working beautifully before these rules were implemented. It will thrive even more now that they have been struck down. In the meantime, ample laws already exist to protect consumers should market failures occur.”

CNET is attempting to gauge public perceptions of the new network neutrality rules by conducting a poll:  “How concerned are you about Net neutrality? The FCC’s Net Neutrality rules got wiped out in a court ruling, leaving some people unimpressed and others predicting Internet Armageddon.” You can read all about it and cast your vote here 

Stay tuned for a follow up article that will preview the F.C.C.’s January 30th open commission meeting, which will cover topics described in this meeting announcement.

Those issues will be contrasted with the policy agenda Mr. Wheeler described during his January 8th CHM speech.

FCC Delays Reverse Auction till 2015; Spectrum Aggregation & Ownership Limits?

The Federal Communications Commission (FCC) has delayed the “Broadcast Television Spectrum Incentive Auction” until 2015.  FCC Chairman Tom Wheeler published a blog post Friday announcing the delay, saying he hopes the auction will take place in mid-2015.  The FCC had set a goal of completing the auction in 2014 and we thought this would be the top priority for the new FCC Chairman.

Wheeler wrote: “I believe we can conduct a successful auction in the middle of 2015.  To achieve that goal, there will be a number of important milestones along the way.  The Task Force will provide more details about the timeline and milestones in a presentation at the January 2014 Commission meeting.”

When the auction is finally held, TV stations will consider bids to relinquish their licensed spectrum and either go out of business or obtain another frequency slot (i.e. TV channel). The licensed spectrum will then be put up for bid by wireless carriers, who covet the low-frequency airwaves because they can cover greater distances and travel more easily through physical barriers.

Observers have called the spectrum auction the most complex proceeding ever undertaken by the FCC. Mr. Wheeler said he has spent more time reviewing the incentive auction than any other issue since taking office, and determined it would be best to wait in order to ensure success. He hopes to avoid any technical difficulties with the software that will be used for the auction and “get it right.”

“I am also confident that the policy challenges are only part of the picture; we must also get the enabling technology right,” he wrote.

Because AT&T Inc. and Verizon Wireless control most of the spectrum under one gigahertz, the auction is considered particularly crucial for T-Mobile US Inc. and Sprint Corp. because it represents a rare opportunity to obtain low-band spectrum.  The 700 MHz band has been dubbed “beachfront property,” because of its excellent propagation characteristics.

“While AT&T is eager to see new spectrum allocations brought to market as soon as practical, we appreciate the enormity of the task the commission faces,” said Joan Marsh, vice president of regulatory affairs at AT&T.

Public interest groups and the smaller wireless firms have lobbied the FCC to set auction rules that would prevent AT&T and Verizon Wireless from grabbing up all the low-band spectrum at the auction. Mr. Wheeler has hinted that he is open to such limitations, but has yet to tip his hand one way or another.

There is also considerable pressure on the FCC to maximize revenue from the auction. The proceeds will be used to compensate broadcasters and fund a $7 billion public safety communications network known as FirstNet.  “This entire Commission is also acutely aware of the importance of the auction to fund FirstNet,” Wheeler wrote.

It’s unclear whether enough TV broadcasters will participate in the auction, which is voluntary. Stations affiliated with the Big Four networks (ABC, CBS, NBC, Fox) aren’t expected to, leaving smaller, independent  TV stations as the most likely participants.  Whether those stations will yield enough spectrum for the auction to be deemed a success remains to be seen.  Another issue is that if the FCC limits bids from AT&T and Verizon, that could depress the prices paid for the airwaves, resulting in less revenue.

Click here for a complete description of the Broadcast Television Spectrum Incentive Auction.

A related FCC spectrum concern is whether the commission will permit AT&T and/or T-Mobile to bid for Verizon’s 700Mhz spectrum that may be put up for sale. AT&T already holds the rights to adjacent 700MHz spectrum, and certainly has the cash to buy Verizon’s if it is put up for sale.  T-Mobile operates its network primarily in the 1900MHz and AWS (1700/2100MHz) frequencies, so the 700MHz spectrum is much more valuable than what they now hold. T-Mobile has targeted AT&T in its marketing in an effort to get customers to bring their phones to its network—and has successfully reversed a long streak of subscriber losses.

Availability of 700MHz spectrum is limited, and regulators have suggested there should be caps placed on ownership so that it isn’t monopolized by industry leaders Verizon and AT&T, which already own roughly 75% of the low-band spectrum currently in use by wireless carriers. In April, the Obama administration’s antitrust team had urged the FCC  to develop auction rules that ensure that T-Mobile US and Sprint are able to buy some of the prime airwaves and better compete nationally with their  two larger rivals.

The F.C.C. already enforces rules limiting “spectrum aggregation.” In theory, the FCC’s spectrum screen prevents further acquisition once a company goes above 33% of the licensed airwaves in one market area. But it applies that limit on a case-by-case basis, usually when one company buys another and asks to transfer ownership of the spectrum licenses.  Although it relies on general guidelines, the rules are unique to every individual transaction. Spectrum deals that violate the FCC’s screen are viewed much more closely by regulators.

After regulators rejected AT&T’s bid to acquire T-Mobile,  AT&T has lobbied the commission for a review on how to measure spectrum.  On the other hand, T-Mobile and  Sprint Corp have argued for ownership limits on lower band spectrum.  The FCC has not decided on any of this yet.