Many of the same civil rights groups that regularly advocate their support of giant corporate telecom mergers are back once again to show their support for the controversial T-Mobile/Sprint merger. But that support does not come for free.

A “Memorandum of Understanding” (MOU) that includes “philanthropy and community investment” that does not exclude direct financial contributions from the two wireless companies to these civil rights groups is a major part of a new “understanding” announced today between several organizations founded to represent minority interests and T-Mobile and Sprint that the wireless companies hope will deliver an imprimatur for the troubled merger deal with regulators and politicians.

The key items in the MOU:

1. Standing up a national diversity and inclusion council comprised of non-employees from diverse groups, including each of the multicultural leadership organizations that are party to the MOU, and other highly esteemed community leaders to facilitate open communication over the development, monitoring, and evaluation of diversity initiatives and to provide advice to the New T-Mobile senior executives.

2. With the help and input of the council, developing and implementing a Diversity Strategic Plan addressing each of the key elements of the MOU and reflecting best practices in the industry.

3. Increasing the diversity of its leadership and workforce at all levels including its Board governance, to reflect the diversity of the communities in which it operates.

4. Making a targeted effort to increase partnerships, business, and procurement activities with diverse business enterprises in a range of categories such as financial and banking services, advertising, legal services and asset sales. New T-Mobile aims to become a member of the Billion Dollar Roundtable by 2025.

5. Expanding wireless offerings to low-income citizens, underserved minority populations and insular and rural areas, and to organizations serving these underserved communities [including] a significant philanthropic investment for institutions serving disadvantaged or underrepresented communities to support tech entrepreneurship and to bridge the gap in literacy.

The groups, most familiar to Stop the Cap! readers that have followed civil rights groups engaged in pay for play advocacy, include:

• National Urban League: A notorious friend of big cable and phone companies, the Urban League is a regular supporter of telecom mergers and opposes net neutrality.
• The League of United Latin American Citizens (LULAC): Brazenly photographs its executive leadership accepting big checks from AT&T and other telecom companies.
• National Action Network: Rev. Al Sharpton’s group loves to support telecom mergers and acquisitions and lobbies to block consumer protection regulation.
• UnidosUS: Receives most of its funding from corporate interests.
• Asian Americans Advancing Justice | AAJC
• OCA – Asian Pacific American Advocates: One of Comcast’s special friends, OCA advocated against new consumer privacy rules two years ago claiming poor people want more intrusive ads.

In a joint statement, the groups urged the FCC to approve the T-Mobile/Sprint merger “so the combined New T-Mobile can definitively launch these enhanced diversity efforts and expansion of service to all communities included in the MOU.”

“T-Mobile is honored to partner with these visionary organizations to create an action plan of this magnitude that includes commitments to diversity and inclusion that are bolder than ever before,” John Legere, CEO of T-Mobile and CEO of New T-Mobile, said in a statement. “With this MOU, we have doubled down on ensuring we represent the communities we serve today and will serve as the New T-Mobile in the future. We are excited for the New T-Mobile to become a reality so we can get to work on delivering these commitments.”

Except in most cases, these kinds of arrangements serve mostly as window dressing, gussying up otherwise nakedly anti-consumer merger deals under the guise of serving minority or disadvantaged interests. Money often quietly flows between the corporate and the non-profit side, usually in the form of donations. Some groups may also offer token advisory board positions to executives, which usually cements an ongoing advocacy relationship.

Members of these civil rights organizations have a right to be puzzled why such groups are spending significant time and resources engaged in corporate advocacy. The interests of two major corporations cementing a multi-billion dollar merger deal and civil rights groups trying to fight discrimination and improve the lives of their constituents are often tangential, if not in direct opposition to each other. Apparently the money that usually comes with these arrangements matters much more.

Charter Communications is envisioning building out a rural fixed wireless network on the edges of its existing service areas in rural parts of New York and North Carolina to attract new customers without spending money on extending its hybrid fiber-coax (HFC) network to high-cost areas.

Charter has spent more than a year conducting mobility and fixed wireless tests using small cells in several cities across the country to determine if the technology is commercially viable. The company is focusing on two service scenarios: rural areas within a mile or two of its existing cable footprint and urban and suburban areas already served by Spectrum’s HFC network.

Charter’s rural initiative uses the Citizens Band Radio Service (CBRS) band at 3.5 GHz to provide rural fixed wireless service to areas just out of reach of its cable network. Trials of fixed wireless service are already underway or will be soon in exurban and rural areas near Denver, Tampa, Bakesfield, Calif., Coldwater, Mich., and Lexington, Ky. These first trials were designed to prove the concept of delivering high-speed fixed wireless internet in different areas of the country. In 2020, additional trials are planned for rural parts of New York and North Carolina, with a tentative plan to launch service that same year.

“Results of these trials have been promising as we were seeing speeds that significantly exceed the FCC’s definition of high speed broadband in most circumstances which would allow for video streaming and the use of multiple apps simultaneously,” Charter wrote on its Policy Blog. “We believe fixed wireless access technologies using this mid-band spectrum could offer a cost-effective solution for providing broadband service to homes and businesses in harder to reach rural areas.”

The next step for Charter is a full service trial in rural counties in New York and North Carolina that would offer high-speed wireless broadband to residential customers. Charter began testing its fixed wireless service in Davidson County, N.C. roughly between the communities of Lexington and Salisbury. Each of Charter’s four temporary transmitting locations in Davidson County are licensed to serve a radius of up to 9.3 miles, but most customers are significantly closer to the transmitting sites. Participants get free service for the duration of the trial, a free outdoor antenna and a free combination receiver/router. All equipment remains the property of Charter and is to be returned at the end of the trial.

Charter told attendees at last week’s SCTE/ISBE Cable-Tec Expo in New Orleans that results exceeded performance expectations. Customers are getting in excess of 25/3 Mbps service, and there is enough bandwidth left over for Charter to consider offering a true wireless triple play package of video, internet, and home phone service.

Craig Cowden, Charter’s senior vice president of wireless technology, told attendees Charter envisions CBRS wireless service to extend the Spectrum cable footprint into rural areas just outside of the cable company’s wired footprint, and a good economic case might be possible to offer service to residents that usually fail the company’s Return On Investment test that governs whether Charter will extend wired service into unserved neighborhoods within their franchise area.

But Cowden also sees Charter deploying CBRS in urban and suburban areas to handle wireless traffic for a growing number of its wireless customers. Spectrum Mobile relies on free Wi-Fi networks and an agreement with Verizon Wireless to provide 4G LTE connectivity for its customers. Charter can begin reducing costs by moving mobile traffic off of Verizon’s network and onto Charter’s own mobile network, likely operating on CBRS frequencies.

The CBRS band is suitable for outdoor traffic, but is likely not going to work well when customers go indoors. Charter plans to hand that traffic back to its extensive network of Wi-Fi hotspots, mostly located at businesses using Spectrum’s commercial service, and the customer’s own in-home Wi-Fi.

Charter has been testing its mobile CBRS service from test transmitters in Tampa and Charlotte, N.C., but plans a much more extensive test in New York and Los Angeles utilizing more than 250 cell sites.

In 2017 and 2018, Charter also filed requests for special temporary authority to test 5G service in the 28 GHz millimeter wave band, but those tests appear to be exploratory and there is no indication a commercial deployment effort is forthcoming soon.

Charter’s Experimental CBRS Projects (based on filings with the FCC for experimental and permanent licenses)

Lexington, Kentucky

WM9LXR was licensed on March 23, 2018 and a CBRS transmitter capable of reaching up to a radius of 9.3 miles was placed on top of the Fairfield Inn & Suites by Marriott Lexington North at 2100 Hackney Place in Lexington. The license expired Sept. 19, 2018. A new application to operate this transmitter was filed Nov. 16, 2018 expiring June 4, 2019.

Centennial, Colorado

WM9XTL was licensed on June 1, 2018 and a CBRS transmitter capable of reaching up to 15 miles away was erected just northeast of the Centennial Airport along E. Easter Avenue. This transmitter was designed to experiment with mobile CBRS services. The license expired Dec. 5, 2018.

Another experimental license to test CBRS service was sought Nov. 16, 2018 and expired June 4, 2019.

A license to operate WO9XOY was filed on May 10, 2019 to experiment with a private fixed wireless LTE network in the CBRS band for a corporate client from the same transmitter location as above. The license would expire Dec. 2, 2019.

Los Angeles

WM9XXU was licensed on June 22, 2018 to test CBRS mobile service from four transmitting sites around Baird Park, Van Nuys, Baldwin Hills, and West Anaheim Junction areas. The license expired Dec. 22, 2018.

An application to operate WN9XRT was filed with the FCC on Nov. 16, 2018. CBRS transmitters would operate from the same neighborhoods as above to conduct outdoor and indoor fixed wireless mobile testing within 8 miles of the four fixed locations until Dec. 22, 2018.

An application to run WO9XQW on an experimental basis was filed May 31, 2019 to expire Dec. 19, 2019. The license application described the CBRS test project:

Charter will deploy experimental fixed and mobile equipment in various configurations. Depending on the testing scenario, devices will be deployed on existing aerial cable strand, on existing buildings/poles or indoors.

Specifically, Charter will use the following deployment approaches:

1. Strand mount deployment: 118ft. height.
2. Building/pole mount deployment: up to 100ft. height.
3. Indoors: up to 40ft. height (3rd floor indoor).

New York

WM9XXV was licensed on June 22, 2018 to test various CBRS applications from three transmitter sites:

125th Street & Rockaway Blvd. Jamaica
72nd Street Flushing
South Beach, Staten Island

The license expired Dec. 22, 2018.

An application for WN9XRS was filed with the FCC on Nov. 16, 2018 to expire Dec. 23, 2018 to test CBRS services from the three locations noted above. On May 31, 2019, another application was filed to continue testing until Dec. 19, 2019.

Charlotte, North Carolina

A pending application filed Aug. 28, 2019 for WN9XHY, a CBRS transmitter located on S. Caldwell Street next to Spectrum Center was filed on Aug. 28, 2018. Charter sought to cover a radius of just over 9 miles to test fixed and mobile applications with an expiration of March 16, 2019.

An application for WO9XCX was filed on March 15, 2019 set to expire Sept. 29, 2019. This is a CBRS experimental project to test indoor and outdoor fixed and mobile wireless reception from two fixed transmitter locations located at Spectrum Center and the Clanton Park/Roseland neighborhood. An application for an additional experimental license was filed March 15, 2019 with an operational end date of Sep. 28, 2019.

Tampa, Florida

An application for WN9XHZ, a CBRS transmitter covering up to 8 miles from Ybor Heights was sought on Aug. 28, 2018 to expire March 16, 2019. It was to test fixed and mobile CBRS applications.

Keystone, Iowa

A license to operate WN9XIX from a mobile transmitter van was filed Sept. 6, 2018 to expire March 30, 2019. An additional application to operate a similar CBRS test project was filed Sep. 17, 2019 and set to expire March 28, 2020. On Sep. 20, 2019 an application was filed to operate WP9XIC until March 29, 2020. This latter project is designed “to evaluate 5G frequencies and technologies for their use in point-to-multipoint access network capacity (e.g., rate versus range) and data throughput. The proposed operations will advance Charter’s understanding of technology and network potential using mid-band spectrum and will advance the potential deployment of fixed and mobile 5G services.”

Bowling Green (and Lake Wales), Florida

A license application filed Nov. 28, 2018 proposed to test wireless service in the so-called C-Band spectrum now used by satellites to check how well it performs with the potential of interference from licensed satellite TV services. Outdoor-only tests of wireless service within a two-mile radius of fixed transmitter locations in the vicinity of Bowling Green and Lake Wales were underway until the license for WN9XSQ expired June 10, 2019.

An additional license to further test potential C-Band spectrum for interference issues was sought to begin Dec. 12, 2018 and expiring June 10, 2019.

Davidson County, North Carolina

Charter applied for an ongoing license to operate WJ2XZT, a CBRS project consisting of four transmitters each serving a radius of approximately nine miles, to provide fixed wireless service to customers in this part of rural North Carolina. The transmitters are located at three locations:

153 Sigmon Road, Lexington
185 Chestnut Grove Church Road, Lexington
784 Mount Carmel Road, Lexington

Park City, Utah

On July 3, 2019 the company applied for WK2XIP, a new one-year experimental project:

“As part of its efforts to lead the industry in broadband innovation, Charter intends to conduct fixed wireless experiments in the 3550-3700 MHz band. The proposed operations will advance Charter’s understanding of 5G technology and network potential in mid-band spectrum and will advance the potential deployment of 5G fixed and mobile services.

“Charter will conduct the proposed test using antennas at a location in the Park City, Utah area. These experiments will evaluate the 3550-3700 MHz frequencies and 5G technologies for their use in real-time communications in a low-latency environment.

“The tests will utilize fixed transmitters with a 2km or smaller effective radius. The antennas will be mounted on a hydraulic mast attached to a mobile trailer, which will be located at the requested test location. The radios will be pointed towards the side of the mountain, the peak of which is higher than the peak height of the mast. The trailer mast can be raised to 10.4 meters.”

Colorado Springs, Colorado

An experimental license for WO9XXJ was filed July 18, 2019 to test a millimeter wave 5G network in the 37 GHz band. The license expires Jan. 28, 2020.

Verizon and T-Mobile are redlining their up and coming 5G wireless services to target wealthy neighborhoods and business districts while shunning the urban poor.

Dave Burstein examined the coverage maps of both carriers in cities like Manhattan and found a distinction in the service available in wealthy southern Manhattan and what upper Manhattan neighborhoods including Harlem and the mostly Latino Washington Heights are getting. For both companies, 5G is not much of a priority for Brooklyn either.

“I do not think T-Mobile specifically intended to exclude people of color, but that seems to be the practical effect,” Burstein wrote.

Ronan Dunne, executive vice president & group CEO of Verizon Consumer confirmed that Verizon will be targeting 5G service to areas where it makes the most economic sense. He said that more than half of Verizon Wireless customers will continue to get 4G LTE-like speeds, with the rest eventually upgraded to 5G service.

“So we’ve taken a very clear view that we want to have both a coverage strategy and a capability strategy. And a very large majority of the volume of data that we carry on our networks goes to large, dense urban environments,” Dunne told investors recently. “So from a population point of view, it’ll be significantly less than half of the customers [getting 5G]. But from a data traffic point of view, it’s significantly more than half. So when it comes to the ability to use 5G as a significant capacity enhancement, there’s more of an opportunity to leverage that in the urban areas.”

In other words, Verizon plans to target population dense urban areas for 5G service the most, because that is where most of its data-loving customers live and where they network’s cost effectiveness may be the highest. Although the geographic coverage of 5G will seem relatively small, the population density of areas targeted for 5G service is not.

Verizon has been touting its forthcoming nationwide 5G network, but Dunne has hinted to investors that the devil will be in the details. Not every customer will have access to Verizon’s super fast millimeter wave 5G service. In fact, at least half the country will be serviced by existing 4G LTE cell towers upgraded to provide 5G service on lower frequencies capable of reaching far beyond the coverage area offered by millimeter wave service. But that will also mean a much larger number of customers will share the same 5G network connection, potentially dramatically reducing speed and performance. Dunne said the performance of this type of 5G service “will approximate a good 4G service.”

Burstein notes in real terms, this will mean a significant difference in network speed. Verizon’s millimeter wave service will be capable of delivering 1-2 Gbps, while Verizon’s 5G upgrade of its existing 4G cell towers will deliver speeds in the low hundreds of megabits per second, potentially even slower on crowded cell sites.

After learning from the experiences of providing a wireless 5G home broadband alternative in a handful of U.S. cities, Verizon is preparing to launch a refreshed 5G Home fixed wireless product in all 30 cities where it intends to provide mobile 5G service this year.

The biggest change will be a new emphasis on self-installs. Verizon estimates about 80% of customers pre-screened online as qualified for the service can install it themselves with an indoor antenna. That is a big change for Verizon, which used to rely on technicians installing a fixed antenna on the side of a customer’s home. A new receiver expected to be introduced in 2020 is also expected to boost reception through the use of a new high-powered chipset, likely including Qualcomm’s new QTM527 mmWave antenna module that was custom designed to enhance and extend the range of 5G fixed wireless services. Verizon’s current 5G Home equipment uses a chipset originally designed for 5G smartphones.

Ronan Dunne, CEO of Verizon Consumer Group, said Verizon Home 5G will be sold as a companion product wherever Verizon’s 5G millimeter wave network debuts.

“We’re now ready to go mass market,” Dunne told a group of investors.

U.S. cities with Verizon 5G Ultra Wideband

• Atlanta
• Chicago
• Denver
• Detroit
• Houston*
• Indianapolis*
• Los Angeles*
• Minneapolis
• Providence
• Sacramento*
• St. Paul
• Washington, D.C.
• Phoenix

(*-These cities, except for Indianapolis, only have fixed wireless 5G Home broadband at this time.)

U.S. cities planned for Verizon 5G Ultra Wideband deployment in 2019

• Boston
• Charlotte
• Cincinnati
• Cleveland
• Columbus
• Dallas
• Des Moines
• Houston
• Indianapolis
• Kansas City
• Little Rock
• Memphis
• San Diego
• Salt Lake City

But where that market will exactly be is hard to tell. Verizon relies heavily on its service address qualification tool, which shows if a prospective customer can obtain the service. That tool is refined enough to ensure that over 90% of Verizon’s fixed wireless traffic stays on its 5G network, with only around 10% falling back to Verizon’s existing 4G LTE network.

Verizon uses its tool to assure “qualified” customers are well inside the radius of its 5G coverage area. An analysis found Verizon’s millimeter wave network, which operates in the 28 GHz band, has a limited range. Although Verizon predicted its network could reach 1,000 feet from each small cell location, the website only qualified those in Sacramento living within around 500 feet of each small cell. Verizon is also heavily reliant on using light poles for smart cells, and these were not always suitable for the widest coverage.

Earl Lum of EJL Wireless Research explored Verizon’s 5G network in Sacramento and found it primarily targeting 5G Home customers. If Verizon is intending to cover entire cities with millimeter wave 5G, Lum said “you’re talking about a crapload of poles.” Some analysts expect Verizon will introduce lower band 5G service to increase and compliment its millimeter wave coverage areas. The impact traffic from Verizon’s 5G Home service will have on lower band 5G networks is not known. The home broadband replacement currently markets speeds of around 300 Mbps with no monthly data cap for as low as $50, if one also subscribes to Verizon Wireless mobile service. Any low band 5G service running from traditional macro cell towers will be shared with a much larger number of customers than those sharing a small cell, potentially creating capacity problems down the road.

One other change to report: Verizon’s newest 5G Home cities will launch using the official 5G NR standard, not the unofficial 5G TF standard Verizon used in the four early launch cities.

It is too early to tell whether incumbent phone and cable companies will perceive a significant competitive threat from Verizon’s high speed fixed wireless proposition. Early reports of the service’s limited coverage in the four launch cities and fears about the high cost of expanding 5G service seemed to calm operator fears of a new competitor. But Verizon has also said for months that it purposely limited its 5G Home network rollout until the official 5G standard emerged. The wireless operator has also used this past spring and summer to learn from its early experiences with fixed 5G service and cut expenses like required truck rolls for installation out of the business. The money saved could be plowed into a more robust network of 5G small cells covering larger areas.

A major battle between satellite owners, broadcasters, and the telecom industry has emerged over a proposal to repurpose a portion of C Band satellite spectrum for use by the wireless industry.

Multiple proposals from the wireless and cable industry to raid C Band satellite frequencies for the use of future 5G wireless networks suggest carving up a band that has been used for decades to distribute radio and television programming.

Before the advent of Dish Networks and DirecTV, homeowners placed 6-12′ large rotatable satellite dishes in backyards across rural America to access more than a dozen C Band satellites delivering radio and television programming. Although most consumers have switched to much smaller fixed satellite dishes associated with Dish or DirecTV, broadcasters and cable companies have mostly kept their C Band dishes to reliably receive programming for rebroadcast.

Now the wireless industry is hoping to poach a significant amount of frequencies in the C Band allocation of 3.7-4.2 GHz to use for 5G wireless service. Competing plans vary on exactly how much of the satellite band would be carved out. One plan proposed by Charter Communications and some independent cable companies would take 370 megahertz from the 500 megahertz now used by C Band satellites and sell it off in at least one FCC-managed auction to the wireless industry. A more modest plan by an alliance of satellite owners would give up 200 megahertz of the band, allowing wireless companies to acquire 180 megahertz of spectrum. To reduce the potential of interference, both major plans offer to set aside 20 megahertz to be used as a “guard band” to separate satellite signals from 5G wireless transmissions.

Much like the FCC’s repack of the UHF TV dial, which is forcing many stations to relocate to a much smaller number of available UHF TV channels, most proposals call on the FCC to subsidize dislocated satellite broadcasters and users with some of the auction proceeds to help pay the costs to switch to fiber optic terrestrial distribution instead.

Broadcasters and satellite companies claim the cable industry proposal would leave U.S. satellite users drastically short of the minimum 300 megahertz of satellite spectrum required to provide radio and television stations with network programming. Many rural broadcasters have complained that the cable industry plan calling for a shift to fiber optic distribution ignores the fact that there is no fiber service available in many areas. Other objectors claim fiber outages are much more common than disruptions to satellite signals, putting viewers at risk of a much greater chance of programming disruptions.

With spectrum valued at more than $8 billion at stake, various industry groups are organized into coalitions and alliances to either support or fight the proposals. The Trump Administration has made it known it is putting a high priority on facilitating the development of 5G services to beat the Chinese wireless industry, which is already moving forward on a major deployment of next generation wireless networks. The FCC, with a 3-2 Republican majority, has signaled it is open to reallocating spectrum to wireless carriers for the rollout of 5G service. Unfortunately, much of this spectrum is already in use, setting up battles between incumbent users threatened to be displaced and the wireless industry, which sees big profits from acquiring and deploying more spectrum.

With serious money at stake, strains are emerging among some individual members of the different industry groups. Late last week, Paris-based Eutelsat Communications quit the largest satellite owner coalition, the C-Band Alliance. The move fractured unity among the world’s satellite owners, just as the FCC seems ready to move on a reallocation plan. Eutelsat will now lobby the FCC directly, reportedly because of concerns among shareholders that splitting off significant amounts of C Band spectrum is inevitable and could drastically reduce the value of Eutelsat’s share price. Eutelsat reportedly wants to independently participate in the FCC’s proceeding, potentially securing a larger amount of compensation from the FCC for the spectrum it will give up as part of a final reallocation plan.

Whatever compensation plan emerges will run into the billions of dollars. Satellite dishes will probably require new equipment to shield signals from interference, may require re-pointing to a different satellite (which could prove problematic for some equipment originally installed in the 1980s), and may even require the launch of additional satellites to provide more capacity in the newly slimmed C Band.

The FCC is expected to decide on the reallocation proposals this fall, with a signal repack likely to take between 18-36 months before the frequencies can be cleared for use by wireless operators.

Satellite owners, mobile carriers, and cable operators discuss reallocating part of the satellite C Band for use by 5G wireless networks. Sponsored by the industry-funded Technology Policy Institute. Sept. 3, 2019 (44:10)