Critics question the wireless industry’s claim LTE-U and Wi-Fi can co-exist peacefully. (Image: EVOLVE)

Consumer groups and cable operators are warning the Federal Communications Commission a plan by the nation’s largest wireless carriers to introduce premium Wi-Fi services for their mobile customers may create serious interference problems for existing Wi-Fi users.

AT&T, Verizon, and T-Mobile are all members of EVOLVE, a group advocating for LTE-U and LAA, technologies that will depend largely on the unlicensed Wi-Fi bands to deliver wireless data to their mobile customers.

Cable operators fear the proposal will give mobile providers an unfair advantage, introducing more traffic into the already crowded Wi-Fi bands while mobile operators reserve the right to use a licensed control channel to shift their customers’ traffic back and forth between unlicensed and licensed spectrum at will. Cable industry critics of the plan claim allowing mobile operators to dump customer traffic into the Wi-Fi bands is likely to worsen interference, harming the cable operators’ investment in a growing network of Wi-Fi hotspots and in-home Wi-Fi.

Consumer groups agree with the cable industry.

The Open Technology Institute at New America, Public Knowledge, Free Press, and Common Cause have filed a joint statement with the FCC warning the agency “mobile carriers will have both the ability and strong incentives to use LTE-U and LAA to engage in anti-competitive behavior harmful to consumers,” all while making a tidy profit charging customers for the use of a service comparable to Wi-Fi, now a free alternative to the carriers’ 3G and 4G data networks.

The groups argue Wi-Fi standards were developed with unlicensed users in mind, able to co-exist peacefully with other similar Wi-Fi signals. The proposed LTE-U technology from wireless carriers is far less sensitive to neighboring signals.

“LTE-U/LAA is designed to be centrally controlled by a network anchored in a separate, exclusively licensed frequency band,” the consumer groups wrote. “3GPP, the mobile industry standards body, may ultimately design LAA in a manner that shares fairly with Wi-Fi and other unlicensed technologies; yet several studies filed by commenters demonstrate that the version of LTE-U that U.S. carriers plan to deploy by next year coexists poorly with Wi-Fi, degrading both throughput and latency (delay).”

Critics contend the wireless industry’s proposed service is not as likely to use “Listen Before Talk” effectively, a standard that checks for existing traffic before powering up on an unlicensed frequency. Consumer groups fear mobile carriers will have both the ability and a strong incentive to use LTE-U and LAA to charge consumers for the use of unlicensed spectrum and give themselves an unfair advantage by escaping the interference its own technology can cause other users.

“Carriers also have powerful incentives to use LTE-U to deter mobile market entry by ‘Wi-Fi First’ providers, such as wireline ISPs,” argue the consumer groups, also referring to independent providers like Republic Wireless that depend primarily on Wi-Fi for smartphone connectivity. “Carriers deploying LTE-U will have the apparent option to adjust their access points to introduce just enough latency to frustrate consumer use of real-time applications, such as video calling.”

Another incentive is money. For several years, wireless carriers have encouraged customers to offload their mobile data traffic to Wi-Fi. But since Wi-Fi traffic does not count against the customer’s usage allowance, it also reduces revenue opportunities. LTE-U is a variant of LTE, and carriers traditionally do count that traffic against a customer’s usage allowance. For the first time, mobile customers will accrue usage charges based on their use of unlicensed frequencies. For some, they may have no other choice.

Ellen Satterwhite, a spokesperson for WifiForward, a coalition of companies advocating for more unlicensed spectrum for Wi-Fi, said LTE signals never play well with traditional Wi-Fi.

“When LTE and Wi-Fi signals collide, LTE wins,” Satterwhite said.

“The wireless carriers have completely changed their tune about Wi-Fi—because they have to,” said David Callisch, vice president of corporate marketing for Ruckus Wireless, a Sunnyvale, Calif.-based maker of Wi-Fi hardware, whose customers include Verizon and AT&T. “Wi-Fi for them is like a train going down the track,” Callisch told Bloomberg BNA in an interview. “You could get hit by it or you could jump on the train. They’re jumping on the train.”

“Carriers have historically hated Wi-Fi, because they can’t control it,” Callisch added. “They’ve always liked the licensed band, because they can buy it and they can control it and they can deliver a quality of service to customers over it. With Wi-Fi, you can’t do that.”

But with LTE-U they have the control they crave, able to use network management technology that prioritizes their customers over other conventional Wi-Fi users. Even better, they can charge customers for using it.

Both cable operators and consumer groups want engineers, not business executives, to carefully develop standards and rules that guarantee Wi-Fi users can co-exist with other users of unlicensed frequencies before the technology is switched on.

Burn Her! T-Mobile CEO John Legere announces a data hog crackdown.

T-Mobile’s CEO has declared war on about 3,000 current customers caught “stealing data from T-Mobile” by using workarounds to avoid T-Mobile’s tethering usage allowance.

T-Mobile customers with unlimited 4G LTE plans get a fixed allowance to be used for tethering when using the Smartphone Mobile HotSpot feature, which allows laptops, tablets, and other wireless devices to share a T-Mobile wireless data connection.

“These violators are going out of their way with all kinds of workarounds to steal more LTE tethered data,” said John Legere, CEO of T-Mobile USA. “They’re downloading apps that hide their tether usage, rooting their phones, writing code to mask their activity, etc. They are ‘hacking’ the system to swipe high-speed tethered data.”

Legere claims the “clever hackers are willfully stealing for their own selfish gain” and are running up as much as two terabytes of usage a month over T-Mobile’s network. Legere thunders he won’t allow this on his watch and the company is starting a campaign of countermeasures this week to go “after a small group of users who are stealing data so blatantly and extremely that it is ridiculous.”

Legere was not specific about how T-Mobile identifies customers it considers to be abusing its network, but a new FAQ on the carrier’s website explains what will happen to those deemed to be exploiting workarounds to exceed T-Mobile’s standard 7GB tethering allowance:

We’re first warning these customers that they’re illegally using more data than they bought. We hope folks will stop on their own so they can keep their current plan. These customers are on an unlimited 4G LTE smartphone plan that includes a set amount of Smartphone Mobile HotSpot data, but they’re using workarounds to make their tethering look like smartphone usage which helps them use significantly more 4G LTE tethering than their plan includes.

Customers who continue to do this will be warned, then lose access to our Unlimited 4G LTE smartphone data plan, and be moved to an entry-level limited 4G LTE data plan.

Legere

Legere is clearly concerned the crackdown could be interpreted by the Federal Communications Commission as a Net Neutrality violation.

“These abusers will probably try to distract everyone by waving their arms about throttling data,” Legere wrote. “Make no mistake about it – this is not the same issue. Don’t be duped by their sideshow. We are going after every thief, and I am starting with the 3,000 users who know exactly what they are doing. The offenders start hearing from us tomorrow. No more abuse and no risk to the rest of our customers’ experience. It’s over. If you are interested, you can find more info in our [FAQ].”

The FCC has no rules prohibiting usage caps, but the issue of speed throttling is less settled and Legere’s comments are intended to frame the issue in terms of data theft and violations of the company’s terms and conditions.

Carriers are often less lenient with hotspot usage because desktop computers and laptops often consume much more data than portable handheld devices like tablets and smartphones. T-Mobile admits that customers who need to consume a lot of data should find another ISP:

[Wired] Broadband services would be a better solution for customers who need more high-speed for tethered devices.

With billions of dollars in new revenue and royalties to be made, Qualcomm and some members of the wireless industry are pushing regulators to quickly approve a new version of LTE wireless technology that will share many of the same frequencies used by home and business Wi-Fi networks, creating the potential for speed-killing interference.

Wireless operators believe LTE-Unlicensed (LTE-U) could be used to offload much of the growing wireless data traffic off traditional 4G LTE wireless data networks. With the cost of securing more wireless spectrum from regulators growing, LTE-U technology would allow operators like AT&T, Verizon, Sprint and T-Mobile to use the U-NII-1 (5150-5250MHz) and U-NII-3 (5725-5850MHz) unlicensed bands currently used for Wi-Fi to deliver high-speed wireless broadband traffic to their customers.

Qualcomm and Ericsson, behind the newest iteration of LTE, have a vested interest promoting it as the ideal choice for metrocell, indoor enterprise, and residential small cell applications. Every manufacturer incorporating LTE-U technology into everything from carrier-owned microcells to smartphones will owe royalty payments to both companies. With billions at stake, Qualcomm is doing everything possible to tamp down fears LTE-U signals will create harmful interference to Wi-Fi signals.

[flv]http://www.phillipdampier.com/video/CES2015 Qualcomm Demonstrates LTE-U 1-2015.mp4[/flv]

At the Consumer Electronics Show in Las Vegas held in January, a Qualcomm representative went as far as suggesting LTE-U will improve home Wi-Fi service. (5:42)

RCRWireless News:

[Qualcomm] set up a screened room with eight pairs of access points occupying the same channel and added Wi-Fi access-point terminals in one room and LTE-U terminals in another. The results show the average throughput of 3.3Mbps with Wi-Fi alone more than doubled to 6.7Mbps when the LTE-U access point was introduced.

In another test to show that LTE-U is a better neighbor to Wi-Fi than Wi-Fi itself, they took eight Wi-Fi nodes and replaced four of them with LTE-U nodes, the result of which showed a 1.9Mbps increase in average Wi-Fi throughput. In almost every test, the LTE-U enhanced network outperformed traditional Wi-Fi.

Burstein

Industry observer Dave Burstein is concerned advocates of LTE-U are trying to rush approval of the technology without verifying Qualcomm’s non-interference claims.

“The telcos are considering 40 and 80MHz channels that could easily swallow half of more of the Wi-Fi spectrum,” Burstein writes in response to an EE Times article about the technology. “If Wi-Fi is important, that’s a mistake to allow. Advocates are trying to rush it through even though there is not a single independent test or field trial.”

Qualcomm dismisses the interference complaints pointing to its own research showing the two standards can co-exist adequately. But multi-billion dollar wireless companies with nationwide Wi-Fi networks at stake are far less confident. In fact, LTE-U has already divided the two largest wireless carriers in the United States. Verizon Wireless is an original proponent of LTE-U while AT&T has expressed “concern,” a polite way of saying it isn’t happy. What separates AT&T and Verizon Wireless? AT&T has invested in a nationwide network of more than 34,000 Wi-Fi hotspots. Verizon offers just over 5,000, most for FiOS customers or those in especially high traffic venues.

A Stanford University professor with no ties to Qualcomm or the wireless industry privately shared his belief allowing 5GHz Wi-Fi signals to commingle with LTE-U is going to cause problems.

The development of “Wild West” Wi-Fi has always tracked differently than the licensed cellular/wireless business. Over more than a decade, evolving Wi-Fi standards have come to expect interference from other nearby Wi-Fi signals. In a densely packed city, more than two dozen Wi-Fi signals can easily be found all competing for their own space across the old 2.4GHz and newer 5GHz unlicensed bands.

Wi-Fi proponents credit its robustness to its “politeness protocol.” Before a wireless router or home hotspot fires up its Wi-Fi signal, it performs several tests to check for other users and constantly adjusts performance by backing off when it discovers interference from other signals. That is why a user can receive strong Wi-Fi signals but still endure reduced performance, as the hotspot accommodates nearby hotspots and other traffic.

It works reasonably well, according to Rupert Baines, a consultant at Real Wireless.

“But [Wi-Fi signals] are delicate, and they rely on implicit assumptions that there aren’t other things there (or aren’t too many),” Baines told EE Times. “In effect, they behave as though the unlicensed band were not technology neutral but were Wi-Fi only.”

The intrusion of LTE-U changes everything.

[flv]http://www.phillipdampier.com/video/Wireless Week Tuesdays with Roger LTE-Us Gain is Wi-Fis Loss 3-24-15.flv[/flv]

On the March 24, 2015 episode of Tuesdays with Roger, Recon Analytics’ founder Roger Entner talks with Wireless Week about the questions raised as major carriers, including T-Mobile and Verizon Wireless, plan to launch LTE into unlicensed territory. Concerns abound, particularly for consumers and companies who rely on Wi-Fi and don’t want licensed use in unlicensed bands to interrupt that service. (7:31)

Change in and of itself is not necessarily a bad thing, especially if LTE-U is superior to Wi-Fi, and some proponents suggest it is. Jag Bolaria, an analyst at The Linley Group, argues LTE better manages data/call handoff better than Wi-Fi access points can. LTE is also a more efficient spectrum user than Wi-Fi.

Last week, South Korea’s LG U+ demonstrated LTE-U was capable of 600Mbps speed, eight times faster than traditional LTE. But to accomplish that level of speed, LG U+ had to occupy 60MHz of bandwidth in the 5.8GHz band and allocate an extra 20MHz from its traditional LTE service. The company plans to further expand its use of South Korea’s 5.8GHz unlicensed band by occupying 80MHz of it to further boost speeds to 750Mbps. But the company did not say how the tests affected others sharing the same frequencies.

If LTE-U is superior, then why not gradually move every user towards the technology and away from Wi-Fi?

Aptilo Networks AB CEO Torbjorn Ward answers LTE-U is a solution in search of a problem.

“I think LTE on unlicensed sounds like a good idea if it wasn’t for the fact that there are four billion devices on Wi-Fi out there,” he told Light Reading, noting that 802.11ac can already run at 100Mbps, so there’s little need for the LTE boost. “I think when it comes to unlicensed, you can do a longer range with LTE, but I don’t see the full benefit.”

That does not seem to matter to LTE-U’s developers or cell phone companies that lack robust Wi-Fi networks of their own.

In the original Qualcomm/Ericsson proposal, both companies promote the fact they could launch LTE-U in the unlicensed Wi-Fi bands “as-is.” That is a big problem for AT&T and other Wi-Fi users because LTE-U evidently employs few, if any protection protocols in its initial specifications for other traffic. Verizon Wireless is reportedly lobbying against the development of interference protection protocols and has publicly asserted its interest in deploying LTE-U regardless of other users.

“In [the] USA, there are no requirements for unlicensed deployment that require changes to LTE air interface,” Verizon stated in its proposal: “New Band for LTE deployment as Supplemental Downlink in unlicensed 5.8GHz in USA.”

LTE-Unlicensed has been characterized as “rude” for not avoiding interference to other users.

Clint W. Brown, business development director of mobility wireless connectivity at Broadcom, and a vice-chairman of the Wi-Fi Alliance counters it is premature to approve LTE-U in the unlicensed Wi-Fi band without more testing and information about its interference protocols.

“We’ve heard about the tests they’ve done, but it’s not factual,” Brown told EE Times. We haven’t seen the data and we don’t know how the tests were set up. First, I’d like to see if [LTE-U] can detect low-level signals. Second, I want to make sure it features a ‘Listen before Talk’ decision process so that LTE-U will wait for an opening rather than barging into the conversation already taking place in the unlicensed spectrum. Third, there should be a back-off mechanism, when it sees a collision. “We aren’t aware of any publicly available documents explicitly stating those attributes.”

The Federal Communications Commission has also now taken an interest and issued a public notice asking stakeholders and consumers to share their thoughts on LTE-U and a companion technology known as Licensed Assisted Access (LAA) that would hand off data sessions between a wireless carrier’s traditional 4G LTE network and LTE-U.

The makes the discussion political as well as technical. The FCC traditionally permits industry groups to define standards, but Republican Commissioner Mike O’Rielly now worries the FCC might butt into that process.

“The decision to jump into this space rather casually causes me great concern,” O’Rielly said. “In particular, any step that could insert the commission into the standards work for LTE-U comes with great risk. I will be vigilant in ensuring that the commission’s involvement does not result in taking sides with various stakeholders, hindering technological innovation, or having any say about what technologies should or should not be deployed.”

For the moment, O’Rielly’s concerns about the FCC are premature as long as a division exists over LTE-U among many of the industry players:

• Companies FOR LTE-U: Verizon, China Mobile, Qualcomm, Ericsson, NTT DoCoMo, T-Mobile USA, Deutsche Telekom, TeliaSonera, and China Unicom.  Equipment manufacturers also in support: Nokia, NSN, Alcatel-Lucent, LG, Huawei, ZTE, Hitachi, Panasonic, and others;
• Companies AGAINST LTE-U (as now defined): Orange, Telefónica, Vodafone, AT&T, Sprint, SouthernLINC, US Cellular, DISH and a handful of vendors.

Burstein also uncovered evidence the wireless industry may be stacking the deck against increased competition and consumers. He found 11 of the world’s largest wireless companies (including AT&T, T-Mobile, and Sprint) quietly colluding on a proposal that would block anyone other than currently licensed LTE users from being able to use LTE-U on a standalone basis. The opaquely-titled proposal, “Precluding standalone access of LTE on unlicensed carriers,” is at least frank about its reasoning: “Standalone deployment in unlicensed spectrum implies drastically different business models from nowadays and might impact the value chain.”

In other words, if consumers are able to get savings from LTE-U using a new generation of non-traditional providers like Republic Wireless or Cablevision’s Freewheel that do not depend primarily on cellular networks, it could cost those 11 traditional wireless companies billions in lost revenue. To stop that, the companies propose requiring a special LAA “guard signal” to stop standalone access of LTE-U. Since only licensed cell phone companies have access to those frequencies, it automatically locks out new upstarts that lack mobile spectrum of their own.

Sneaky insertions like that may be exactly why the Obama Administration’s FCC is being more activist about monitoring the wireless industry, potentially cutting off anti-competitive proposals before they can become adopted as part of a formal technical standard.

[flv]http://www.phillipdampier.com/video/Fairness to Wi-Fi and LTE unlicensed 5-8-2015.mp4[/flv]

RCRWireless News gets deep into the development of LTE-Unlicensed and how it will impact cellular infrastructure, Wi-Fi and small cells. (25:39)

The largest telecom companies in the United States, their trade associations, and Ajit Pai, one of two Republican commissioners serving at the Federal Communications Commission routinely claim America has the best broadband in the world. From the perspective of providers running to their respective banks to deposit your monthly payment, they might be right. But on virtually every other metric, the United States has some of the most expensive broadband in the world at speeds that would be a gouging embarrassment in other countries.

Slovakia – A Long, Tough History, But Better Broadband than the United States

Bratislava, the capital city of Slovakia, has existed since the year 907. From the 10th century until just after the end of World War 1, the city (then commonly known by its German name of Pressburg) was part of Hungary and the Austro-Hungarian empire. After the “War to End All Wars,” ethnic Czechs and Slovaks jointly formed a democratic Czechoslovak Republic in 1918 which existed peacefully until the Germans arrived in 1938 and renamed part of Czechoslovakia… Germany.

Unfortunately for the Czechs and Slovaks, life didn’t get much easier after the end of World War II. As Stalin sought to create a buffer zone between Germany (and western Europe) and the Soviet Union, Czechoslovakia, along with most of Eastern Europe, faded behind the Iron Curtain into the Soviet sphere of influence.

The city center of Bratislava

After decades of deterioration under autocratic rule, the Czechoslovak Velvet Revolution of 1989 restored multi-party democracy and Communism was was on its way to being fully extirpated across Europe.

By the time the June 1992 election results were announced, it was clear the country’s constituent Czechs and Slovaks had irreconcilable differences and were headed to national divorce court. On one side, the Czech-oriented Civic Democratic Party, headed by Václav Klaus. On the other, Vladimír Mečiar’s Movement for a Democratic Slovakia, whose aims were obvious based on its party name alone. With the writing on the wall, Klaus and Mečiar managed to work out an agreement on how to divide the country and on Jan. 1, 1993 the Czech Republic and the Slovak Republic were born.

Since the separation, Slovakia has prospered, and is now recognized to have a high-income advanced economy with one of the fastest growth rates in both the European Union and the OECD. It joined the EU in 2004 and adopted the Euro as its currency in 2009. Slovakia had to bring its economy up to date after fifty years of Communism. The country had a functioning telecommunications infrastructure, albeit one highly dependent on dilapidated equipment produced in the German Democratic Republic (the former East Germany) and the Soviet Union.

After the Slovak Republic was born, Slovenské Telekomunikácie maintained a monopoly on Slovak telephone lines and telex circuits under the close watch of the Ministry of Transport, Posts and Telecommunications. It took until the year 2000 for economic reforms to allow for the privatization of telecommunications. As was the case in many other central and eastern European countries, Germany’s Deutsche Telekom (T-Mobile) won a majority ownership in the company, which is today still known as Slovak Telecom.

The Slovak Broadband Marketplace Today

The Slovak government insisted that telecommunications networks in the country be competitive and it maintains oversight to make sure monopolies do not develop. It rejected claims that total deregulation and competition alone would spur investment. Slovakia welcomes outside investment, but also makes certain monopoly pricing power cannot develop. As a result, most residents of Bratislava have a choice of up to eight different broadband providers — a mix of cable, telephone, wireless, and satellite providers that all fiercely compete in the consumer and business markets.

Many providers are foreign-owned entities. UPC, Slovakia’s cable operator, is owned by John Malone’s Liberty Global. Slovak Telecom is owned by Germany’s T-Mobile/Deutsche Telekom. Tooway is a French company.

Prices are considerably lower than what American providers charge, although speeds remain somewhat lower than broadband services in Bulgaria, Romania, and the Baltic States. At one address on Kláštorská, a street of modest single family homes (some in disrepair), these companies were ready to install service:

• RadioLAN offers 18/1.5Mbps unlimited wireless service for $21.85 a month;
• UPC offers 300/20Mbps unlimited cable broadband for $30.63 a month;
• Slovanet offers 10/1Mbps DSL with a 240GB usage cap for $18.56 a month;
• Swan offers 10.2Mbps/512kbps unlimited DSL for $24.70 a month;
• Slovak Telecom offers 10/1Mbps DSL with a 240GB usage cap for $21.96 a month;
• Benestra offers 10/1Mbps DSL with a 4GB per day usage cap for $24.24 a month;
• Satro offers 9Mbps/768kbps unlimited wireless service for $29.32 a month;
• Tooway offers 22/6Mbps satellite Internet with a 25GB usage cap for $54.79 a month.

In other parts of the country, two providers are installing competing fiber broadband services. Slovak Telecom is slowly discarding its old copper wire infrastructure in favor of fiber optics, and is already providing 300Mbps service to some residents to better compete with UPC Cable. Some areas can get straight fiber service, others get VDSL, an advanced form of DSL offering higher speeds than traditional DSL. Orange, a provider not available in the immediate area of our sampled home, has already installed its own fiber service to over 100,000 fiber customers and is growing.

In comparison, Comcast sells 105Mbps service in Nashville, Tenn. for $114.95/mo (not including modem fee) with a 300GB monthly usage cap. That is one-third the speed of UPC Cable at nearly four times the cost… if you stay within your allowance. Prices only get higher after that.

T-Mobile has asked the Federal Communications Commission to investigate AT&T’s “artificially high roaming rates” charged when its customers travel outside of T-Mobile’s home service area.

T-Mobile is heavily reliant on AT&T for roaming service outside of major cities and the country’s smallest national wireless carrier complains AT&T is using their market power to put it at a major disadvantage, which could force new limits on roaming access in some areas.

T-Mobile provided examples of the damage already done by AT&T’s roaming rates:

“Limitless Mobile has severely restricted its customers’ access to AT&T’s network ‘for the sole reason that AT&T’s data roaming rates are too high and by continuing roaming access, Limitless could not maintain a commercially competitive retail wireless data offering to the general public,’” T-Mobile told the FCC.

The Rural Wireless Association noted that competing carriers “cannot sustain the provision of data roaming services if [they] must provide that service at a loss.”

The problem of data roaming rates is getting larger as carrier agreements are due for renewal at many mobile providers. Independent cellular companies are finding AT&T unwilling to renew at prices and terms comparable to their existing contracts. Instead, they face renewal rates that average a minimum of 10 and as much as 33 times higher than the national carriers’ retail rates.

For example, T-Mobile’s agreement with AT&T includes a data roaming rate that is now 150 percent higher than the average domestic rate that T-Mobile pays for data roaming.

This is one thousand percent higher than the data roaming rate negotiated between Leap Wireless and MetroPCS prior to their respective acquisitions, wrote T-Mobile.

With the stark price increases, carriers have begun imposing limits, including speed throttling and data caps, on customers when roaming on AT&T’s network.

Because of AT&T’s artificially high roaming rates, T-Mobile wireless customers roaming in South Africa have a better user experience than customers roaming on AT&T’s network in South Dakota, argues T-Mobile. Their speed is twice as fast, and their data usage is unlimited.

T-Mobile is asking the FCC to intervene by establishing some type of standard about what constitutes “commercially reasonable” roaming rates as part of its 2011 Data Roaming Order, designed to protect competition.

This year, carriers dependent on Verizon Wireless or AT&T to help deliver “nationwide coverage” are negotiating roaming access to the companies’ 4G LTE networks for the first time. Most roaming agreements used to only cover 3G service, delivered at a slower speed.

If carriers like Sprint and T-Mobile are unable to negotiate fair terms, both companies will be at a major competitive disadvantage, relegated to providing only regional coverage or charging higher prices for roaming service.

AT&T vice president of regulatory affairs Joan Marsh said T-Mobile’s request bordered on being illegal, in direct violation of the Telecommunications Act. Marsh argued T-Mobile and other carriers should be incentivized to build their own networks instead of relying on cheap roaming access from companies like AT&T. Marsh added any move by the FCC to set rates or benchmarks would be beyond the FCC’s mandate. Wireless carrier rates are deregulated and not subject to common carrier regulation.