New York State residents have until July 2 to share their views about a proposal by Verizon Communications that would allow the company to drop landline service in rural upstate New York and other locations and replace it with a wireless substitute — Voice Link, as its sole service offering.

Stop the Cap! has covered the issue of rural landline service extensively since 2008. In the past few years, while CenturyLink, Windstream, FairPoint, and Frontier have developed business plans to sell lucrative landline telephone and broadband service in rural areas, AT&T and Verizon have proposed abandoning their landline networks in certain areas in favor of wireless.

Verizon has sought to stop offering rural landline service in areas where it feels no longer economically justified providing it. It ultimately means dismantling communications infrastructure that has provided reliable voice telephone service for more than 100 years.

Voice Link is first being introduced as Verizon’s “sole service” for beleaguered residents living on the western half of Fire Island, which was devastated by last fall’s Hurricane Sandy. Verizon does not want to foot the bill to rebuild and repair the damaged copper wire infrastructure and does not believe installing its fiber optic network FiOS is economically justified either. That leaves residents with one option for basic phone service: Voice Link.

Unfortunately, many of the residents now encountering Voice Link have told the Public Service Commission it has proven unreliable or unsatisfactory and represents a downgrade from the landline service they used to have. (Stop the Cap! has repeatedly offered to test Voice Link’s workability and sound quality ourselves, but Verizon has not taken us up on that offer.)

The company does admit Voice Link is incompatible with basic data services, which means Verizon customers using Voice Link will lose DSL and dial-up Internet access. It also does not work with fax machines, home alarms, and medical monitoring services. Verizon has promised to address these issues in the future, but has offered no timeline or guarantees. Instead, it suggests customers consider purchasing added-cost services from Verizon Wireless, which could cost some residents hundreds of dollars a month for phone and broadband service.

Stop the Cap! believes Voice Link should be offered only as an optional service for customers who wish to use it. In its current form, it is unsuitable, unproven, and insufficient to serve as Verizon’s sole offering, particularly when the company is the carrier of last resort for many rural residents, as well as those on Fire Island.

At the very least, Verizon must be compelled to offer an equal or better level of service, not diminish it. That means better voice quality, rock solid cell coverage, an equivalently priced, unlimited wireless broadband service option for DSL customers, and compatibility with the data services that are now supported over the plain old telephone network.

The Commission should also explore the true costs of repairing and/or replacing wired infrastructure before allowing the company to dismantle it. Once the wired infrastructure is removed, the costs to provision rural New York with fast, reliable, wired broadband service in the future will become prohibitive. Wireless service is no panacea for rural New York, where coverage issues abound, especially in the mountainous areas upstate and across the rolling hills of the Southern Tier. Verizon’s lawyers admitted as much when they wrote the terms and conditions governing Voice Link and other wireless services, walking away from significant liability if calls to 911 go unconnected:

“In the absence of gross negligence or willful misconduct by Verizon, our liability to you, to anyone dialing 911 using the Service, or to any other person or party, for any loss or damage arising from any acts, errors, interruptions, omissions, delays, defects, or failures of 911 services or emergency personnel, whether caused by our negligence or otherwise, shall not exceed the amount of our charges for such Services during the affected period of time. This limitation of liability is in addition to any other limitations contained in this Agreement.”

In other words, Verizon’s only responsibility is to credit your account for the time you could not reach 911 or your call summoning help was dropped. You will see that credit reflected on a future bill, assuming you are still among the living when the emergency is over.

We strongly urge our fellow New Yorkers to share their personal views about Voice Link as a landline substitute with the PSC. This issue is important not only to Fire Island but to the rest of rural upstate New York as well, particularly pertaining to whether customers will have broadband service or not. Verizon management has clearly stated their agenda is to retire copper landline service and replace it with wireless in non-FiOS areas deemed too costly or unprofitable to keep up or upgrade.

Sharing your views is fast and easy and can be done in several ways. Be sure to reference “Matter/Case: 13-00986/13-C-0197” in your comments and include your contact information. All submissions will become publicly viewable on the Commission’s website under the “Public Comments” tab. You can find submissions from Stop the Cap! there as well.

Write (U.S. Mail):

Hon. Jeffrey C. Cohen, Acting Secretary
New York State Public Service Commission
Three Empire State Plaza
Albany, New York 12223-1350

E-Mail:

[email protected]

Online Comments:

You can post comments directly to the Commission’s Document and Matter Management System (DMM). Choose the “Post Comments” link on the upper-right of your screen. An online submission form will appear asking for your contact information. You can include your comments in the provided text box on that form or attach a .PDF, .DOC, or .TXT file.

Wireless Industry: We’re running out of spectrum!
Wireless Industry: We’ve got plenty to room for unlimited ESPN!

America is on the verge of a wireless traffic data jam so bad, it could bring America to its knees.

Or not.

Stop the Cap! notices with some interest that while wireless carriers continue to sound the alarm about a spectrum crisis so serious it necessitates further compressing the UHF television dial and forces other spectrum users to become closer neighbors, the same giant phone companies warning of impending doom are negotiating with online video producers to offer customers “toll-free,” all-you-cat-eat streaming video of major sports events that won’t count against your usage allowance.

ESPN is in talks with at least one major carrier (AT&T or Verizon Wireless) to subsidize some of the costs of its streamed video content so that customers can watch as much as they want without running into a provider’s usage limit. Both Verizon and AT&T have signaled their interest in allowing content producers to pay for subscribers’ data usage. In fact, they don’t seem to care who pays for the enormous bandwidth consumed by streaming video, so long as someone does.

At a recent investment bank conference Verizon Wireless chief executive Dan Mead explained the next chapter in monetizing data usage will allow the company to rake in more revenue from third parties instead of customers already struggling with high wireless bills.

“We are actively exploring those opportunities and looking at every way to bring value to our customers,” said Mead.

Content producers are increasingly frustrated with the stingy caps on offer at AT&T and Verizon Wireless because customers stop accessing that content once they near their monthly usage limit. One large provider admitted to ESPN that “significant numbers” of customers are already reaching their cap before the end of their billing cycle, after which their online usage plummets to limit the sting of overlimit charges.

Offering “toll-free” data could dramatically increase the use of high bandwidth applications and increase profits at wireless providers based on new fees they could collect from content producers. Customers would still be subject to usage limits for all non-preferred content, a clear violation of Net Neutrality principles.

The buffet is open.

But in case you forgot, wireless carriers won exemption from Net Neutrality, arguing their networks lack the capacity to sustain a Net Neutral Internet experience. These same companies claim without more frequencies to handle the massive, potentially unsustainable amount of wireless traffic, the wireless data apocalypse could be at hand in just a few years. It was also the most-cited reason AT&T and Verizon discontinued their unlimited use data plans.

But unlimiting ESPN video? No problem.

In January 2010, Verizon Wireless was singing a very different tune to the FCC about the need to control and manage high bandwidth applications like the “toll-free” streaming video service ESPN proposes (underlining ours):

Wireless broadband services face technological and operational constraints arising from the need to manage spectrum sharing by a dynamically varying number of mobile users at any time. Thus, unlike, for example, cable broadband networks, where a known and relatively fixed number of subscribers share capacity in a given area, the capacity demand at any given cell site is much more variable as the number and mix of subscribers constantly change in sometimes highly unpredictable ways.

Are wireless carriers now part of the problem?

For example, as a subscriber using a high-bandwidth application such as streaming video moves from range of one cell site to another, the network must immediately provide the needed capacity for that subscriber, while not disrupting other subscribers using that same cell site. Of course, the problem is magnified many times over as multiple subscribers can be moving in and out of range of a cell site at any given moment. Moreover, the available bandwidth can fluctuate due to variations in radio frequency signal strength and quality, which can be affected by changing factors such as weather, traffic, speed, and the nearby presence of interfering devices (e.g., wireless microphones).

These problems compound those resulting from limited spectrum. As the Commission has repeatedly recognized in proclaiming an upcoming spectrum crisis, “as wireless is increasingly used as a platform for broadband communications services, the demand for spectrum bandwidth will likely continue to increase significantly, and spectrum availability may become critical to ensuring further innovation.”

A wireless carrier cannot readily increase capacity once it has exhausted its spectrum capacity. Thus, wireless broadband providers are left to acquire additional spectrum (to the extent available) or take measures that use their existing spectrum as efficiently as possible, which they do through a combination of investing in additional cell sites and network management practices that optimize network usage and address congestion so as to provide consumers with the quality of service they expect.

Regulators need to ask why wireless companies are telling the FCC there is a bandwidth crisis of epic proportions that requires the Commission to exempt them from important Net Neutrality principles while telling investment banks, shareholders and content producers the more traffic the merrier, as long as someone pays. Customers also might ask why their unlimited use data plans were discontinued while carriers seek deals to allow unlimited viewing with their preferred content partners.

What is the real motivation? The Wall Street Journal suggests one:

“Creating a second revenue stream for mobile broadband is the holy grail for wireless operators but collecting fees from content companies would probably make the FCC take a close look into the policy implications,” said Paul Gallant, managing director at Guggenheim Securities. An FCC spokesman declined to comment.

[flv width=”512″ height=”308″]http://www.phillipdampier.com/video/WSJ ESPN Toll Free Data 5-9-13.flv[/flv]

The Wall Street Journal takes a closer look at a plan to manage an end run around Net Neutrality by allowing preferred content partners to offer streaming video services exempt from your usage cap. (4 minutes)

AT&T’s WiMAX Internet service in Alaska will be switched off Jan. 31, forcing rural Alaskan customers to find an alternative for inexpensive wireless service in areas where DSL or cable broadband is unavailable.

The company stopped signing up new customers last March and has been repeatedly notifying existing customers they will need to find an alternative service soon.

AT&T is shutting off the aging WiMAX network, which delivered up to 2Mbps service at prices starting at around $20 a month, in favor of newer wireless broadband services, including AT&T’s LTE 4G service and Wi-Fi hot spots.

AT&T is recommending customers switch to one of its mobile broadband plans. But WiMAX customers are likely to experience sticker shock when they see the difference in price.

AT&T charges $40 a month for just 1GB of usage plus an additional $20 a month device fee on its Mobile Share Device Data Plan.

Clearwire wants a divorce from customers it deems are using the wireless broadband service too much — as in around 5GB per month, despite the fact many of those customers pay for “unlimited” accounts.

Broadband Reports says several ex-customers are now complaining on Twitter about their abrupt, involuntary departure this week as paying customers, despite company promises that advance warnings would be sent if a customer was engaged in “excessive use.”

“One user excessively running heavy bandwidth applications can adversely affect the speeds and service quality for their neighbors,” Clearwire told Broadband Reports. “It is rare that we take this step and when we do it affects an extremely small percentage of our total user base. We typically contact users to notify them of this type of situation first in order to provide an opportunity to make necessary changes.”

Broadband Reports:

How much usage was considered too much? Clearwire won’t get specific, but one of the users tells Broadband Reports Clearwire informed him he’d breached 5 GB three months in a row — which frankly doesn’t sound excessive for a modern wireless network.

Clear began throttling heavy users on unlimited accounts to around 256kbps back in 2010. They’ve never really been specific about what triggers the throttled state for users, given it appears to be calculated on the fly based on local tower congestion — so what triggers throttling may be different in different markets. It’s not entirely clear why throttling these users back to 256 kbps wasn’t substantial enough of a punishment for these “fired” customers.

A Short History of Wireless Cable

Spectrum offered Chicago competition to larger ON-TV, selling commercial-free movies and sports on scrambled UHF channel 66 (today WGBO-TV).

Long before many Americans had access to cable television, watching premium commercial-free entertainment in the 1970s was only possible in a handful of large cities, where television stations gave up a significant chunk of their broadcast day to services like ON-TV, Spectrum, SelecTV, Prism, Starcase, Preview, VEU, and SuperTV. For around $20 a month, subscribers received a decoder box to watch the encrypted UHF broadcast programming, which consisted of sports, popular movies and adult entertainment. The channels were relatively expensive to receive, suffered from the same reception problems other UHF stations often had in large metropolitan areas, and were frequently pirated by non-paying customers with modified decoder boxes.

With the spread of cable television into large cities, the single channel over-the-air services were doomed, and between 1983-1985,virtually all of their operations closed down, converting to all-free-viewing, usually as an independent or ethnic language television outlet.

But the desire for competition for cable television persisted, and in the mid-1980s the Federal Communications Commission allocated two blocks of frequencies for entertainment video delivery. The FCC earlier allocated part of this channel space to Instructional Television Fixed Services (ITFS) for programming from schools, hospitals, and religious groups, which could use the capacity to transmit programming to different buildings and potentially to viewers at home with the necessary equipment.

Home Box Office got its start broadcasting on microwave frequencies before moving to satellite.

In practice, ITFS channels allocated during the 1970s were underutilized, because running such an operation was often beyond the budgets and technical expertise of many educational institutions. Premium movie entertainment once again drove the technology forward. After signing off at the end of the school day, Home Box Office, Showtime, and The Movie Channel signed on, using microwave technology to distribute their services to area cable systems and some subscribers. As those premium services migrated to satellite distribution beginning in 1975, reallocation for a new kind of “wireless cable TV” became a reality.

Wireless cable (technically known as “multichannel multipoint distribution service”) began in earnest in the late 1980s and early 1990s, with a package of around 32 channels — typically over the air stations, popular cable networks, and one or two premium movie channels. Some operations in smaller cities sought to beam just a channel or two of premium movies or adult entertainment to paying subscribers, the latter at a substantial price premium. Installation costs paid by providers were more affordable than traditional cable television — around $350 for wireless vs. $1,000 for cable television. That made wireless attractive in rural areas where installation costs for cable television could run even higher.

However, it was not too long before wireless cable operators ran into problems with their business models. Obtaining affordable programming was always difficult. Some cable networks, then-owned by large cable systems, either refused to do business with their wireless competitors or charged discriminatory rates to carry their networks. By the time legislative relief arrived, the wireless industry realized they now had a capacity problem. As cable television systems were being upgraded in the 1990s, the number of channels cable customers received quickly grew to 60 or more (with many more to come with the advent of “digital cable”). Wireless cable was stuck with just 32 channels and a then-analog platform. Satellite television was also becoming a larger competitive threat in rural areas, with DirecTV and Dish delivering hundreds of channels.

American Telecasting gave up its wireless cable ventures, under such names as People’s Wireless TV and SuperView in 1997, selling out to companies including Sprint and BellSouth (today AT&T). BellSouth pulled the plug on the services in February, 2001.

Wireless providers simply could not compete with their smaller packages, and most closed down or sold their operations, often to phone companies. The few remaining systems, mostly in rural areas, have typically combined their wireless frequencies with satellite provider partners to deliver television, slow broadband, and IP-based telephone service.

Rebooting Wireless Cable for the 21st Century

By the early-2000’s the Federal Communications Commission proposed a new allocation for a “Multichannel Video and Data Distribution Service” (MVDDS). Designed to share the 12.2-12.7GHz band with Direct Broadcast Satellite (DBS) services DirecTV and Dish, MVDDS was partly envisioned as a potential way to deliver local stations to satellite subscribers over ground-based transmitters. But things have evolved well beyond that concept, especially after both satellite providers began using “spot beams” to deliver local stations to different regions from their existing fleet of orbiting satellites.

MVDDS was ultimately opened up to be either a competing cable television-like service or for wireless broadband, or both. Michael Powell, then-chairman of the FCC during the first term of George W. Bush, said the technology was free to develop as providers saw fit:

What is MVDDS? The short answer is that we do not know.  Its name, Multichannel Video Distribution and Data Service, seems to suggest everything is possible – and perhaps it is.

But the service rules the Commission has adopted do not require MVDDS to provide any particular kind of service – it could be a multichannel video, or data, or digital radio service, or any other permutation on spectrum use.

The Commission was once in the business of requiring spectrum holders to provide a certain type of service.  That approach failed because government is a very bad predictor of technology and markets – both of which move a lot faster than government.  Over the past decade or so, the Commission has adopted more flexible service rules that bound a service based largely on interference limitations and its allocation (fixed or mobile, terrestrial or satellite).  In this Order, we follow that flexible model for MVDDS.

In 2004 and 2005, licenses to operate MVDDS services were opened up for auction, and a handful of companies won the bulk of them: MDS America, which built a 700-channel wireless cable system in the United Arab Emirates, DTV Norwich, an affiliate of cable operator Cablevision, and South.com, which is really satellite provider Dish Network. Another significant winner was Mr. Bruce E. Fox, who wants to partner with other providers to finance and operate MVDDS services.

Cablevision and Fox are the two most active license recipients at the moment.

A Look at Today’s MVDDS Wireless Players

Fox launched Go Long Wireless in Baltimore as a demonstration project. Go Long transmits its signal from the roof of the World Trade Center at the Baltimore Inner Harbor to the Emerging Technology Center, a business incubator site a few miles away. Fox believes the technology is especially suited to multi-dwelling units like apartment complexes and condos. He plans to work with other service providers who will market and bill the service under their own brand names. Fox does not seem to be interested in challenging the marketplace status quo. He does not believe in using MVDDS to provide television service, for example. In Fox’s view, the real money is in broadband and Voice over IP telephone service.

Cablevision’s involvement is more direct-to-consumer. Its Clearband service– now operating under the new brand ‘OMGFAST’ — is now selling up to 50/3Mbps wireless broadband service in the Deerfield Beach, Fla. area. The company has had nothing to say about whether this service is slated to expand, and if it does, Cablevision will not be permitted to operate it in areas where they already provide cable service, due to the FCC’s cross-ownership rules.

OMGFAST originally bundled voice service in its broadband packages, which it sold at different price points: 12Mbps for $39.95 a month, 25Mbps for $59.95 a month, and 50Mbps at $79.95. The company also tested a 50Mbps promotion priced at $29.95 a month for three months, $59.95 ongoing. Today it offers a better deal: $29.95 a month for 50Mbps service as an ongoing rate. (Expect to pay $10 a month more for mandatory equipment rental, and $14.95 a month if you also want voice service.)

[flv width=”640″ height=”450″]http://www.phillipdampier.com/video/Clearband FAST 50 Mbps Internet.flv[/flv]

Here is a promotional video explaining how Clearband (now OMGFAST) wireless broadband works. (3 minutes)

MVDDS currently delivers broadband with similar constraints cable systems operate under — namely, download speeds are much faster than upload speeds. That is because upstream bandwidth relies on another transmission technology, often WiMAX, in the 3.65 GHz or 5 GHz bands.

The wireless technology is also very “line of sight,” meaning the tower must be within six miles of the subscriber and not blocked by any obstructions. Hills, buildings, even heavy foliage can all block MVDDS signals the same way satellite signals can be blocked (they share the same frequencies).

Most customers end up with an antenna that very much resembles a traditional satellite dish from DirecTV or Dish, mounted on a roof. To maximize available bandwidth, MVDDS uses a configuration similar to cellular systems, with up to 900Mbps of total bandwidth available to each 90-degree narrow beam sector.

Cablevision has MVDDS licenses to serve most large cities in the United States.

The question is, how will license holders ultimately use the technology. Although originally proposed as a competitor to traditional cable or satellite TV, deregulation has left the fate of MVDDS in the hands of the operators.

Some are considering not selling the service to consumers at all, but rather making a market out of providing backhaul connectivity for cell towers. Dish may be interested in using its licenses to offer customers a triple play package of broadband and phone service with its satellite TV package. Nobody seems particularly interested in providing television service over MVDDS, primarily because programmers’ demands for higher carriage payments would cut into revenue.

Even Cablevision isn’t completely sure what it wants to do. Although it currently is trialing broadband and phone service in Florida, the company earlier petitioned the FCC for increased power to establish a more suitable wireless backhaul service it can sell to mobile phone companies.

For the moment, reviews seem relatively positive for the Florida market test. Of course, as more customers pile on a wireless service, the less speed becomes available to each customer. OMGFAST does not appear to be currently concerned, noting it has no usage caps on its service.

Want to know which provider may be coming to your area? See below the jump for a list of the top-three bid winners and the cities they are now licensed to serve, in order of market size.

… Continue Reading