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Christopher Mitchell: Brendan Carr is Wrong on the Treasury Department’s Broadband Rules

The Federal Communications Commission has no excuse for why the agency finished with the same bad data it started with.

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The author of this Expert Opinion is Chris Mitchell, director of the Community Broadband Networks Initiative at Institute for Local Self-Reliance

With all due respect to Federal Communications Commissioner Brendan Carrhis reaction to the Rescue Plan Act’s State and Local Fiscal Relief Fund (SLFRF) spending rules is way off base. As I wrote last week, the rules for broadband infrastructure spending are a good model for pushing down decision-making to the local level where people actually have the information to make informed decisions. (Doug Dawson recently also responded to Commissioner Carr’s statement, offering a response with some overlap of the points below.)

See Christopher Mitchell, Treasury Department Rescue Plan Act Rules Improve Broadband Funding, Broadband Breakfast, January 13, 2022

The Final Rule from the Treasury Department gives broad discretion to local and state governments that choose to spend some of the SLFRF (SLurF-uRF) funds on broadband infrastructure. The earlier draft of rules made it more complicated for networks built to address urban affordability challenges.

However, in coming out against the rules, FCC Commissioner Carr is giving voice to the anger of the big cable and telephone monopolies that cities can, after collecting evidence of need, make broadband investments even in areas where those companies may be selling services already. Commissioner Carr may also be frustrated that he has been reduced to chirping from the sidelines on this issue because the previous FCC, under his party’s leadership, so badly bungled broadband subsidies in the Rural Digital Opportunity Fund (RDOF) that Congress decide NTIA should administer these funds and have the state distribute them.

Nonetheless, the issues that Commissioner Carr raised are common talking points inside the Beltway and we feel that they need to be addressed.

Background Note

The failure of the FCC to assemble an accurate data collection is many years in the making. No single presidential administration can take the full blame for it, but each of them could have corrected it.

President Joe Biden’s FCC is not yet fully assembled because of delays in appointment and in Senate confirmation, but it would not be reasonable to lay blame on the current FCC for the failures discussed below. That said, it is not clear that we are on a course for having better maps and data that will resolve these problems anytime soon.

Commissioner Carr’s Criticism 

Commissioner Carr jumps immediately into the rural vs urban frame, suggesting that the Biden Administration could leave rural families behind by allowing local governments to invest in broadband in areas where an existing provider may already claim to offer service. Outlawing this practice – which he and others close to the largest cable and telephone companies call “overbuilding” – has been a major point for Republican FCC Commissioners.

  • Rather than directing those dollars to the rural and other communities without any Internet infrastructure today, the Administration gives the green light for recipients to spend those funds on overbuilding existing, high-speed networks in communities that already have multiple broadband providers. This would only deepen the digital divide in this country.

Pardon me? Logically, it is not clear what exactly Commissioner Carr is griping about here. Using Maryland as an example, if Baltimore is allowed to spend some of its funds to ensure unconnected families in public housing have high-quality Internet access, it is not clear that rural Garrett County in the western part of the state is harmed. Local governments do not receive different amounts of funds based on whether they spend it on broadband or other allowable expenses.

See Christopher Mitchell and other from the Institute for Local Self Reliance in the Broadband Breakfast Live Online for Wednesday, January 19, 2022 — The Community Broadband Network Approach to Infrastructure Funding

Broadband Breakfast on January 19, 2022 — The Community Broadband Network Approach to Infrastructure Funding

States could be the issue. Perhaps Commissioner Carr is concerned that Maryland will use some of its SLFRF money for broadband and it will spend too much in urban areas rather than rural regions. That would be an historical anomaly, even though there are far more people living in urban areas than in rural areas who are not on the Internet. And yet, nearly all state and federal dollars have gone to rural areas for infrastructure improvements, with very little being spent to help the low-income families left behind in urban areas. There is no history of states prioritizing urban investments over rural.

Bad Data, Srsly?

What I found really galling though was this bit:

  • It gets worse. The Treasury rules allow these billions of dollars to be spent based on bad data. It does this by authorizing recipients to determine whether an area lacks access to high-speed Internet service by relying on informal interviews and reports—however inaccurate those may be—rather than the broadband maps that the federal government has been funding and standing up

It is 2022. The FCC announced three weeks ago that it did not have a timeline for better maps.  Many of us have complained for more than 10 years about the misleading and inaccurate collection of claims that the FCC advances as its understanding of where broadband exists in the United States.

Commissioner Carr has been an FCC Commissioner for more than four years, nearly all of that time when his agency was run by a Republican. For part of that time, the Republicans controlled the Presidency, the House, and the Senate. They have no excuse for why his party’s FCC finished with the same bad data processes it started with. No one was defending the FCC data or maps during those years, but the FCC did not bother to begin collecting new data.

Now Commissioner Carr claims that “parts of this country” have broadband services at speeds near 100 Mbps down and 20 Mbps up. OK, Commissioner. Where? Do you have a secret list? No, these are talking points to obscure the fact that Commissioner Carr and his agency has utterly failed to track precisely what “parts of this country” actually has access to broadband.

Will I agree that most, perhaps 80 percent, of the country has access to 100 by 20 Mbps? Yes. But that doesn’t matter if no one can agree which homes are well-served. And it opens up a whole other set of questions that Carr neatly sidesteps, which is that contemporary broadband service goes beyond the academic question of whether an ISP provides that service most of the time at some price. If the price isn’t affordable, then there is a problem that needs to be addressed. Or as we like to say, if it’s not affordable, it’s not accessible. And, if the service is not very reliable, then there is a problem that must be addressed.

This is why the final rule is both necessary and good: because it allows communities the flexibility they need to address not just the gaps in infrastructure, but reliability and affordability as well. But of course Commissioner Carr should know that we do not have this information at the federal level, because I’m quite sure he opposes collecting pricing and other information. Despite the many instances in which providers have lied to the Commission in presenting the areas they offer service, Carr objects per se to local evidence gathered via interviews to understand where broadband actually is.

A Prediction: This Is Not A Problem

It is remarkable to see the amount of performative horror Commissioner Carr expresses at the prospect of a city like Baltimore using some of the Rescue Plan dollars to ensure its families in public housing are on the Internet, even if a cable provider could theoretically sell them Internet access for $75/month, or provide a subsidized service if they jump through all the right hoops. Compare that to the silence from the Commissioner when it became clear that the largest telephone companies took billions of dollars in broadband subsidies and might have forgotten to upgrade their services.

The SLFRF Treasury Rules give the appropriate amount of deference to local and state leaders to act in an utter void of information about what is available to each home. Commissioner Carr is deeply worried – because the largest cable and telephone companies are deeply worried – that some places will use these dollars to build networks that are unneeded or would create too much competition for the existing companies.

My prediction is that communities will not do this. Of course it’s not zero: a cardinal rule of dealing with large numbers of humans is that there are always outliers. But of the cities that allocate some of their SLFRF dollars to broadband infrastructure, they will overwhelmingly focus on areas where there are real affordability and reliability challenges from existing services. The reality is that very few of these investments will result in any material losses to existing ISPs, but the monopoly providers know that even modestly opening the door to locally built and operated infrastructure driven by community-driven solutions could open the floodgates to the competition they fear so much.

Commissioner Carr has spent years as one of a very small number of people that could correct the abject failure of the FCC to collect useful information about broadband deployments. The rest of us have had to move on and figure out how to work in the absence of data. The best option is to allow for local decision-making where they can collect evidence and act. And most importantly, they will have to take responsibility for their actions and lack of action in ways that FCC Commissioners often do not.

Editor’s Note: This piece was authored by Christopher Mitchell, director of the Institute for Local Self Reliance’s Community Broadband Network Initiative. His work focuses on helping communities ensure that the telecommunications networks upon which they depend are accountable to the community. He was honored as one of the 2012 Top 25 in Public Sector Technology by Government Technology, which honors the top “Doers, Drivers, and Dreamers” in the nation each year. This piece was originally published on MuniNetworks.org on January 20, 2022, 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.

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.

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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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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Bjorn Capens: Strong Appetite for Rural Broadband Calls for Next Generation Fiber Technology

The first operator to bring fiber to a community creates a significant barrier to entry for competitors.

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The author of this Expert Opinion is Björn Capens, Nokia Fixed Networks European Vice President

In July, the Biden-Harris administration announced another $401 million in funding for high-speed Internet access in rural America. This was just the latest in a string of government initiatives aimed at helping close the US digital divide.

These initiatives have been essential for encouraging traditional broadband providers, communities and utility companies to deploy fiber to rural communities, with governments cognizant of the vital role broadband connectivity has in sustaining communities and improving socio-economic opportunities for citizens. 

Yet there is still work to do, even in countries with the most advanced connectivity options. For example, fixed broadband is missing from almost 30 percent of rural American homes, according to Pew Research. It’s similar in Europe where a recent European Commission’s Digital Divide report found that roughly 18 percent of rural citizens can only get broadband speeds of a maximum 30 Mb, a speed which struggles to cope with modern digital behaviors. 

Appetite for high-speed broadband in rural areas is strong

There’s no denying the appetite for high-speed broadband in rural areas. The permanent increase in working from home and the rise of modern agricultural and Industry 4.0 applications mean that there’s an increasingly attractive business case for rural fiber deployments – as the first operator to bring fiber to a community creates a significant barrier to entry for competitors. 

The first consideration, then, for a new rural fiber deployment is which passive optical network technology to use. Gigabit PON seems like an obvious first choice, being a mature and widely deployed technology. 

However, GPON services are a standard offering for nearly every fiber broadband operator. As PON is a shared medium with usually up to 30 users each taking a slice, it’s easy to see how a few Gigabit customers can quickly max out the network, and with the ever-increasing need for speed, it’s widely held that GPON will not be sufficient by about 2025. 

XGS-PON is an already mature technology

The alternative is to use XGS-PON, a more recent, but already mature, flavor of PON with a capacity of 10 Gigabits per second. With the greater capacity, broadband operators can generate higher revenues with more premium-tier residential services as well as lucrative business services. There’s even room for additional services to run alongside business and residential broadband. For example, the same network can carry traffic from four G and five G cells, known as mobile backhaul. That’s either a new revenue opportunity or a cost saving if the operator also runs a mobile network. 

This convergence of different services onto a single PON fiber network is starting to take off, with fiber-to-the-home networks evolving into fiber for everything, where homes, businesses, industries, smart cities, mobile cells and more are all running on the same infrastructure. This makes the business case even stronger. 

Whether choosing GPON or XGS-PON, the biggest cost contributor is the same for both: deploying fiber outside the plant. Therefore, the increased cost of XGS-PON over GPON is far outweighed by the capacity increase it brings, making XGS-PON the clear choice for a brand-new fiber deployment. XGS-PON protects this investment for longer as its higher capacity makes it harder for new entrants to offer a superior service. 

It also doesn’t need to be upgraded for many years, and when it comes to the business case for fiber, it pays to take a long-term view. Fiber optic cable has a shelf-life of 75 or more years, and even as one increases the speeds running on fiber, that cable can remain the same.  

Notwithstanding these arguments, fiber still comes at a cost, and operators need to carefully manage those costs in order to maximize returns. 

Recent advances in fiber technology allow operators to take a pragmatic approach to their rollouts. In the past, each port on a PON server blade could only deliver one technology. But Multi-PON has multiple modes: only GPON, only XGS-PON or both together. It even has a forward-looking 25G PON mode. 

This allows an operator to easily boost speeds as needed with minimal effort and additional investment. GPON could be the starting point for fiber-to-the-home services, XGS-PON could be added for business services, or even a move to 25G PON for a cluster of rural power users, like factories and modern warehouses – creating a seamless, future-proof upgrade path for operators. 

The decision not to invest in fiber presents a substantial business risk

Alternatively, there’s always the option for a broadband operator to stick with basic broadband in rural areas and not invest in fiber. But that actually presents a business risk, as any competitor that decides to deploy fiber will inevitably carve out a chunk of the customer base for themselves. 

Besides, most operators are not purely profit-driven; they too recognize that prolonging the current situation in underserved communities is not great. High-speed broadband makes areas more attractive for businesses, creating more jobs and stemming population flows from rural to urban centers. 

But rural broadband not only improves lives, but it also decreases the world’s carbon emissions both directly, compared to alternative broadband technologies, and indirectly by enabling online and remote activities that would otherwise involve transportation. These social and economic benefits of fiber are highly regarded by investors and stockholders who have corporate social responsibility high on their agendas. 

With the uber-connected urban world able to adopt every new wave of bandwidth-hungry application – think virtual reality headsets and the metaverse – rural communities are actually going backwards in comparison. The way forward is fiber and XGS-PON. 

Björn Capens is Nokia Fixed Networks European Vice President. Since 2017, Capens has been leading Nokia’s fixed networks business, headquartered in Antwerp, Belgium. He has more than 20 years of experience in the fixed broadband access industry and holds a Master’s degree in Electrical Engineering, Telecommunications, from KU Leuven. 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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