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Expert Opinion

Forbes Mercy Including Fixed Wireless in the USF Discussion



WASHINGTON, DC October 24, 2011 –

Forbes Mercy, President of Washington Broadband Inc and WISPA VP/ Legislative Chair shared some thoughts and comments with after our panel on “Bringing Broadband Infrastructure to Rural Areas: Where is the Progress?”

You can watch the video of the panel or check out Broadband Breakfast’s summary below:

“Our first goal was to remind those attending that Fixed Wireless is the often forgotten delivery method of Internet to more rural areas than any other solution of high speed Internet.  Many of our providers, all small business owners first introduced the Internet to their communities.  There are over 2000 Wireless Internet Service Providers (WISP’s) servicing more than 2 million customers throughout all 50 states.  We are represented by

the Wireless Internet Service Providers Association (WISPA).

WISP’s ignore the corporate density matrix used by major carriers who seek 1000-3000 homes per square mile often going as low as 10 to 20% of the statewide households per square mile.  WISPA has worked to use NTIA data to provide a visual map of 21 states to date showing in some cases such as Texas that 75% of the area with homes as few as 10.48 per square miles were being served exclusively by Fixed Wireless Broadband Providers. The use of this data will provide clarity and credibility in preventing federally funded aid to competitors in the form of grants or USF when an existing provider is already incumbent.

WISP’s have speeds in excess of the National Broadband Plan in most cases and should not be discounted when counting underserved or unserved areas because we are not corporate giants.

Spectrum is being sought by mobile and fixed wireless providers. Mobile equipment is over 100 times more expensive than fixed and thus fixed can be deployed much more quickly in rural areas with a faster Return on Investment which leads to lower monthly costs and deeper expansion into rural areas.  Using a narrower low power band it is more
efficient to allow contiguous space to the Fixed providers who are already deployed in many of the areas currently considered unserved.”

As Deputy Editor, Chris Naoum is curating expert opinions, and writing and editing articles on Broadband Breakfast issue areas. Chris served as Policy Counsel for Future of Music Coalition, Legal Research Fellow for the Benton Foundation and law clerk for a media company, and previously worked as a legal clerk in the office of Federal Communications Commissioner Jonathan Adelstein. He received his B.A. from Emory University and his J.D. and M.A. in Television Radio and Film Policy from Syracuse University.

Expert Opinion

Dmitry Sumin: How Can Operators Minimize Blocking Legitimate Traffic While Preventing Fraud?

Blocking the entire compromised originating or terminating ranges of voice traffic leads to unnecessary losses.



The author of this Expert Opinion is Dmitry Sumin, Head of Products at the AB Handshake Corporation.

It’s no surprise to both telecom professionals and customers that calls to certain Pacific Island countries, such as Vanuatu, are blocked for calls from many mobile networks. How did it come to this?

The reason for this massive inconvenience for customers is that fraudsters often use high-cost call destinations for various kinds of schemes. In such fraud scenarios, fraudsters hijack calls and direct them to their own or leased lines to profit from businesses or individual subscribers. Short-stopping, Private Branch Exchange hacking, Wangiri and Wangiri 2.0 calls, and callbacks are a few examples of these fraud schemes.

Operators face a storm of trouble tickets and disputes due to fraud, so they prefer to block these high-cost call destinations altogether. The percentage of fraudulent traffic to these destinations is very high compared to legitimate traffic.

Widespread industry use of fraud number databases leads to the approach of blocking entire country codes. Credible organizations and regulators, such as GSMA, CFCA, TUFF and BEREC, provide such databases. These databases are also sold commercially and operators often block the full number ranges listed in these databases.

Fraudsters now use allocated and live numbers

However, there’s a problem. Fraudsters don’t just conduct attacks by using unallocated numbers which have not been assigned to a specific service provider. They now use more and more allocated number ranges, with some numbers even assigned to real customers. An allocated number is a number that belongs to a network operator under a national numbering plan.

Previously, operators could just block unallocated numbers used in fraud attacks and prevent fraud without affecting legitimate traffic. This is no longer possible. In fact, our team has estimated that more than 75 percent of fraud attacks come from and to allocated number ranges. Moreover, 50 percent of the numbers in those ranges are assigned to real subscribers.

It’s clear that when allocated number ranges are blocked, legitimate traffic gets blocked as well. This leads to revenue loss, dispute tickets from customers and customer churn.

The issue with the current blocking process

Before discussing the new approach to blocking fraud, let’s look at the main stages of the aforementioned fraud attacks that use call hijacking. First, the fraudster gains access to the originating A number range, for example, by hacking a corporate PBX. Then the traffic from this compromised range to specific terminating B ranges gets short stopped. This means that the call is hijacked to an expensive destination country. The hackers and the rogue carriers share the revenue generated by the fraudulent calls, which are billed to the end customer or another carrier in the routing flow.

If we block the entire originating A range, we will lose legitimate traffic to other destinations. And if we block the terminating B range, then we will also block the legitimate traffic coming from non-fraudulent A numbers, as in the case of blocking the country codes of Pacific Island nations.

The new approach: Granular blocking of A and B ranges for the duration of the attack

As you can see, blocking the entire compromised A or B range leads to unnecessary losses. How can we improve our approach to stopping fraud so that legitimate traffic is unaffected?

Our practice at AB Handshake shows that this can be done by introducing two adjustments to the blocking process. First, once an attack is detected, you should only block the traffic from the compromised A range to the compromised B range. Second, the ranges should be unblocked immediately after the attack is over.

This new approach allows service providers and transit carriers to avoid excessive blockages and minimize revenue losses while preventing fraud. But to realize this new approach, there has to be a specific fraud detection process. However, not every anti-fraud tool is capable of this. Let’s see what features an anti-fraud tool must have to achieve this.

Maximum granularity and accuracy of detection

If the tool is to detect only the compromised A and B ranges without affecting legitimate traffic, it has to offer maximum granularity of detection. This requires the highest possible accuracy in detection. An important term to understand here is “false positive,” which is a false indication of fraud when it isn’t present. In our case, regular and valid traffic could get mistakenly marked and treated as fraudulent. The anti-fraud tool must employ the latest technology, such as artificial intelligence and machine learning, to provide the highest detection accuracy and maximum granularity.

Detection speed

The most important aspects of a real-time approach are constant monitoring of live traffic and the speed of fraud detection. Ideally, the time frame between detection and response should be close to zero. This means that the least amount of fraudulent calls will get through. The solution should also detect the end of the attack with maximum speed so the ranges can be unblocked immediately to avoid revenue loss.

Real-time control

The anti-fraud solution must be integrated with the operator’s network control components on a signaling level. This ensures it can block the compromised ranges immediately when the attack starts and unblock them exactly when it’s over.

Advanced anti-fraud tools are a must

To satisfy all of the criteria above, the anti-fraud solution must use the latest technology available. One example is the call validation technology, which works on a call-by-call basis and has 100 percent detection accuracy of all known fraud types. Another option is using an anti-fraud tool with an AI engine. Such tools employ machine learning algorithms and offer up to 99 percent fraud detection accuracy.

A low-cost alternative to AI-powered tools would be the widespread adoption of real-time API solutions. Such APIs send real-time alerts when an attack is detected. The big data included in such alerts comes from hundreds of networks worldwide monitored by an AI anti-fraud tool. This alert shows the compromised A and B ranges and the types of fraud schemes they are used for. The API will also notify operators when the attack is over so they can unblock the ranges safely and avoid revenue loss.

A solution in times of crisis

At a time when the volume of international voice traffic and the revenue it generates is falling globally because of the competition from WhatsApp, Viber and VoIP services, the issue of telecom fraud is especially troublesome. Fraudsters have become more and more adept at masking their attacks as legitimate traffic, so it is no longer enough just to block ranges from databases. Blocking fraud must now be done with maximum accuracy and granularity to avoid the disruption of legitimate traffic and the resulting loss of revenue.

The new approach of blocking the compromised A and B ranges only for the duration of the attack will help operators minimize unnecessary losses while effectively preventing fraud. The first step is to have the right anti-fraud tool for this task. Thankfully, the rapidly advancing technology used by anti-fraud vendors is already capable of realizing this new approach.

Dmitry Sumin is head of products at the AB Handshake Corporation. A graduate of the Moscow State University, he has over 15 years’ experience in international roaming, interconnect and fraud management. Having previously worked for both MNO and MVNO/MVNE operators, he has a good understanding of different technologies and business models within the telecommunications market. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to The views reflected in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Broadband's Impact

Lindsay Mark Lewis: As Inflation Spiked, Broadband is ‘The Dog That Didn’t Bark’

Why have internet prices remained constant while demand surges? It all boils down to investment.



The author of this Expert Opinion is Lindsay Mark Lewis, executive director of the Progressive Policy Institute.

There are many lessons to be learned from last year’s midterms, but Democrats should not take the results as some broad endorsement of the economic status quo. Midterm voters identified inflation as the most important issue driving their votes. And while the latest Labor Department data shows the producer price index decreasing by 0.1% in February, prices remain 4.6% higher than a year ago, which means lawmakers still have work to do to bring inflation under control.

And as they search for ideas, they may want to examine the dog that didn’t bark – in particular, the one sector of the economy that has been an interesting counternarrative to the otherwise troubling inflation story.

Home internet service is one of the few major living costs that isn’t skyrocketing. In fact, the most popular broadband speed tier one year ago actually costs 15% less today, on average.

This success story – and the bipartisan policies behind it – offers important lessons.

Remarkably, broadband prices are declining even as demand surges. The pandemic made home internet service more essential than ever for education, job opportunities and health care – all driving internet traffic 25% to 50% above pre-pandemic levels.

So why have internet prices remained constant – even declined by some measures – while demand surges? In short, it all boils down to investment.

When the pandemic cratered economic activity in the spring of 2020, executives in many industries – from lumber to oil refineries to computer chips – made the snap decision to pull back on long-term investments in new factories and manufacturing capacity. When the economy roared back, those industries couldn’t meet demand, sending prices soaring.

In the broadband industry, conversely, providers responded by investing $86 billion into their network infrastructure in 2021 – the biggest one-year total in nearly 20 years. These investments are fueling faster speeds – fixed broadband speeds are up 35% nationwide in the past 12 months – while making sure networks have the capacity to handle growing traffic needs.

This teaches us three things.

First, we should observe a Hippocratic oath and “do no harm.” America’s broadband system has thrived under a decades long bipartisan consensus for light-touch, pro-investment policies. Nearly $2 trillion in private capital built the networks that now deliver American consumers higher speeds at lower per-megabit prices than consumers enjoy in Europe, despite having to cover greater distances and more difficult terrain.

This further tells us that it’s precisely the wrong time to abandon this successful model in favor of price controls and utility-style regulation, as some House and Senate progressives have proposed. Even Democratic policy experts acknowledge that approach would be toxic for private investment.

Second, policymakers need to recognize that broadband isn’t immune from the supply chain crunches plaguing so many other sectors of the economy. Broadband buildouts are already getting delayed by shortages in fiber cable, network hardware and skilled labor. And that’s before $42 billion in federal infrastructure funding goes out the door starting next year, which will only intensify demand for these scarce supplies.

That means rural buildout projects funded by federal dollars are likely to see inflationary pressures – and take longer to complete – than Congress expected when it passed the infrastructure bill in 2021. That will put pressure on state broadband offices to be even more diligent about waste, and to emphasize reliable supply chains with experienced network builders. Bidders will also need the flexibility to buy fiber from wherever they can manage to source it, even if that means relaxing the program’s strict “Buy American” rules. This requires a regulator ability to do smart tweaking of rules to expedite buildouts cost-effectively.

Third, we need to help more financially struggling households get connected. Thanks to President Joe Biden’s Affordable Connectivity Program – and an agreement with 20 broadband companies – 48 million households can now get home internet service for free.

But more than a year later, just over a third of eligible households have signed up. Investing in enrollment campaigns and digital literacy training programs is the fastest way we can crank up the dial on enrollment. Relatively small investments here could pay huge dividends in bringing millions more Americans into the digital economy.

Even with these remaining challenges, the overall contours of American broadband policy – encouraging investment, competition and affordability – are working well. And as the saying goes: “If it ain’t broke, don’t fix it.” In an inflation-roiled economy that defies easy answers, we should learn from – not mess with – this all-too-rare success story.

Lindsay Mark Lewis is executive director of the Progressive Policy Institute. Contact him at This piece was originally published in the Richmond Times on March 24, 2023, and is reprinted with permission.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to The views reflected in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Expert Opinion

David Strauss: How Will State Broadband Offices Score BEAD Applications?

Fiber, coax and fixed wireless network plans dependent on BEAD funding demand scrutiny.



The author of this Expert Opinion is David Strauss, Principal and Co-Founder of Broadband Success Partners.

Given the vital ways in which access to broadband enables America, adequate Internet for all is a necessary and overdue undertaking.  To help close the digital divide, the Infrastructure Investment and Jobs Act includes $42.5 billion in Broadband Equity, Access and Deployment funding for the last mile. Add to this the estimated level of subgrantee matching funds and the total last mile figure rises to $64 billon, according to the BEAD Funding Allocation and Project Award Framework from ACA Connects and Cartesian.

The federal funds will be disbursed by the Department of Commerce’s National Telecommunications and Information Administration to the State Broadband Offices who will then award subgrants to service providers. On June 30, each state will find out their allocation amount. By 2024, the states will establish a competitive subgrantee process to start selecting applicants and distributing funds.

A critical element of the selection process is the methodology for scoring the technical merits of each subgrantee and their proposal. Specific assessment criteria to be used by each state are not yet set. However, the subgrantee’s network must be built to meet these key performance and technical requirements:

  • Speeds of at least 100 Megabits per second (Mbps) download and 20 Mbps upload
  • Latency low enough for “reasonably foreseeable, real-time interactive applications”
  • No more than 48 hours of outage a year
  • Regular conduit access points for fiber projects
  • Begin providing service within four years of subgrant date

What level of scrutiny will each state apply in evaluating the technical merits of the applicants and their plans?

Based on our conversations with a number of state broadband leaders, the answers could be as varied as the number of states. For example, some states intend to rigorously judge each applicant’s technical capability, network design and project readiness. In contrast, another state believes that a deep upfront assessment is not needed because the service provider will not receive funds until certain operational milestones are met. Upon completion, an audit of the network’s performance could be implemented.

We, at Broadband Success Partners, are a bit biased about the level of technical scrutiny we think the states should apply. Having assessed over 50 operating and planned networks for private sector clients, we appreciate the importance of a thorough technical assessment. Our network analyses, management interviews and physical inspections have yielded a valuable number of dos and don’ts. By category, below are some of the critical issues we’ve identified.

Network Planning & Design

  • Inadequate architecture, lacking needed redundancy
  • Insufficient network as-built diagrams and documentation
  • Limited available fiber with many segments lacking spares

Network Construction

  • Unprotected, single leased circuit connecting cities to network backbone
  • Limited daisy-chained bandwidth paths on backhaul network
  • Lack of aerial slack storage, increasing repair time and complexity

Network Management & Performance

  • Significant optical ground wire plant, increasing potential maintenance cost
  • Internet circuit nearing capacity
  • Insufficient IPv4 address inventory for planned growth


  • Obsolete passive optical network equipment
  • Risky use of indoor optical network terminals in outdoor enclosures
  • Sloppy, untraceable wiring

Technical Service / Network Operations Center

  • Technical staff too lean
  • High labor rate for fiber placement
  • Insufficient NOC functionality

While the problems we uncover do not always raise to the level of a red flag, it happens often enough to justify this exercise. Our clients who invest their own capital in these networks certainly think so. The same should hold true for networks funded with taxpayer money. Fiber, coax and fixed wireless network plans dependent on BEAD funding demand serious scrutiny.

David Strauss is a Principal and Co-founder of Broadband Success Partners, the leading broadband consulting firm focused exclusively on network evaluation and technical due diligence. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to The views reflected in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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