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Michael O’Rielly: Substantive Objections to a Government 5G Wholesale Network

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Over the last few months, various ideas have been floated about the offering of 5G wireless services via a government-sponsored network. This entire effort seems convoluted and borders on the preposterous. Just the notion of the U.S. moving away from the highly-successful, private-sector led approach that is responsible for our country’s premier position globally would be a serious misstep. In essence, it would throw a monkey wrench into one of the greatest success stories in the history of technology. At the same time, it has been nearly impossible to nail down with any granularity what exactly is being contemplated by this new “network.” To call this effort a trial balloon is insulting to balloons, as all the ideas mentioned have far less consistency than balloons, and more closely resemble a child’s bubbles. Based on what we do know, however, the entire effort is jam-packed with insurmountable problems.

Accordingly, I’ve attempted to expose a few of the issues that someone trying to create a government-sponsored 5G network would face – no matter how it was structured – and explain why it doesn’t make logical sense. Perhaps all the rhetoric and lobbying in favor of this scheme will end once people examine some straight facts and salient arguments.

No Available Spectrum Bands

In an ever-increasingly wireless world, each megahertz is being strenuously fought over. Any effort to repurpose a commercial band to new and different uses, such as this proposed network, will not occur without a huge fight (consider, e.g., C-Band discussions). Moreover, the “easy” bands to convert for advanced wireless services have already been allocated. With that avenue essentially closed, the concept being bandied about is that this new network would be “given” spectrum from the Department of Defense’s (DoD) holdings. The most likely DoD frequencies that could be used for this purpose would be in the 3 GHz band, but DoD has already thrown up multiple roadblocks to any commercial activity in these bands as a threat to its mission. I know this well, as I’ve been advocating for a complete reallocation of the 3.45 to 3.55 GHz and portions of the 3.1 to 3.45 GHz bands for commercial use. Without spectrum, there is zero chance that such a network could even function, much less succeed. Not to mention, true 5G will require low-, mid- and high-band spectrum, so it is unlikely that this nationwide network would ever be able to realize the capacity, speeds, and latency of 5G.

Even if there were some magical band that DoD would make available, federal government agency spectrum cannot be used to offer commercial services. Therefore, the minute a commercial entity tried to use the government-sponsored wholesale network to offer services, the network and any users – not to mention the DoD – would be in violation of the law and numerous FCC rules. Good luck trying to get a private company to commit to use this wholesale network when it would be immediately subject to cease and desist orders and potential penalties from the Commission, especially since the Chairman and all Commissioners have loudly objected to this wholesale network concept from the outset. And, that is even if we get to this point, because multiple lawsuits would be filed that would bring these plans to a halt immediately. Additionally, there seems to be a very low likelihood that Congress will change the underlying laws and regulations, as relevant legislative efforts in play (e.g., bills by Senators Cruz and Cornyn) seem to be taking the discussion in the direct opposite direction.

Can’t Compel Usage

Absent interpreting current law or regulations in an incomprehensible way, there is no way to require any provider to use a wholesale wireless network. Without a mandate, it means that any use will have to be completely voluntary. Given nationwide providers’ alternative plans to roll-out 5G services and their objections to this network, they clearly have zero interest in using it. And, these are the reactions before we even have clear guidance on how access to this wholesale network would be determined. Without the bigger providers’ participation, use and financial support for this new system would be left to regional providers, smaller entities, and/or new entrants. It is possible that some of these might be willing to use such a network, but their traffic load is likely to be incredibly low and wouldn’t make the overall economics work. Moreover, their usage patterns would likely peak in specific locations and not others. Yet a massive network infrastructure would have to be constructed for multiple reasons, including security (see below), notwithstanding the overall demands for its use. And, if there are new entrants who can use the capacity of and support such a network, they are also free to acquire spectrum like any other commercial entity, instead of getting a government handout.

No Tower Agreements/Relationships

Almost all wireless towers and antenna locations are owned or leased by companies unaffiliated with the large wireless providers. However, the existing contractual relationships and uncertainty surrounding the viability of this random wholesale network model means that it is unlikely that the current wireless infrastructure would be available for this purpose. To the extent collocation is not an option, that leaves constructing new towers and contracting for new antenna sites. This would make such a network build – starting from the ground up – astronomically expensive. In fact, other current spectrum holders have admittedly decided not to take this approach. It would also take a very long time, if ever, to execute these agreements and finish construction, which would increase the likelihood that any nationwide network and, more importantly the dedicated spectrum, would be underutilized if this plan was ever to be put in motion. This endeavor is not unlike plans of the recently bankrupt Alliance of American Football and its backers’ efforts to build a new professional football league from the ground up; jumping to the punchline, the vision lasted all of six weeks.

Won’t Ensure Security

One of the main reasons given for the creation of a government-sponsored wholesale network is that it is the only mechanism to secure 5G communications from interceptors and those with nefarious intentions. This line of thinking is flawed for at least two reasons. First, it assumes that private sector wireless providers don’t care about security or can’t ensure sufficient security, which just isn’t accurate. These companies have been and continue to work hard within the standard-setting bodies to incorporate security within the various 5G standard iterations. That means the protocols adopted have and will promote extensive security efforts. More importantly, these same providers know quite well that users expect security when using their networks. Thus, they have every incentive and are pursuing the appropriate steps to ensure robust, secure communications, especially in a 5G universe.

Second and equally flawed is the idea that any network, especially this wholesale one, can be completely secure. To guarantee security of the overall system, no data can be handed off to another carrier or carried by the public Internet. In other words, this network must carry all its traffic from end to end, especially in a 5G universe where computing will be diffuse and not centralized, generating unlimited exposure points. Siting wireless facilities nationwide is expensive enough but building separate fiber and backhaul systems from scratch is practically undoable. Even if this were possible, which it is not, there would be intense interest in breaking into and exploiting its communications. It effectively would be an engraved invitation for any rogue entity seeking to undermine the U.S. government’s sponsorship of the network. Also, arguing that this network couldn’t be broken into ignores the reality of past breaches of high priority U.S. government networks (e.g., DoD, CIA).

Won’t Stop China’s Global Expansion

For those worried about the communist Chinese government’s influence and resulting harmful effects, it is nearly impossible to see how hamstringing the U.S. market with a government-sponsored network will convince other countries to take similar action. Shooting oneself in the foot rarely leads others to do the same. In fact, there is no evidence showing how and no plausible argument as to why taking such a drastic step would sever other nations’ installation of Chinese equipment in their networks or curtail Chinese wireless providers from gobbling market share as they move from country to country. More problematic, there is a likelihood that the U.S.’s pursuit of such a curious path — with its added costs, extensive buildout timelines, and suspect security improvements — would drive other nations to increase their reliance on what has typically been cheaper-priced Chinese communications equipment, placing Chinese manufacturers and providers in a stronger position than those in the U.S. and other market-based countries. And, it is fairly conceivable that the Chinese government would counter our action with even more subsidies. Instead of curtailing China’s 5G global position, it may act as a further catalyst.

Government Undermining Private Sector Wireless Market

The establishment of such a wholesale 5G network would unfairly and inappropriately provide a U.S. government imprimatur over those of the private sector. This is not too dissimilar to the debate decades ago over whether there should be a government-sponsored national U.S. bank. While I have little doubt that our nation’s existing wireless providers could compete and succeed against this new network model, just the mere threat of giving this “idea” serious consideration might have negative repercussions. For instance, it might improperly increase providers’ risk for customer loss, especially government agency traffic; potentially initiate review of their borrowing costs; and generate negative public perception of their network security. Creating unnecessary doubt and market uncertainty for the private sector is a serious unintended consequence of continuing to even have the debate over this network.

On a larger scale, such a government stamp-of-approval combined with free DoD spectrum would send a signal that we are not fully committed to American capitalism. At this precarious moment in time and with global economic uprisings on the rise, this slice of socialism sends exactly the wrong signal to the rest of the world.

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Given all the issues identified, a major question remains: why in the world would we gamble our nation’s strong wireless position for a less than half-baked, flawed idea? Certainly, it makes little sense to give it any credence or pursue it in any capacity — at least until definitive solutions to the issues above and potentially others are presented. I won’t hold my breath that any attempt will be made to provide any specifics or to answer the unanswerable.

Michael O’Rielly has been a Commissioner at the Federal Communications Commission since October 2013.

BroadbandBreakfast.com accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@broadbandcensus.com. The views reflected in Expert Opinion pieces do not necessarily reflect the views of BroadbandBreakfast.com and Breakfast Media LLC. This article was originally published on FCC.gov.

Broadband Mapping

Garland McCoy: Some State Attorneys General Are Preparing to Take the FCC to Court

While some will “cash out,” other state broadband officials will seek the full measure of federal broadband infrastructure funds due.

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The author of this Expert Opinion is Garland McCoy, Executive Director of Precision Ag Connectivity and Accuracy Stakeholder Alliance

Let me start by saving the time of those state broadband officials who are going to accept the recently released FCC Broadband Map Data at face value and take NTIA’s “cash out,” and in doing so, forgo participation in the available FCC challenge process. For those state broadband officials, the insights, and recommendations I provide below will be of little interest to you. 

If the past is any prelude to the future, the Internet Service Providers will use the same challenge criteria to successfully throw out the crowdsourced and bulk data that states have gathered for their own maps. As I detailed in my recent article on Broadband Breakfast, the FCC published specifications for its challenge process on September 15, 2022.

This directive gives ISPs authority to challenge data drawn from their respective service territories, leaving states with little choice but to accept the FCC’s map. The only notable exception is California, which has put in place its own statewide device-driven data gathering methodology, and we consider its data as likely challenge-proof. 

Not all is lost for states seeking to challenge the FCC’s maps

But all is not lost for other states. By the end of the first quarter of next year I firmly believe there will be some state broadband officials who will seek to pursue the full measure of federal broadband infrastructure funds due them, and not simply acquiesce to a smaller portion of funds that is supported by the flawed FCC map.

I base this assumption on new methodologies now available to states, which will bring the same type of credible validation and metering to broadband service at the end-user level that has been available, and required, for decades with other important utilities such as electricity, water, and natural gas. In other words, these methodologies will allow consumers to determine if they are getting true broadband speed connectivity – and frankly whether or not they are getting what they are paying for.

These state broadband officials have reviewed the recently released FCC broadband map and have compared it to their own respective state broadband maps. And not surprisingly, what they are finding is an FCC map that vastly overstates the amount of broadband connectivity in their states, and in doing so, vastly reduces the amount of federal dollars that state will receive. And these differences are significant. It could mean as much as a loss of tens of millions of dollars in smaller states and up to half a billion dollars or more for larger states. 

What these state officials will ultimately find is irrefutable evidence that many of the ISPs doing business in their state have been systematically providing significantly less service speed and quality than their customers’ terms of service agreements stipulate.

States are beginning to work with their state attorneys general on lawsuits

Knowing this and considering how the FCC has not run a transparent and straightforward process – and has used the calendar in a way to run out the clock on states, you can see why some state broadband officials have begun working with their state attorneys general to not only prepare to challenge the FCC data, but to take their case to court. 

Consider the calendar issue alone: The FCC released its long-anticipated new map data on November 18, 2022, and is giving states until January 13, 2023, to respond – with the major holidays of Thanksgiving, Christmas, and New Year’s falling in the interim.

If you are one of these state broadband officials currently considering your options to challenge and/or litigate, then we can play a vital role in your efforts. You will need to ensure that your state broadband map data is litigation-ready by putting in place bullet-proof methodologies and highly credible network monitoring devices/meters. This data can be used to support your case for the full broadband infrastructure funding that your State is entitled to receive.  Additionally, these same devices and methodologies can be used to support any state lawsuits against ISPs for false/deceptive advertising and breach of the spirit, if not the letter, of customer “terms of service” contracts. 

Importantly, our device-driven methodology also focuses solely on the premium customers of ISPs in rural counties of a state, which establishes what FCC refers to as the “available service” for a given ISP’s service territory. 

You have the power to truly close your state’s broadband connectivity gap by fully utilizing the historic level of federal infrastructure funding that has been set aside for this purpose, which in turn will bring accountability and equity to broadband network services for your citizens. 

If you want a citizen-centric partner in these initiatives, please visit our website and contact me at the email address provided below. PAgCASA is a non-profit organization focused on promoting rural prosperity, and we are utilizing industry standard network monitoring/metering devices, same as used by the largest ISPs, litigation-ready methodologies, and an expert team and partnerships to accomplish our goals.

Garland T. McCoy, Co-Founder and Executive Director of Precision Ag Connectivity and Accuracy Stakeholder Alliance, is a long-time non-profit veteran in the fields of technology and telecommunication policy having served as Founder and CEO of the Technology Education Institute & Technology Policy Institute. Garland was recently an adjunct professor at Syracuse University’s iSchool, teaching information policy and decision making, and can be reached at garland.mccoy@pagcasa.org. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. 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 Mapping & Data

Jeff Miller: Tools to Manage the Next-Generation Network Buildouts

Service providers that use GIS applications are able to reduce design time by 80 percent.

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The author of this expert opinion is Jeff Miller, Synchronoss Technologies CEO.

Today’s digital world is driving the insatiable need for fiber networks and connectivity, thus the thrust for widespread broadband buildouts and deployments worldwide. Broadband connectivity is the heartbeat for mobility, cloud applications, voice, video, and social media, not to mention home automation, IoT, and smart cities. As a result, service providers and operators are investing heavily in infrastructure, claiming their 5G networks are the largest or fastest or most reliable.

Initiatives like the Rural Digital Opportunity Fund are aimed at bridging the digital divide and fast-tracking investment to deploy high speed fixed broadband service to rural areas and small businesses that lack it. The Federal Communications Commission’s $20.4 billion program requires that networks stand the test of time by prioritizing higher network speeds and lower latency.

A key element in the implementation of RDOF-backed projects is broadband mapping. The Federal Communications Commission is in the process of updating its current broadband maps with more detailed and precise information on the availability of fixed and mobile broadband services. The Broadband Deployment Accuracy and Technological Availability Act, signed into law in March 2020, requires the FCC to change the way broadband data is collected, verified, and reported

As carriers build, expand, and upgrade their fiber network infrastructure, a great deal of planning is required, along with documenting the intricacies of design and engineering processes.

Streamlining and automating network planning and design processes through software can deliver accurate and timely network info for service providers, increase efficiency, and create opportunities for reducing costs.

GIS based systems are replacing volumes of paper, and outdated static CAD, Excel and Vizio files. They offer sophisticated tools to manage all aspects of network design and infrastructure management. Working with many service providers that use GIS applications, they are able to reduce design time by 80 percent and drastically cut other capital expenditures.

Automation is key

Having to rely on a system of manual processes to manage the fiber network makes it increasingly difficult to scale. Fortunately, with the introduction of automation into the network management process by utilizing an accurate physical network inventory in addition to geographic information system mapping, scalability becomes a much easier task.

Continuous planning and engineering tasks can ultimately become automated through software implementation. Automating network fiber management creates significant business value by shifting a service provider’s approach from reactive to proactive. A comprehensive and updated database for network architecture quickly allows for scenario analysis and capacity planning. Sharing automated processes across different organizations becomes much simpler and improves collaboration while reducing errors. This can allow staff to shift their focus to more pressing operational activities thus making the network more reliable.

Integration between different systems

Whether it is your enterprise GIS or outage monitoring system, it should be easy to interact with third-party systems to get the most out of the network data. Ideally, you should be able to receive an outage notification and use that location to track down the network and pinpoint the root cause to act and quickly resolve the situation before customers notice. This can help save time, money, and guarantee customer satisfaction.

Mobilize network data and increase field worker productivity

Utilizing a fiber networking and planning solution enables network information to be shared easily and quickly between the field and office to provide access to the information they need when they need it at any given time. Enterprise-wide access can provide timely and accurate network information for a wide range of communications service providers.

When it comes to service providers, expanded visibility into a network yields a greater overall awareness of the network. Automating third-party data exchange processes with accurate and up-to date inventory can optimize performance for field workers and guarantee customer satisfaction. Improved access to data can increase ROI by allowing cable locators and field techs to receive accurate confirmation before they arrive at a job. In the end, there will be fewer mistakes which ensures happier customers.

The right tools can result in improved scalability, reduced time to revenue, lower operational costs, and actionable insights that can be gleaned from network data.

Jeff Miller serves as President and CEO of Synchronoss Technologies. He previously served as President for IDEAL Industries Technology Group, following a 16-year experience with Motorola Mobility where he was Corporate Vice President of North America. Miller also serves on the Board of 1871, Chicago’s largest start-up incubator, and on the non-profit Boards of Aspire Chicago and Junior Achievement. This article is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. 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

Dmitry Sumin: What to Do About Flash Calls, the New SMS Replacement

Why are flash calls on the rise and how do operators handle them to maximize revenue?

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

Chances are you’ve received several flash calls this week when registering for a new app or verifying a transaction. Flash calls are almost instantly dropped calls that deliver one-time passcodes to users, verifying their phone numbers and actions. Many prominent apps and companies, such as Viber, Telegram, WhatsApp, and TikTok, use flash calls as a cheaper, faster, and more user-friendly alternative to application-to-person SMS.

With the flash call volume expected to increase 25-fold from 2022 to 2026, from five to 130 billion, it’s no wonder they’re a hot topic in the telecom industry.

But what’s the problem, you may ask?

The problem is that there is currently no way for operators to bill zero-duration calls. This means operators don’t make any termination revenue from flash calls, which overload networks. What’s more, operators lose SMS termination revenues as businesses switch to flash calls. SMS business messaging accounts for up to five percent of total operator-billed revenue in 2021, so you can see the scale of potential revenue losses for operators. 

In this article, I’ll discuss why flash calls are on the rise, why it’s difficult to detect and monetize them, and what operators can do about this.

Why are flash calls overtaking SMS passcodes?

Previously, application-to-person SMS was a popular way to deliver one-time passwords. But enterprises and communication service providers are increasingly switching to flash calls because they have several disruptive advantages over SMS.

First and foremost, flash calls are considerably cheaper than SMS, sometimes costing up to eight times less. Cost of delivery is, of course, a prime concern for apps and enterprises.

Second, flash calls ensure smooth user interaction, which boosts user satisfaction and retention. On Androids, mobile apps automatically extract flash call passcodes. This makes the two-factor authentication process fast and frictionless. In comparison, SMS passcodes require users to read the SMS and sometimes insert the code manually.

Third, on average flash calls reach users within 15 seconds, while SMS sometimes take 20 seconds or longer. The delivery speed of flash calls also improves the user experience.

The problem: Flash calls erode operators’ SMS revenues

While offering notable advantages for apps, flash call service providers, and end users, flash calls create numerous challenges for operators and transit carriers.

As we discussed before, flash calls erode operators’ SMS revenues because much of the new flash call traffic will be shifted away from current SMS business messaging. The issue is only going to become more pressing as the volume of flash calls grows.

So from the operator’s standpoint, flash calls reduce revenue, disrupt relations with interconnect partners, and overload networks. However, there is still no industry consensus on how to handle flash calls: block them like spam and fraudulent traffic or find a monetization model for this verification channel, like for application-to-person SMS.

Accurate detection of flash calls is a challenge

The first crucial step that gives operators the upper hand is accurately detecting flash calls.

This is difficult because operators have no way of discerning legitimate verification flash calls from fraud schemes that rely on drop calls, such as wangiri. The wangiri fraud scheme uses instantly dropped calls to trick users into calling back premium rate numbers. In addition, flash calls need to be distinguished from genuine missed calls placed by customers.

The problem is that even advanced AI-powered fraud management systems struggle to accurately differentiate between various zero-duration calls. The task requires AI engines to be trained on large volumes of relevant traffic coupled with analysis of hundreds of specific call parameters.

Dedicated anti-fraud solutions are the answer

There are only a few solutions on the market that are capable of accurately distinguishing flash calls from other zero-duration calls. Dedicated fraud management vendors have made progress on this difficult task.

The highest accuracy of flash call detection now available on the market is 99.92 percent. Such tools allow operators to precisely determine the ranges from which flash calls are sent. As a result, operators can make an informed decision on how to treat flash calls to maximize revenue and can proactively negotiate with flash call providers.

Flash call detection creates new opportunities

Our team estimates that flash calls make up to four percent of Tier one operators’ international voice traffic. Without accurate detection and a billing strategy, this portion of traffic overloads operators’ networks and offers no revenue. However, with proper detection flash calls offer a new business opportunity.

Now is a crucial time for operators to start implementing flash call detection into their system and capitalize on the trend.

There are a few anti-fraud solutions on the market that give operators all the necessary information to negotiate a billing agreement with a flash call provider. Once an agreement has been reached, all flash calls coming from this provider will be monetized, much like SMS.

All flash calls not covered by agreements can be blocked automatically. This will help to restore SMS revenues. Once a flash call has been blocked, subscribers will most likely receive an SMS passcode sent as a fallback.

Moreover, modern solutions don’t affect any legitimate traffic because they only block selected ranges. This also helps to prevent revenue loss.

Essentially, the choice of how to handle flash calls comes down to each operator. However, without a powerful anti-fraud solution capable of accurately detecting flash calls in real time, it’s nearly impossible to monetize flash calls effectively and develop a billing strategy.

Dmitry Sumin is the Head of Products at the AB Handshake Corporation. He has more than 15 years of experience in international roaming, interconnect and fraud management. Since graduating from Moscow State University, he has worked for both vendors and network operators in the MVNO and telecommunications market. This piece is exclusive to Broadband Breakfast.

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

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