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Jeff Blum and V. Noah Campbell: Unleashing the Next Wave of American 5G through Competition in the 12 GHz Spectrum Band

Allowing 5G use of the 12 GHz band will lead to better broadband.

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The authors of this Expert Opinion are Jeff Blum of DISH and V. Noah Campbell of RS Access

The Biden administration has recognized the importance of spurring competition in the America economy, including the telecommunications market. Indeed, President Biden recently signed an Executive Order aimed at promoting “a fair, open, and competitive marketplace.” Today, more than 30 diverse companies and stakeholders (known collectively as the 5Gfor12GHz Coalition) are actively working to further this national priority by urging the FCC to expand the use of a huge swath of mid-band spectrum. Doing so will unleash innovation and additional choice in the marketplace, to the benefit of competition and American consumers.

We represent DISH and RS Access, two members of this Coalition. Our Coalition was founded on the belief that the FCC can and should modernize its rules for the 12.2-12.7 GigaHertz (12 GHz) band to allow for 5G use. In doing so, the FCC will further the Administration’s efforts to promote competition by enabling more choice, innovation, connectivity, and lower costs for families and businesses. And, the FCC can unleash the 12 GHz band while protecting existing satellite users, an outcome that will propel competition among broadband providers.

Put simply, allowing 5G use of the 12 GHz band will lead to better broadband options and services for all Americans. By decreasing latency and enhancing video streaming, it will allow more families to access telehealth, more students to connect to virtual classrooms, and more businesses to reach new customers. By amplifying speeds, it will enable a new generation of mobile apps that bring services families need to their fingertips within minutes.

And by boosting data collection and aggregation, it will revolutionize industries like agriculture, as farmers and ranchers will now have smart sensors that provide critical information about crops and livestock in real time. These are just a few examples of how putting 12GHz to work for accelerated 5G deployment will benefit consumers across the nation, daily.

The best part about modernizing rules for the 12 GHz Band? We do not have to sacrifice any services to reap the benefits this 500 MHz of key spectrum has to offer. As the science and data demonstrate, there are many ways to protect existing users of the 12 GHz band while expanding use of the band for 5G and other broadband services—giving all operators in this space a chance to succeed and innovate for American consumers and businesses.

The proof is in the data: a recent study by the econometric firm Brattle Group (which has specialized in analyzing the economic impact of spectrum policy) shows that modernizing rules in the 12 GHz band would bring extraordinary U.S. consumer welfare benefits. And, another study by one of the world’s leading radio engineering firms demonstrates how leveraging this spectrum for 5G networks will spur the rapid deployment of next generation applications in the United States.

Modernizing rules for the 12 GHz band truly is a win-win-win for all sectors of our economy. It benefits the more than 400 million consumers and businesses who rely on 5G for critical services; customers who depend on reliable products from current licensees like satellite providers; and families still living without access to broadband.

The evidence is clear, the record is robust, and the time is now. We must not let this opportunity to accelerate American competition pass us by. As Acting Chairwoman Jessica Rosenworcel said, “Our economy thrives on competition. It is the reason the United States is home to some of the most dynamic companies in the world.” We could not agree more.  And for that reason, we urge the Commission to seize this moment and unleash the power of 12 GHz for 5G.

See also “Broadband Breakfast on Wednesday, July 14, 2021 — Spectrum for 5G, LEOs and the Future of the 12 GigaHertz (GHz) Band.

Jeff Blum serves as DISH’s Executive Vice President, External & Legislative Affairs, overseeing public policy, regulatory and government affairs in Washington. He has been with DISH since 2005, and currently serves as Vice-Chairman of the Satellite Broadcasting and Communications Association as well as serving on the boards of INCOMPAS, the Computer & Communications Industry Association and the Broadband Internet Technical Advisory Group. Jeff was a partner at the Los Angeles firm of Davis Wright Tremaine, where his practice focused on copyright, First Amendment and anti-piracy litigation

V. Noah Campbell founded RS Access in 2018 to acquire spectrum in the 12 GHz band in the United States and to operate wireless networks serving a wide variety of constituents throughout our markets, which comprise approximately 15% of the US population. RS Access’ service is designed to ensure that customers can affordably acquire MVDDS point-to-multipoint connections to augment existing network architectures. Campbell, a wireless industry entrepreneur, also founded Radio Spectrum Group, LLC and MSD Capital, L.P.

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 expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

Broadband Breakfast is a decade-old news organization based in Washington that is building a community of interest around broadband policy and internet technology, with a particular focus on better broadband infrastructure, the politics of privacy and the regulation of social media. Learn more about Broadband Breakfast.

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Expert Opinion

David Don: Strong Partnerships for Broadband ‘Beyond the Build’

BEAD success requires a long-term commitment to technological, economic, social, and civic vitality.

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The author of this Expert Opinion is David Don, Senior Vice President of Public Policy at Comcast

In the Infrastructure Investment and Jobs Act (IIJA), Congress laid out a bold plan to bring broadband to every remaining unserved corner of the nation. That plan authorizes distribution of grants totaling $42 billion in Broadband Equity and Deployment (BEAD) money to benefit each state and territory. The process for distributing those funds has already begun, and the first transfers are expected early next year.

The BEAD investments are vital to close geographic gaps in broadband coverage. But the job of connecting communities to broadband does not end with laying cables and installing hardware. Success requires a long-term commitment to the technological, economic, social, and civic vitality of each community.

Congress has made capital funds available only for building these broadband networks. Operating and maintaining them — and keeping them secure and innovative — will require continuous investment. As Brookings recently explained, “If a government decides to greenlight a project by only looking at the upfront sticker price, it’s a recipe for deteriorating infrastructure.”

In most communities, particularly those that have lacked broadband until now, success is best assured by building public-private partnerships with established and experienced ISPs. Community leaders should carefully consider which partners have a real track record that can be relied upon to make broadband successful beyond the build – long after the federal grant dollars have been spent.

Six key ISP capabilities that communities should prioritize in potential BEAD partners

  1. Superior Scale. Selecting a partner with vast resources and networking experience facilitates more rapid and extensive rollout of broadband infrastructure, and also brings assurances of quality network management in the future. Whether it is conducting routine maintenance and upgrades or coping with critical natural disaster recovery or supply chain shocks, an ISP with superior scale is best equipped to meet the ongoing demands of operating critical infrastructure and to keep costs down.
  2. Financial Stability. Companies with strong balance sheets have superior access to capital, are better able to manage rising interest rates and to withstand uncertain economic conditions, and have the resources to operate networks for decades. When companies with flimsy balance sheets take federal broadband subsidies but prove unable to follow through on their commitments, it wastes the public’s money and leads to costly delays in serving communities. Prime examples can be found in any of the many recipients of the FCC’s Rural Digital Opportunity Fund (RDOF) grants who have defaulted even before beginning construction, affecting one-third of RDOF census blocks.
  3. Continuous Innovation. Partners who are at the forefront of technological advancements can keep pace with the changing digital landscape, innovating continuously to meet consumer demand. Internet traffic is growing incredibly fast – up over 20% in the last year alone. Broadband speeds are up over 3x since 2017. Leading innovators like Comcast always keep their networks and services ahead of the curve and bring those capabilities to their public sector partnerships.
  4. Seamless Security. In 2022, cyberattacks against tech and telecom companies more than doubled. Investment in cybersecurity is essential to protect American businesses and consumers, and it already carries a price tag of over $200 billion a year worldwide. While no ISP is immune to cyberattacks, companies may underinvest in network security, creating serious risks. We have one of the deepest cybersecurity teams in the world, with hundreds of employees dedicated to minimizing cybersecurity harms. Small, inexperienced ISPs cannot match this.
  5. The Skills to Promote Broadband Adoption. A local community can have good broadband infrastructure, but if its citizens are not taking the service that’s not success. A company with a proven track record in driving higher adoption rates can ensure that many more households reap the benefits of broadband. We have been the industry leader in meeting the adoption challenge for over a decade, with our first-of-its-kind Internet Essentials program as well as our successful participation in the bipartisan-supported Affordable Connectivity Program, which has helped millions of low-income households connect to the Internet.
  6. Track Record for Serving Communities. Efforts by local governments to go at it alone in building broadband, or choosing inexperienced partners, are riddled with failure. Whether it’s participants in BTOPRDOF or state subsidy programs, we have seen scores of ISPs over-promise and under-deliver. At Comcast, we have an unmatched track record: We meet our commitments, and we bring service to all neighborhoods in our footprint.

The broadband future depends on effective collaboration

Community leaders who understand the complexity and risk associated with building and maintaining a broadband network will value a partner that can help them deploy digital infrastructure that is not just built to last, but built to lead.

Comcast brings to local communities its deep-rooted commitment to high-quality technology, widespread adoption, and services that are stable, secure, and innovative.

We are ready and able to work with communities to maximize the value of their broadband investment to every household. With Comcast, communities can be sure they will have a steady and reliable partner who will ensure their success beyond the build for decades to come.

David Don is Senior Vice President of Public Policy at Comcast. This piece is was posted on Comcast’s blog on September 28, 2023, and is reprinted with permission.

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

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Broadband Speeds

Johnny Kampis: FCC Push To Eliminate Data Caps Could Increase Broadband Rates For Many Users

Usage based billing ensures that those who use the most data pay the most money.

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The author of this Expert Opinion is Johnny Kampis, director of telecom policy for the Taxpayers Protection Alliance

The Federal Communications Commission, under the behest of Chair Jessica Rosenworcel, may now go after the practice of usage-based billing, a common method by which internet-service providers charge consumers different rates based on how much data they use.

A push by the FCC to eliminate the practice could result in price increases for many broadband users.

Rosenworcel announced a proposal in June to investigate how internet data caps affect consumers, especially the impacts on those with disabilities and lower incomes. Many broadband providers offer tiered pricing based on data usage, limiting how much a customer can use before paying more for their service or facing slowdown in their speeds.

Internet access is no longer nice-to-have, but need-to-have for everyone, everywhere. As we emerge from the pandemic, there are many lessons to learn about what worked and what didnt work, especially around what it takes to keep us all connected,” Rosenworcel said. When we need access to the internet, we arent thinking about how much data it takes to complete a task, we just know it needs to get done. Its time the FCC take a fresh look at how data caps impact consumers and competition.”

But usage-based billing ensures that those who use the most data pay the most money, helping keep costs lower for those who use less data. It is a common practice across many industries. For example, if you operate a business, your accountant would bill you for more hours to do your taxes than you neighbor who only files personal taxes. If you travel farther across the city in an Uber, youd pay a higher rate than another customer traveling a few blocks. And – since Democrats wants to regulate the internet as a utility – if you use more kilowatts of electricity in your home than your neighbor, you get a higher power bill.  

As James Erwin of Digital Liberty notes, its this latter point where the proposition by the FCC really falls apart.

“If one accepts the premise that high-speed broadband is now a necessity, not a luxury, and uses that as justification for outlawing usage-based billing, why shouldn’t the same logic apply to electricity? It has been government policy for close to a century that universal electricity is imperative for access to modern life. Despite this, electric utilities still put meters on our houses and measure our usage to charge us.”

Case for Consumers points out that pricing is one of the most critical decisions by a business and can determine its success or failure.

“This is why letting the market, as opposed to government, set prices is an enormous advantage to consumers, as prices for goods and services necessarily reflect the actual costs incurred and most often land at a point of equilibrium reflecting actual market value at the time and place delivered,” the organization posted on a blog. “This allows businesses to efficiently and economically produce goods and services, as well as improve those goods and services, in order to make a profit while preventing consumers from overpaying their hard-earned money.”

Most internet providers offer tiered plans, which allow light users to pay a much lower rate for a limited amount of data and heavy users to pay a higher rate for unlimited data. An effort by a Democrat-led FCC to eliminate this structure, capping the rate, would likely lead to light users (who often have lower incomes) having to pay more for their internet.

As Case for Consumers notes: If the government dictated the price of a fill-up (regardless of tank size), then gas stations would set the price high enough to ensure they did not lose money on larger vehicles, meaning the driver of a Geo Metro would pay the same at the pump as the owner of a Chevy Suburban, an absolutely outlandish notion.”

A large reason why the United States enjoyed robust broadband infrastructure during the early days of the COVID-19 pandemic was the ability of internet providers to use the revenue from such tiered pricing systems to continue to reinvest and maintain their systems. Efforts by the FCC to force providers to charge a lower-than-market price would put such long-term stability at risk.

Johnny Kampis is director of telecom policy for the Taxpayers Protection Alliance. 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 expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Expert Opinion

Craig Settles: Believe in the Healing Power of Telehealth

Healthcare organizations are seeing telehealth as an opportunity to enhance connectivity with patients and improve healthcare outcomes.

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The author of this Expert Opinion is Craig Settles, who unites community broadband teams and healthcare stakeholders through telehealth

Listening to many politicians and National Telecommunications and Information Administration officials, you’d think “broadband” is practically synonymous with “telehealth.” So let’s go with it! Make telehealth front and center, the marketing hook of your NTIA Broadband Equity Access Deployment and Digital Equity Act grant applications.

Do a medical needs assessment of NTIA’s eight populations (target markets): 1) low-income urban dwellers, 2) rural communities, 3) Native American communities 4) veterans, 5) seniors, 6) people with disabilities, 7) those for whom English is a second language, and 8) the incarcerated. Low-income Americans have high rates of heart disease, diabetes, stroke, and other chronic conditions compared to higher-income Americans.

How many people would we help with telehealth and how many people would go home with a computing device? A marketing win-win – attack the disease, attack the digital divide.

By the numbers

The Centers for Disease Control and Prevention reports 4 of 10 adults live with two or more chronic diseases. That’s 103.2 adult human beings. Imagine if we leveraged those $45 billions from NTIA, the thousands of all staff people, and the hosts of volunteers to treat, cure, or prevent chronic conditions?

In 2020, 1,603,844 new cancer cases were reported and 602,347 people died. About 695,000 people in the U.S. died from heart disease in 2021 and the disease costs us about $239.9 billion each year in 2018 and 2019. 37.3 million people have diabetes.

Many more millions suffer from and die from lung disease, strokes, Alzheimer’s disease, obesity, and kidney disease. What’s more, many these of chronic diseases are driven by unhealthy lifestyles – smoking, minimal physical activity, poor nutrition, and excessive alcohol use.

Make sure the numbers include the dramatic disparities. For example, African Americans make up 12% of the U.S. population, but twice as many die from strokes (100,000) as all other ethnic groups combined. Studies have found that Black people between the ages of 45 and 54 die of strokes at a rate that’s 3 times greater than their White counterparts. Being overweight or obese increases your risk of stroke. About three out of four Hispanics are overweight.

Telehealth making a difference: Gilda Radner’s legacy

Gilda’s Club Twin Cities, part of the Cancer Support Community global non-profit network providing free social and emotional support for those impacted by cancer, offers telehealth to medically underserved Minnesota urban and rural residents. The club partnered with telehealth firm Equiva and ISP Infinti Mobile to enroll members in the Federal Communications Commission’s Affordable Connectivity Program, to sign them up for Internet access, and send them tablets preloaded with special content.

“CSC organizes the telehealth content in a way that makes sense for their constituents,” says Beth Strohbusch, head of marketing for Equiva. “Members learn about cancer treatment options, digital support groups, and free psychosocial services if members are having problems with depression.”

Strohbusch believes it’s not just hospitals and support groups pursuing broadband and telehealth. Healthcare organizations, nursing homes, and financial risk-bearing organizations are seeing telehealth as an opportunity to enhance connectivity with patients and improve organizations’ financial and chronic healthcare outcomes.

Jason Welch, Infiniti president, says, “Equiva has a reach we don’t have – the healthcare communities, the cancer support community, those in elder care, the larger healthcare organizations. Infiniti saw a natural, practical fit. The Equiva ACP Connect Program is a practical combination of services that are easily explained. Our customers understand accessing healthcare and related resources from their computers and is the data transport mechanism allowing them to do so.”

The eyes have it

Age-related macular degeneration affects the central part of the retina that allows you to see fine details clearly. AMD causes damage to the macula and results in blurring of your central vision. It is a leading cause of blindness among older Americans and is more common in individuals of European ancestry.

Ocutrx manufactures an augmented reality corrective devices that tackles AMD and doubles as patients’ cell phone with Wi Fi, 4G, and 5G capabilities. CEO Michael Freeman says, “We build circuit board in our headsets that enables them to do everything that cell phones do, control seven cameras, and creates the six degrees of freedom where patients can pose virtual objects out in front of their eyes.”

The user puts on the headset and continually does a field test in each eye. Software signals the device when the user can’t clearly see an object, which triggers the cameras that starts projecting real-time on the lens a live 60-frames/second video. Augmented reality moves pixels from the peripheral to the front of the user and within 13 milliseconds the user can see the object.

Ocutrx has a headset for patients with chronic disease. Patients and their doctor each has a headset and cell phone capabilities for talking real time over an encrypted network. This headset measures temperature, respiratory rate, heart rate and other readings. Freeman adds, “Its camera can be disconnected so you can show the doctor your arm or leg.” To treat ‘lazy eye’, AI in the headset let’s patients play a game virtually. It frosts the lens of the good eye and makes the lazy eye work harder and tracks how well the eyes work together when they’re doing the exercises.

The fruits of telehealth

Telehealth vender Fruit Street delivers digital therapeutics for addressing bad habits that have medical consequences. CEO Laurence Girard says, “digital therapeutics may be programs that deal with sleep, stress, and resiliency, others may focus on opiate addiction or general mental health. ​

One in three adults have prediabetes in which someone’s blood glucose (sugar) level is too high but not high enough yet for a diagnosis of type 2 diabetes. Fruit Street’s Digital Diabetes Prevention Program combines group telehealth sessions, wearable devices, and dietary tracking in the vender’s mobile application. Besides lowering the risk to develop type 2 diabetes, the program can also lower the risk of having a heart attack or stroke, improve health overall, and help subscribers feel more energetic.​

Consider nonprofits marketing core digital therapeutics within a community. Imagine teams of “Life Changers” whose main goal is to embed broadband, smart home, cloud, and telehealth infrastructure that keeps residents healthy while reducing asthma, diabetes, hypertension, and other chronic illnesses.

Craig Settles conducts needs analyses with community stakeholders who want broadband networks to improve economic development, healthcare, education and local government. He hosts the radio talk show Gigabit Nation, and is Director of Communities United for Broadband, a national grass roots effort to assist communities launching their networks. 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 expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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