While wireless providers currently treat Wi-Fi as a friendly way to offload wireless data traffic from their 3G and 4G networks, the wireless industry is starting to ponder whether they can also earn additional profits from regulating your use of it.

Dean Bubley has written a white paper for the wireless industry exploring Wi-Fi use by smartphone owners, and ways the industry can potentially cash in on it.

“It is becoming increasingly clear that Wi-Fi access will be a strategic part of mobile operators’ future network plans,” Bubley writes. “There are multiple use cases, ranging from offloading congested cells, through to reducing overseas roaming costs and innovative in-venue services.”

Bubley’s paper explores the recent history of some cell phone providers aggressively trying to offload traffic from their congested 3G networks to more-grounded Wi-Fi networks.

Among the most intent:

• AT&T, which acquired Wayport, a major Wireless ISP, and is placing Wi-Fi hotspots at various venues and in high traffic tourist areas in major cities and wants to seamlessly switch Apple iPhone users to Wi-Fi, where available, whenever possible;
• PCCW in Hong Kong;
• KT in the Republic of Korea, which has moved as much as 67 percent of its data traffic to Wi-Fi;
• KDDI in Japan, which is planning to deploy as many as 100,000 Wi-Fi Hotspots across the country.

Bubley says the congestion some carriers experience isn’t necessarily from users downloading too much or watching too many online shows.  Instead, it comes from “signalling congestion,” caused when a smartphone’s applications demand repeated attention from the carrier’s network.  An application that requires regular, but short IP traffic connections, can pose a bigger problem than a user simply downloading a file.  Moving this traffic to Wi-Fi can be a real resource-saver for wireless carriers.

Bubley notes many wireless companies would like to charge third-party developers fees to allow them access to each provider’s “app store.”  Applications that consume a lot of resources could be charged more by providers (or banned altogether), while those that “behave well” could theoretically be charged a lower fee.  The only thing preventing this type of a “two-sided business model,” charging both developers and consumers for the applications that work on smartphones, are Net Neutrality policies (or the threat of them) in many countries.

Instead, Bubley suggests, carriers should be more open and helpful with third party developers to assist them in developing more efficient applications on a voluntary basis.

Bubley also ponders future business strategies for Wi-Fi.  He explores the next generation of Wi-Fi networks that allow users to establish automatic connections to the best possible signal without ponderous log-in screens, and new clients that can intelligently search out and connect to approved networks without user intervention.  That means data traffic could theoretically be shifted to any authenticated or preferred Wi-Fi network without users having to mess with the phone’s settings.  At the same time, that same technology could be used to keep customers off of free, third party Wi-Fi networks, in favor of networks operators run themselves.

Policy controls are a major focus of Bubley’s paper.  While he advocates for customer-friendly use of such controls, sophisticated network management tools can also be used to make a fortune for wireless providers who want to nickle and dime customers to death with usage fees, or open up new markets pitching Wi-Fi networks to new customers.

For example, a wireless carrier could sell a retail store ready-to-run Wi-Fi that pushes customers to a well-controlled, store-run network while customers shop — a network that forbids access to competitors or online merchants, in an effort to curtail browsing for items while comparing prices (or worse ordering) online from a competitor.

Customers could also face smartphones programmed to connect automatically to a Wi-Fi network, while excluding access to others while a “preferred” network is in range.  Wireless carriers could develop the same Internet Overcharging schemes for Wi-Fi use that they have rolled out for 3G and 4G wireless network access.  Also available: speed throttles for “non-preferred” applications, speed controls for less-valued ‘heavy users,’ and establishment of extra-fee “roaming charges” for using a non-preferred Wi-Fi network.

Bubley warns carriers not to go too far.

“[We] believe that operators need to internalize the concept of ‘WiFiNeutrality’ – actively blocking or impeding the user’s choice of hotspot or private Wi-Fi is likely to be as divisive and controversial as blocking particular Internet services,” Bubley writes.

In a blog entry, Bubley expands on this concept:

I’m increasingly convinced that mobile device / computing users will need sophisticated WiFi connection management tools in the near future. Specifically, ones that allow them to choose between multiple possible accesses in any given location, based on a variety of parameters. I’m also doubtful that anyone will want to allow a specific service provider’s software to take control and choose for them – at least not always.

We may see the emergence of “WiFi Neutrality” as an issue, if particular WiFi accesses start to be either blocked or “policy-managed” aggressively.

[flv width=”640″ height=”380″]http://www.phillipdampier.com/video/The Future of Wi-Fi.flv[/flv]

Edgar Figueroa, chief executive officer of The Wi-Fi Alliance, speaks about the future of Wi-Fi. Wi-Fi technology has matured dramatically since its introduction more than a decade ago and today we find Wi-Fi in a wide variety of applications, devices and environments.  (3 minutes)

Two years after Americans dumped analog television in favor of digital over the air broadcasting, in just over two weeks many Canadians will discover their favorite free-TV signals gone from the analog airwaves forever.

Canada’s transition to digital TV will take a substantial step forward on Aug. 31st when many Canadian local television stations cease broadcasting in analog.  Canada’s pay television providers are taking full advantage of the transition, trying to persuade Canadians who watch their television signals over-the-air for free they will be better off paying for those signals going forward.

Part of the problem is that digital television signals, while “snow-free,” are not pixel-free in many areas distant from the transmitter.  As Americans in suburban locations discovered, those trusty indoor rabbit ears may be insufficient to receive an annoyance-free picture.

Digital television signals are not the nirvana some suggest.  The same passing vehicles and aircraft that caused wavy analog pictures or other interference can turn a digital picture into a frightfest of frozen picture blocks, digital raining pixels, and other effects that can make watching a difficult signal near impossible.

For Americans who thought the days of the external rooftop antenna were behind them, digital television changed all that, especially in more rural areas that could live with a slightly snowy analog picture, but found sub-optimal digital signals unwatchable.

Canada’s vast expanse, and its accompanying large network of low powered television repeater stations rebroadcasting signals from major stations in provincial capitals and large Canadian cities may prove to be an even greater reception challenge, especially in the Canadian Rockies and hilly terrain in eastern Canada.

Some Canadians experimenting with digital-to-analog converter boxes have found reception less practical than they originally thought.

Peter, a Stop the Cap! reader who lives near Oshawa, Ontario delivers some difficult news:

“Reception of digital signals from Toronto’s CN Tower has proved to be a lot more difficult in Oshawa than the existing analog signals,” Peter writes.  “We have no trouble getting truly local signals like CHEX-TV, which has a transmitter in analog serving Oshawa, but watching digital signals from Toronto really requires an outside antenna for good reception.”

Peter’s decision to erect a rooftop antenna opened the door to reception of analog and digital signals from Toronto and across Lake Ontario, where he can receive digital signals from some stations in Buffalo and Rochester, N.Y.  But it was an expense of several hundred dollars to get the work done.

“Cable and satellite companies are taking full advantage of the digital switch to try and get free-TV viewers to ‘upgrade’ to pay television, and they don’t hesitate to mention the expense and hassle of erecting rooftop antennas to guarantee good digital reception,” Peter says.

Peter can only imagine what digital reception will be like in the Canadian Rockies, where large networks of analog, mostly low-powered UHF transmitters deliver basic reception to important networks, especially CBC, outside of major cities.

“If you visit western Alberta or eastern B.C., good luck to you — we could barely watch over the air signals in most of the mountain towns,” Peter says. “Most people either have cable or satellite already.”

Not every television transmitter is scheduled to switch off analog service at the end of August.  Many rural areas are expected to retain analog signals for some time, in part because of the expense of digital conversion and concerns about reception quality.  But some areas, particularly near the U.S. border, are scheduled to drop analog signals regardless, potentially causing disruptions for plenty of free-TV viewers.  Ottawa is anxious to auction off the vacated frequencies for cell phone, Wi-Fi and wireless broadband use for an estimated $4 billion, and the demand is highest in cities along the U.S. border.

“As many as 1.4 million English-language viewers and 700,000 Francophone viewers may be left without a CBC signal,” Ian Morrison, spokesman for the non-profit Friends of Public Broadcasting, which monitors the CBC and promotes Canadian content on TV and radio told the Toronto Star. “For the most part, these are poorer and older people on fixed incomes who are of no interest to advertisers, but who rely for their news and connection to the community on the CBC, the nearest thing we have in this country to a public broadcaster.”

The Canadian Radio-television and Telecommunications Commission runs a website regarding the transition and includes a list of impacted television stations.  Canadian consumers who elect to purchase converter boxes for their analog televisions will pay full price for them — Ottawa has not followed Washington’s lead subsidizing their purchase with a coupon program.

Meanwhile, many pay television providers are running “digital TV upgrade” specials trying to get Canadians to walk away from free TV in favor of paid video packages:

Shaw Direct: Shaw’s direct to home satellite service has developed the best offer around for qualifying residents in 20 Canadian cities set to lose analog television: free service.

“The Local Television Satellite Solution is [for] households in 20 designated cities that have been receiving their television services over-the-air, and will lose over-the-air access to their local broadcaster because the analog transmitter is being shut down and will not be replaced by a digital transmitter,” a Shaw spokesperson told the Toronto Star. “Shaw will provide a household in a qualifying area with a free satellite receiver and dish that is authorized to receive a package of local and regionally relevant signals from Shaw Direct. There are no monthly programming fees provided that a household qualifies to participate in the program.”

The qualifying cities:

Barrie	Fredericton	Moncton	Sherbrooke
Burmis	Halifax	Québec	St John’s
Calgary	Kitchener	Saguenay	Thunder Bay
Charlottetown	Lethbridge	Saint John	Trois-Rivières
Edmonton	London	Saskatoon	Windsor

For everyone else, Shaw Direct’s least expensive package is their Bronze – English Essentials tier which runs $41.99 a month.

Rogers Cable: Rogers is marketing a special package called Rogers Digital TV which offers up to 85 channels for $10.14 a month, which includes all fees.  Many of the channels are included for the first year as a teaser.  After that, customers are left with mostly local stations and filler (including — we’re not kidding — the Aquarium Channel, which shows exactly what you think it does.  Remember, this is the same cable company that brought you the Swiss Chalet Rotisserie Channel.)

“It’s a fine way to get people used to paying for television, and Rogers introductory price is sure to increase at some point,” suspects Peter.  “Maybe you can save a few dollars using those Swiss Chalet meal coupons, though.”

Telus: Western Canada’s largest phone company doesn’t offer much, in comparison.  A basic package of Telus IPTV over your phone line — Optik TV — starts at $41 a month for the first six months.  Telus Satellite TV starts at $38.27 a month, for the first half of a year.  Prices run higher after that.  The most Telus will toss in is a $50 credit for a customer referral from a friend or family member.

Bell: Another phone company with not a whole lot on offer.  Bell’s basic service, which includes TV stations from the U.S. and Canada, starts at $33.50 a month.

Videotron: Quebec’s largest cable company is pitching a combo mini-pack with basic service for $21.29 a month and a required extra channel package starting at $11.17 a month.  That’s around $33 a month.

Can you watch online?  The CRTC says you may find many of your favorite shows available online for free viewing, but includes the important caveat: most Canadian ISP’s engage in classic Internet Overcharging schemes that include a monthly usage allowance that will curtail substantial online viewing.  It should come as little surprise most of the providers in the pay television business in Canada also happen to be the largest Internet Service Providers as well.

About 93 percent of Canadians currently receive television from some form of pay television provider — cable, telco TV, or satellite, according to the CBC.  But some of the 7 percent who do not are at risk of losing Canada’s public broadcaster after the conversion.  While CBC owns most of the stations and transmitters it broadcasts from, it also affiliates with private stations in certain cities where it does have its own presence.

Come Sept. 1, no over-the-air CBC signals of any kind will be transmitted from London and Kitchener-Waterloo in Ontario; Sherbrooke, Chicoutimi, Quebec City and Trois-Rivières in Quebec; Saint John and Moncton in New Brunswick; Saskatoon, Sask., and Lethbridge, Alta.  These are all cities where private stations provided CBC service.  Viewers in these areas will need a pay television subscription, or simply go without.

For some of those already subscribing to cable, Sept. 1 also signals the end of some of their favorite stations, as CRTC requires cable providers to prioritize local stations over more distant ones.  In southeastern Ontario, for example, a number of viewers will lose access to CBLT, Toronto’s CBC station, and CFTO, Toronto’s CTV affiliate, in favor of “more local” stations in Kingston, Ottawa, and Peterborough.

Stop the Cap! reader Larry Posk from Atlanta just threw AT&T overboard, fed up with the company’s anti-consumer policies, and Sprint paid him $125 to walk.

“I can’t think of a single reason to stay with the sharks at AT&T who are spending my money to pay off legislators to drop Net Neutrality, impose usage caps on all of their broadband and wireless accounts, and now try and wipe out T-Mobile; I’ve had enough,” Larry writes.  “I told AT&T goodbye and switched to an unlimited plan from Sprint, who more than covered my early termination fee and gave me a new smartphone for free.”

Larry is a beneficiary of Sprint’s customer win-0ver promotion that covers up to $125 in early termination fees when customers cancel service mid-contract.  Larry owed AT&T around $70, but Sprint gave him the full $125 benefit as a credit on his first Sprint bill.

“All I had to do was transfer my old AT&T number to Sprint, which effectively ended my AT&T service,” Larry says.  “Technically I did not even have to call AT&T to cancel service — the number transfer does the trick, but I felt extra satisfaction giving AT&T a piece of my mind.”

Larry doesn’t want to do business with companies that engage in Internet Overcharging.

“I can basically understand there might be a need for some limitations on wireless service, but when AT&T put the same scheme on their DSL and U-verse customers, it was clear they were simply ripping customers off and I want no part of it,” Larry says.

Sprint also gave Larry another 10 percent off because he belongs to a credit union that qualifies him for additional discounts.  In the end, he’s actually saving about $24 a month and isn’t exposed to a usage limit any longer.

“I recognize the fact Sprint’s network isn’t as wide-ranging as AT&T or Verizon, but I barely travel and Sprint’s coverage in Atlanta is actually better than AT&T because Sprint hasn’t dropped any of my calls,” Larry says. “Data speed is adequate for my needs, and is about on par with what AT&T was delivering here in Atlanta, but it’s not as fast as Verizon.”

Larry says he didn’t know about Sprint’s promotion until he asked, and he recommends customers inquire about Sprint covering their early termination fees before signing up for service.  We found some customers complaining they did not get the credit, but we suspect that might be because they didn’t follow the terms and conditions.  The most important one of all: you have to buy your new phone from Sprint, not a third-party retailer.  Here is the fine print:

Available for consumer and individual-liable lines only. Available online, via telesales, and in participating Sprint stores. Purchases from other retailers are not eligible for the service credit. Requires port-in from an active wireless line/mobile number or landline/number that comes through the port process to a new-line on an eligible Sprint service plan. Excludes $19.99 Tablet Plan. Request for service credit must be made at sprint.com/switchtosprint within 72 hours from the port-in activation date or service credit will be declined. Ported new-line activation must remain active with Sprint for 61 days to receive full service credit. Upgrades, replacements, add-a-phone/line transactions and ports made between Sprint entities or providers associated with Sprint (i.e. Virgin Mobile USA, Boost Mobile, Common Cents Mobile and Assurance) are excluded. You should continue paying your bill while waiting for your service credit to avoid service interruption and possible credit delay. A $125 service credit will be applied for netbooks, notebooks, tablets, mobile broadband devices and smartphones which include BlackBerry, Android, Windows Mobile, Palm, and Instinct family of devices. All other phones are considered feature phones. A $50 service credit will be applied for feature phones and Sprint Phone Connect (when available). Smartphones require activation on an Everything Plan with data with Premium Data add-on charge.

 

Lebanese consumers and businesses are fed up with Lebanon’s archaic Internet infrastructure and the usage limits that come with it.

Now the country is waiting with anticipation as the government prepares to open up new bandwidth from a 3.84 terabit per second underseas cable that passes through the region, but has been left idle since last December.

Lebanon’s Internet is ranked among the slowest in the world, mostly thanks to an over-controlling state telecommunications authority that has priced broadband Internet access into the stratosphere.  Most Lebanese cannot afford the ridiculously slow and expensive “top speed” DSL connections offered by the country’s phone company, offering “up to 2Mbps” speeds for $200US per month.  Instead, most lower income households still use dial-up access, while Lebanon’s middle class settles for 256kbps DSL that still runs a ridiculous $25 a month.

But the 60 percent of the country choosing 256kbps Internet finds even those speeds less than useful when considering they come with a usage allowance of a paltry 3GB per month.  Going over that limit delivers an expensive lesson.  Excess usage is billed at $17 per gigabyte.

Lebanon’s Ministry of Communications, who made the announcement of the forthcoming access improvements, didn’t impress many consumers with word they would “double or triple” the usage cap to celebrate forthcoming speed increases.

“It [is] like entering [the knowledge economy] through a small window,” said Diana Bou Ghanem, head of the the ministry’s ICT office.

Even with the forthcoming improvements, government controls have kept Lebanon’s Internet in the dark ages.  Broadband statistics reveal war-torn Afghanistan and Iraq enjoy faster broadband than Lebanon, and some of the world’s poorest countries like Zambia and Tanzania enjoy speeds twice as fast as those found in downtown Beirut.

Lebanon’s Daily Star newspaper covered the broadband debacle with some alarming reporting suggesting some of the government’s key officials on telecommunications barely grasp telecommunications networks, policies, and practical realities.

For example, former Telecom Minister Charbel Nahhas, a major booster of Lebanon’s forthcoming foray into 3G wireless broadband, seems to believe such networks will deliver up to 20Mbps to Lebanese cell phone users.

Nahhas considers 3G cutting edge for Lebanon, even as the rest of the world prepares to retire it for faster 4G wireless networks.

Telecom Minister Adviser Antoine Boustani seems to think broadband is a tangible resource that can be exported like oil, gas, or electricity.

“We will have an overflow of capacity with [the new underseas cable],” Boustani told the newspaper. “We could even distribute the excess to other countries.”

The Lebanese government and state run phone company — Ogero — have even been willing to celebrate broadband achievements both have regularly failed to meet:

Ogero had planned to host a huge party announcing the [underseas] cable last December, under the auspices of then Prime Minister Saad Hariri. According to sources close to the affair, it was to feature a seated dinner for some 500 persons at the prestigious Pavillion Biel, prime time live television coverage and even Lebanese Opera singer Hiba Kawas, who was commissioned to write a song for the event, performed with a full orchestra. Despite the fact that the Lebanese leadership failed to deliver broadband to its citizens for the past decade, some 10 trophies were to be crafted by the Lebanese sculptor Rudy Rahme and distributed to various officials.

But all this was cancelled when then Telecoms Minister Nahhas received an invitation and challenged Ogero’s role in managing the [underseas] cable and the prime minister’s patronage of it.

Lebanon is following developments elsewhere in the region where broadband usage limits are becoming a thing of the past. When a cartel of Kuwaiti ISP’s threatened to introduce new usage caps in unison, a full-scale consumer revolt forced the government to ban usage caps in the country.

“The Internet has become a cornerstone in development, economy and everyday life in Kuwait,” the country’s telecoms minister, Salem al-Uthayna, said last month in explaining the decision to abolish caps.

Most observers place the blame for Lebanon’s snail-like broadband development at the feet of the government and the state-run phone company, which has blocked efforts to radically change broadband in the country.

Critics accuse both the government and phone company of fearing major market changes, preferring incremental development over a full-scale broadband revolution.  But not everyone is a critic.

“It’s better to look for solutions – play it in a positive way,” said Abu Ghanem, who has worked at the ministry for 15 years. “I don’t want to blame anyone. Just let us work and let us deliver.”

One member of the private sector trying to put Lebanon’s bottom-rated broadband in a different context suggested citizens look on the bright side.

“OK, we are last in Internet [speed] but we are better at other things,” the source added. “Look at the price of real estate in Beirut.”

On Friday, the tech-wireless media was in a frenzy over news one of AT&T’s law firms accidentally posted an un-censored copy of “highly confidential information” regarding its merger proposal with T-Mobile on the Federal Communications Commission website.  Although nobody seems to have a complete copy of the notorious filing to share (it was quickly pulled down after Wireless Week — an industry trade publication — blew the whistle), it turns out if you are willing to plow through AT&T’s periodic publicly-available document dumps, you don’t really need “top secret” information to realize how AT&T is trying to sucker America into accepting its competition-busting merger deal with T-Mobile USA.

What AT&T is Telling the FCC’s Lawyers But Hiding from You

As part of the approval process, the FCC sent AT&T a significant homework assignment, demanding answers to some detailed questions about the justification for the merger, how AT&T intends to use both its existing and newly-acquired wireless spectrum from both Qualcomm and, presumably, T-Mobile, and what specific plans the company has to expand its next generation wireless data network to rural America.

Last week, we learned from the unredacted filing that AT&T will pay $39 billion for T-Mobile to expand a 4G network that AT&T refused to spend $3.8 billion dollars to build themselves.  You read that right.  AT&T says it can expand its own 4G network to an additional 55 million people for just under $4 billion, or buy T-Mobile for nearly $40 billion to accomplish the same thing.

And what exactly does AT&T get from T-Mobile?  A largely urban network running a 4G network that goes nowhere near the 55 million largely rural Americans AT&T claims it intends to serve if the merger wins approval.

So scratch AT&T’s claim that the acquisition of T-Mobile’s network will do anything directly for the rural Americans T-Mobile never directly served.

AT&T’s biggest selling point is that its acquisition of T-Mobile will allow it to reach “97 percent of America” with its improved 4G network:

Because of the spectrum gains and the overall economic benefits resulting from the transaction, senior management made a business judgment that the merger with T-Mobile USA allowed AT&T to expand its LTE build-out to 97 percent of the population. These economic benefits include incremental reductions in cost due to the addition of T-Mobile USA resources, greater scale economies, such as higher volume discounts on handsets and equipment, a larger customer base, and the expectation of a higher take-rate for its LTE service. In addition, the transaction will enable AT&T to re-purpose its existing capital budget allocated to spectrum acquisitions to be allocated for other uses. Overall, the scale and scope of the larger combined wireless business will permit the additional capital investment to be spread over a larger revenue base than would be the case absent the merger.

But the unredacted, “highly confidential” part of the same document exposes important facts AT&T didn’t want the public to know:

“AT&T senior management concluded that, unless AT&T could find a way to expand its LTE footprint on a significantly more cost-effective basis, an LTE deployment to 80 percent of the U.S. population was the most that could be justified,” wrote AT&T counsel Richard Rosen.

In other words, by collecting T-Mobile customers’ monthly payments, AT&T can utilize that additional revenue, earned mostly from T-Mobile’s urban customer base, and use it to pay for rural cell sites the company itself won’t spend the money to upgrade to achieve that 97 percent coverage.

You can read between the lines of AT&T’s public statements and come to the same conclusion Rosen made confidentially, but it helps when the company’s own lawyer says it out loud.

Karl Bode from Broadband Reports thinks there is something familiar about that 97 percent figure.  It just so happens to be Verizon’s existing 3G coverage area.  Verizon pointed to their more robust 3G coverage in a major ad campaign that began just prior to the Christmas shopping season in 2009.  It did enough damage to bring AT&T to court in an effort to stop the ads, and reacquainted America with Luke Wilson, who threw postcards on a floor map touting AT&T’s more robust, but considerably less speedy, last-generation EDGE data network.

Verizon completed their expansive 3G network without the benefit of a merger and is in the process of building their 4G LTE network on their own as well — capable of eventually reaching the majority of Americans without taking out the fourth largest wireless carrier in the country.  AT&T, on the other hand, spent its time in court and handing Wilson more postcards to throw  instead of investing appropriately in its network over the last three years.

AT&T’s Document Dump: More than 1 Million Documents Bury FCC and Justice Lawyers

Another important revelation that doesn’t require the accidental disclosure of redacted data is the fact AT&T is burying government lawyers at both the FCC and Department of Justice in virtual paper.  The company admits to sending at least 1.2 million documents to Justice alone.  Reviewing AT&T’s filings with the FCC exposes the use of the old legal trick of burying your opponents in paper, hoping they will miss important documents that could call into question the veracity of the company’s arguments.

With the FCC, AT&T’s lawyers love to use appendices and attachments as virtual dumping grounds, adding copies of virtually any company document that contain “key words” or “search terms” in response to the Commission’s questions.

Take this Q&A exchange:

FCC Question: Provide all plans, analyses, and reports discussing: (a) spectrum requirements for all band segments; (b) the average data transmission speeds that the Company expects customers will be able to obtain; (c) actual and forecasted traffic and busy hour analyses, (d) total data tonnage; (e) capacity utilization rate; (f) vertically integrated operations; or (g) other technical or engineering factors required to attain any available cost savings or other efficiencies necessary to compete profitably in the sale or provision of any relevant product or any relevant service.

AT&T’s Answer: To respond to this request, AT&T conducted key word searches of custodian files as detailed in the tables appended as Exhibit A. Documents responsive to this request are included in AT&T’s production.

It’s the equivalent of putting the phrase “data transmission speeds” into a search engine and then attaching every document that appears in the results and calling it “your answer,” relevant or not.

AT&T used the same approach in answering the FCC’s questions about how the merger would specifically bring improved 4G service to areas without service today, what impact the merger will have on roaming agreements and wholesale access to the combined AT&T/T-Mobile network, and even in response to a basic question about plans for targeting particular competitors, customers, or customer segments after the merger.

Reality: AT&T Doesn’t Care About T-Mobile’s Network

So what else does AT&T win from a nearly $40 billion investment in T-Mobile?  While the leak of confidential information continues to be largely protected by a trade industry publication that has not released it publicly in full, anyone versed in telecommunications can easily find plenty in AT&T’s public documents.

The most important point is that AT&T admits, publicly,  it has not determined exactly what it intends to do with T-Mobile’s most important asset — its network:

• “AT&T, however, will not be in a position to make any final determinations until it is able to obtain more detailed information about T-Mobile USA’s operations, which will occur later in the acquisition process.”
• “AT&T has not yet begun detailed integration planning efforts.”

Would you spend $40 billion to buy a cellular service provider and not have the first clue what you would do with it?

But it gets even sillier.  AT&T doesn’t even know, several months after the merger was announced, exactly where T-Mobile’s cell towers are and what kind of backhaul connectivity they have:

AT&T has not yet begun detailed integration planning and its knowledge of T-Mobile USA’s operations is necessarily limited at this early stage. The actual process of determining which specific T-Mobile USA sites to integrate and which to decommission will require substantially more data from T-Mobile USA regarding its network as well as a more thorough engineering analysis of each area’s characteristics and capacity needs, which could change by the time the Transaction closes. Consequently, AT&T has not yet determined the exact number or location of T-Mobile USA towers or other locations used for transmission of signals that will be integrated into the combined company’s network to increase network density.

Because AT&T has not yet begun detailed integration planning and its knowledge of T-Mobile USA’s operation is necessarily limited at this early stage, AT&T does not have documents regarding the integration of the two companies’ switching facilities and backhaul.

These facts have made it impossible for AT&T to be responsive to specific questions from the FCC about the impact of acquiring and integrating T-Mobile’s operations into AT&T’s.  That left the company answering the Commission’s questions with statements like this:

Q. Provide all plans, analyses, and reports discussing any possible modification by the Merged Company of the terms, including prices, for providing backhaul for unaffiliated mobile wireless service providers to new or existing towers.

A. AT&T has not yet begun detailed integration planning, and its knowledge of T-Mobile USA’s operations is necessarily preliminary at this early stage. Any consideration regarding potential modification of terms and pricing for backhaul has not yet occurred. Thus, AT&T does not have any documents responsive to this request.

Good to know… or not know.

So if AT&T isn’t dwelling on the details of T-Mobile’s network, what do they expect to obtain from its purchase?

Here are AT&T’s “assumptions.”  That’s right, AT&T isn’t actually promising to do any of this.  It just “assumes” it will based on earlier planning — the same kind of planning that was supposed to deliver 4G upgrades without T-Mobile in the equation, until company executives changed their minds:

• Utilize the parties’ combined scale, spectrum, and other resources to extend AT&T’s deployment of LTE services to over 97% of the U.S. population, extending service to an additional 55 million Americans;
• Integrate AT&T’s and T-Mobile USA’s wireless networks, including:

1. Integrate T-Mobile USA cell sites into the AT&T wireless network, resulting in a more robust network grid;
2. Combine AT&T’s and T-Mobile USA’s GSM networks, eliminate redundant GSM control channels and maximize utilization efficiencies;
3. Combine AT&T’s and T-Mobile USA’s GSM spectrum holdings, resulting in channel pooling efficiencies and improved coverage;
4. Optimize usage of the parties’ combined spectrum holdings and deploy additional spectrum to support more spectrally efficient network technologies; and
5. Decommission redundant cell sites and reuse radios and other equipment from decommissioned sites to enhance network efficiency and performance.

• Make AT&T rate plans available to T-Mobile USA customers, while preserving rate plans for T-Mobile USA consumers who wish to maintain their existing plan of choice;
• Make AT&T services, smartphones, and other devices available to current T-Mobile USA customers;
• Integrate retail outlets, dealers, and marketing efforts under the AT&T brand;
• Integrate billing, customer care, and other support services;
• Integrate certain functional units, including, but not limited to human resources, general & administrative, information technology, finance, procurement, and legal.
• Achieve savings in network infrastructure investment and network and customer equipment purchases; and
• Achieve efficiencies in interconnection and transport costs.

During AT&T’s periodic communications with shareholders, the company has spent most of its time talking about cost savings made possible from closing redundant retail outlets, integrating networks, and the always-vague savings from job redundancies (read that major layoffs).  In fact, AT&T has said they will save up to $10 billion dollars in infrastructure expenses with the merger.  At the same time, its public relations efforts promise the company will spend a veritable fortune — up to $8 billion, improving AT&T’s own network.

You can be certain to the uninitiated, eight billion dollars sounds like a lot of money.  It’s a dollar amount that is sure to razzle-dazzle plenty of people.  That is, until you realize during the same period of time, T-Mobile itself would have been spending up to $18 billion of its own money upgrading its network.  Eighteen billion minus eight billion equals the aforementioned $10 billion — the savings AT&T will realize from continuing to under-spend on both its network and T-Mobile’s.

More Fun Facts: AT&T Cares More About Counting Your Usage Than Measuring Network Capacity & Utilization

Wading through AT&T’s filings has revealed another important fact pertinent to Stop the Cap! readers: AT&T obsesses about measuring your wireless data usage but doesn’t have much of a clue about how much network capacity it has at different cell sites, nor the utilization rates at those sites.  No wonder AT&T drops calls.  If the company isn’t carefully measuring network utilization at a granular level, it can’t hope to find overcongested sites that badly need upgrades to stop the problem of dropped calls and slow speed data:

AT&T does not maintain in the ordinary course of business a nationwide list of all CMAs where its individual network is underutilized. With regard to the areas where AT&T’s and T-Mobile USA’s networks may be underutilized relative to each other, AT&T does not have this information on a CMA by CMA basis, nor does AT&T have engineering data that would provide this granular information for T-Mobile USA.

However, when the opportunity to engage in highly-profitable Internet Overcharging exists, measuring customer usage takes a high priority, as we learn from AT&T in response to another question from the FCC:

The .csv file in Exhibit 19-1 contains current (as of March 11, 2011) data usage for each UMTS site (by USID) measured in kilobytes, during the monthly busy hour, and separately for the uplink and the downlink. The .csv file in Exhibit 19-2 contains current (as of March 11, 2011) data usage for each GSM site, measured in Erlangs, combined for the uplink and downlink, for the monthly busy hour. At the Commission’s request, AT&T also provides an estimate of GSM data usage in terms of Kilobytes, using a formula that converts Erlangs to Kilobytes. ll Both exhibits identify the CMA associated with each site. The .xlsx file in Exhibit 19-3 contains usage projections that are currently used by the network engineers for each of AT&T’s 27 regional clusters in the ordinary course of business.

AT&T doesn’t lose any money when it drops your call from an overcongested cell site (unless you grow weary enough of it to cancel service), but can lose plenty if it doesn’t measure customer data usage in hopes of limiting customer use or charging them an overlimit fee when they don’t.

AT&T’s Mother-of-all-Disclaimers: AT&T Has Not Verified It Has Produced All Requested Documents

The most flippant part of AT&T’s document dump is the revelation that despite the million plus documents thrown at two government agencies, AT&T isn’t willing to affirm it actually produced copies of the relevant documents the government wants as part of the review process.  In a host of disclaimers and AT&T’s own descriptions of how it defines the meaning of the government requests, the company notes:

Pursuant to discussions with the Commission staff, AT&T is submitting its Response consistent with the following qualifications:

• Custodian files were searched covering the period from January 1, 2009 through March 21, 2011, except for certain custodians, whose files were searched through early May, 2011.
• AT&T has not verified that it has produced “all other documents referred to in the document or attachments,” pursuant to instruction 4.
• AT&T has not searched backup disks and tapes for documents.

Nothing to slip through scrutiny there, right?