January 11, 2017
The United States Telecom Association (“USTelecom”) is pleased to submit its comments in response to the Commission’s Public Notice (“Public Notice”) seeking comment, suggestions and feedback on Commissioner Mignon Clyburn’s #Solutions2020 Call to Action Plan. In the Public Notice, Commissioner Clyburn sets forth all of the ideas and topic areas pitched during an October 2016 policy forum where stakeholders gather to provide their thoughts on the toughest challenges facing the communications sector in the next four years. USTelecom applauds Commissioner Clyburn for her work in addressing these issues. It is precisely this forward-looking innovation agenda that better serves consumers in the telecommunications marketplace. Incenting investment in fiber and IP technologies, reducing costs and streamlining the acquisition and use of rights-of-way, removing outdated regulations that do not serve consumers but instead serve only to reduce competition and innovation will all help accomplish this forward-looking agenda.
The #Solutions2020 Call to Action Plan addresses general and specific areas which serve to ensure the spread of broadband technology to all parts of our country. Several of the action items such as health related services and inmate calling services meet targeted needs of specific sectors of the nation, while other action items such as empowering communities and spreading 5G impact our country as a whole. USTelecom supports all of these areas as an opportunity for growth in the industry and seeks to ensure an understanding that at the foundation for all of these worthwhile initiatives is the need for the deployment of ubiquitous fiber. The nation’s wired broadband infrastructure is a critical component of our wireless freedom.
Many don’t realize that virtually every wireless device ultimately travels over the nation’s wired infrastructure. Current widespread use of mobile broadband significantly relies on the broadband infrastructure backbone. Once you get home with your smartphone or tablet, chances are you connect to your Wi-Fi network to access the internet. With data gathered from July 2016, Sandvine reports that 10 device classes across four major platforms generate nearly three quarters (73.4 percent) of fixed-access broadband traffic (downloads and uploads) in North American households. No matter what the connected device—PCs, mobile devices, gaming consoles or OTT boxes—streaming movies, TV shows and all other forms of audio and video generate the largest share of traffic on a home’s fixed broadband network. So when the Commission seeks to undertake a mission to expand wireless broadband, maintaining and investing in our nation’s wired networks to connect today’s cell sites and tomorrow’s small cells is more critical than ever.
The Public Notice specifically mentions the move from already robust and in high-demand 4G wireless technologies to a new age of 5G connectivity that will be inclusive and ensure that those living in rural and low-income areas are a part of this new frontier. As the move toward 5G technology picks up speed, now is the time to consider how it will impact the broadband infrastructure. In a competitive marketplace, ultra-fast broadband connectivity is a key differentiator, and 5G development and trials are underway. Several of USTelecom’s member companies are actively engaged in building all digital network infrastructures that can support next-gen wireless broadband technologies. AT&T shared its plans to begin field trials for 5G in Austin, Texas before the end of the year. The company expects 5G will deliver speeds 10 to 100 times faster than 4G LTE, which is a part of AT&T’s longer-term innovation strategy to support broad-ranging advances that benefit consumers and their communities. Verizon has also announced an aggressive timeline for its 5G field-testing and deployment efforts, aiming to launch part of its 5G network by 2017, far ahead of the 2020 arrival date marketplace analysts have been predicting for the launch of this technology. There is clearly a sense of urgency to push forward on 5G and usher in a new generation of innovation.
This next wave of ultra-high speed gigabit broadband expansion coincides with a report profiled in Telecompetitor, indicating that subscribers to super-fast broadband service surpassed the 300 million mark in mid-June 2015, and will possibly reach 50 billion broadband connections by 2020. Higher speeds will help support growing bandwidth demands resulting from data-heavy consumer Internet use and the billions of connected devices expected to use these networks. While 5G speeds will fluctuate based on a variety of factors ranging from signal strength to network congestion to location-specific variables (i.e., trees, buildings), Verizon predicts its 5G technology will have 50 times the capacity of its 4G network and tests have shown speeds 40 times faster than 4G. This means, for example, that a 3-D movie will download in 6 seconds on a 5G network compared with 6 minutes for 4G. Because of this growth, it is more important than ever to ensure that the broadband infrastructure continues to expand to new communities and can respond to new technologies and uses as they develop.
Commissioner Clyburn also makes special mention of broadband as the driver of improved health related services. From health to education and the environment, broadband provides consumers with deep and far-reaching opportunities, enhancing overall quality of life in many respects. Broadband-enabled health care is considered by many to be the next great frontier of American medicine. High-speed transmission capability in particular has generated efficiencies such as faster patient diagnoses, reduced medical errors, and additional control over skyrocketing patient care costs. These gains benefit Americans at both a financial level (reduced annual out-of-pocket expenses) and a personal level (enhanced access to online health information). Just like the rest of the wireless applications discussed throughout the Public Notice, these telemedicine applications that use wireless technology rely on a fiber backbone.
One of the most important ways to ensure that fiber deployment goes unimpeded is to remove or forbear from burdensome regulation. USTelecom was successful in achieving forbearance from several outdated regulations when the Commission granted portions of the Modernization Petition. At issue in that Petition were regulations that pre-date many major technology and competitive transitions in the telecommunications marketplace. Their removal was necessary to free up resources that can be devoted to new broadband networks and services. USTelecom was pleased with the grant of forbearance where it was issued, but notes that there is still much work to be done to free up broadband providers from regulations that impede deployment.