F-22Raptor
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Before the FEDERAL COMMUNICATIONS COMMISSION
I. THE U.S. IS ALREADY THE WORLD LEADER IN 5G
T-Mobile and Sprint state in their Public Interest Statement that their proposed merger is
“necessary” for “the rapid and widespread deployment of 5G networks.”2 The merger, the
Applicants claim, will “force” AT&T “and other competitors to more quickly provide faster,
better 5G services” instead of the “tepid adoption” of 5G that could be expected otherwise.3
Absent a merger, the Applicants contend, “none of the carriers are on track to deploy a robust national 5G network quickly.”4
In fact, the U.S. is already the world leader in 5G, and AT&T and the other major facilities
based wireless carriers are in the midst of a race to deploy next generation 5G services – a race that began long before T-Mobile and Sprint announced their merger plans.5 As Chairman Pai has observed, the U.S. is “in the lead on 5G,” 6 and the FCC has taken “important steps that will help solidify U.S. leadership in 5G.”7 Commissioner Carr similarly has noted, “I think we’re really in great shape when it comes to the race to 5G.”8
Analysts echo these comments. A new IHS Markit study finds that “North America seems
to be leading the race to launch commercial 5G services” – “5G is going live in North America by the end of 2018, and then in South Korea in 2019,” but “[m]ost operators in Europe, however, aren’t planning to deploy 5G until 2021 or later.”9 GSMA agrees: “The US will be one of the first countries to launch 5G commercial services, as was the case for 4G.”10 GSMA notes the “continuous efforts from US government institutions to support 5G progress through new spectrum allocations (including mmWave bands) and work to enable infrastructure deployment,” as well as “[c]ontinued, significant operator investment in both fibre infrastructure and 4G network upgrades.”11 Indeed, analysts estimate that nearly half of the mobile subscriptions in North America will be 5G by 2023.12 As the trade press explains, the wireless industry is engaged in an “early 5G arms race,”13 and this rush to deploy the best 5G service the fastest will continue with or without the T-Mobile/Sprint merger.
AT&T is fully engaged in that arms race and is leading the industry. AT&T already
offers “5G Evolution in more than 140 markets, covering nearly 100 million people with
theoretical peak speeds of at least 400 Mbps,”14 and AT&T plans to serve more than 400 markets by the end of 2018.15 5G Evolution technology takes advantage of features like 256 QAM, 4x4 MIMO, and three-way carrier aggregation, which permit enormous boosts in speed and capacity.
In addition, AT&T is starting to upgrade cell towers with LTE-Licensed Assisted Access (“LTE LAA”), which achieves theoretical peak speeds of up to 1 Gbps.16 LTE-LAA combines
unlicensed spectrum with licensed spectrum through carrier aggregation to increase network
capacity – providing faster speeds and a better customer experience. AT&T has deployed LTE LAA in 15 markets and expects to reach at least 24 later this year.17 AT&T “expect to be the first U.S. company to introduce mobile 5G service.” AT&T’s “millimeter wave mobile 5G trials are going well,” and AT&T is “on track to launch service in parts of 12 markets by the end of this year.”18
AT&T’s launch of mobile 5G service will be the culmination of testing that began in
2016 with an enterprise 5G trial in Austin in which AT&T used millimeter wave (“mmW”)
technology to power a 5G network experience in a customer’s office.19 AT&T subsequently
expanded these pre-standards 5G mmW fixed wireless trials to three additional communities – South Bend, Kalamazoo, and Waco – where AT&T worked with residential, small business, and educational trial participants. 20 AT&T also created a 5G testbed in Austin where engineers could build and test creative solutions and run “stress tests” simulating real-world customer experiences before they are rolled out to customers.21 More recently, AT&T has tested standards-based mobile 5G, also in Austin.22 Through trials and testing, AT&T has “collected mountains of data and insights to comb through, obsess over and ultimately act on.”23 These trial learnings are guiding AT&T’s mobile 5G launch this year and will help ensure that AT&T is building a 5G network that is both real and reliable for everyone.24
To support the massive data use that 5G will bring, AT&T is expanding its deployment of
software-defined networking,25 as well as related elements like white box (replacing traditional proprietary routers inside cell towers with new hardware built around open standards that can be quickly upgraded via software)26 and Network AI (deploying open source software in AT&T’s centralized network cloud and in AT&T’s edge cloud).27 Having virtualized 55 percent of its network already, AT&T plans to reach 75 percent virtualization by 2020.28
AT&T is also actively seeking to enhance further its 5G capabilities by acquiring
additional spectrum for its 5G build out through secondary market transactions and future
auctions. As AT&T has stated, “future wireless growth will increasingly depend on our ability
to offer innovative video and data services on a wireless network that has sufficient spectrum and capacity to support these innovations,” and “[w]e continue to invest significant capital in . . . obtaining additional spectrum that meets our long-term needs.”29
https://ecfsapi.fcc.gov/file/1082768442509/AT&T Comments in TMUS Sprint 8-27-18.pdf
I. THE U.S. IS ALREADY THE WORLD LEADER IN 5G
T-Mobile and Sprint state in their Public Interest Statement that their proposed merger is
“necessary” for “the rapid and widespread deployment of 5G networks.”2 The merger, the
Applicants claim, will “force” AT&T “and other competitors to more quickly provide faster,
better 5G services” instead of the “tepid adoption” of 5G that could be expected otherwise.3
Absent a merger, the Applicants contend, “none of the carriers are on track to deploy a robust national 5G network quickly.”4
In fact, the U.S. is already the world leader in 5G, and AT&T and the other major facilities
based wireless carriers are in the midst of a race to deploy next generation 5G services – a race that began long before T-Mobile and Sprint announced their merger plans.5 As Chairman Pai has observed, the U.S. is “in the lead on 5G,” 6 and the FCC has taken “important steps that will help solidify U.S. leadership in 5G.”7 Commissioner Carr similarly has noted, “I think we’re really in great shape when it comes to the race to 5G.”8
Analysts echo these comments. A new IHS Markit study finds that “North America seems
to be leading the race to launch commercial 5G services” – “5G is going live in North America by the end of 2018, and then in South Korea in 2019,” but “[m]ost operators in Europe, however, aren’t planning to deploy 5G until 2021 or later.”9 GSMA agrees: “The US will be one of the first countries to launch 5G commercial services, as was the case for 4G.”10 GSMA notes the “continuous efforts from US government institutions to support 5G progress through new spectrum allocations (including mmWave bands) and work to enable infrastructure deployment,” as well as “[c]ontinued, significant operator investment in both fibre infrastructure and 4G network upgrades.”11 Indeed, analysts estimate that nearly half of the mobile subscriptions in North America will be 5G by 2023.12 As the trade press explains, the wireless industry is engaged in an “early 5G arms race,”13 and this rush to deploy the best 5G service the fastest will continue with or without the T-Mobile/Sprint merger.
AT&T is fully engaged in that arms race and is leading the industry. AT&T already
offers “5G Evolution in more than 140 markets, covering nearly 100 million people with
theoretical peak speeds of at least 400 Mbps,”14 and AT&T plans to serve more than 400 markets by the end of 2018.15 5G Evolution technology takes advantage of features like 256 QAM, 4x4 MIMO, and three-way carrier aggregation, which permit enormous boosts in speed and capacity.
In addition, AT&T is starting to upgrade cell towers with LTE-Licensed Assisted Access (“LTE LAA”), which achieves theoretical peak speeds of up to 1 Gbps.16 LTE-LAA combines
unlicensed spectrum with licensed spectrum through carrier aggregation to increase network
capacity – providing faster speeds and a better customer experience. AT&T has deployed LTE LAA in 15 markets and expects to reach at least 24 later this year.17 AT&T “expect
AT&T’s launch of mobile 5G service will be the culmination of testing that began in
2016 with an enterprise 5G trial in Austin in which AT&T used millimeter wave (“mmW”)
technology to power a 5G network experience in a customer’s office.19 AT&T subsequently
expanded these pre-standards 5G mmW fixed wireless trials to three additional communities – South Bend, Kalamazoo, and Waco – where AT&T worked with residential, small business, and educational trial participants. 20 AT&T also created a 5G testbed in Austin where engineers could build and test creative solutions and run “stress tests” simulating real-world customer experiences before they are rolled out to customers.21 More recently, AT&T has tested standards-based mobile 5G, also in Austin.22 Through trials and testing, AT&T has “collected mountains of data and insights to comb through, obsess over and ultimately act on.”23 These trial learnings are guiding AT&T’s mobile 5G launch this year and will help ensure that AT&T is building a 5G network that is both real and reliable for everyone.24
To support the massive data use that 5G will bring, AT&T is expanding its deployment of
software-defined networking,25 as well as related elements like white box (replacing traditional proprietary routers inside cell towers with new hardware built around open standards that can be quickly upgraded via software)26 and Network AI (deploying open source software in AT&T’s centralized network cloud and in AT&T’s edge cloud).27 Having virtualized 55 percent of its network already, AT&T plans to reach 75 percent virtualization by 2020.28
AT&T is also actively seeking to enhance further its 5G capabilities by acquiring
additional spectrum for its 5G build out through secondary market transactions and future
auctions. As AT&T has stated, “future wireless growth will increasingly depend on our ability
to offer innovative video and data services on a wireless network that has sufficient spectrum and capacity to support these innovations,” and “[w]e continue to invest significant capital in . . . obtaining additional spectrum that meets our long-term needs.”29
https://ecfsapi.fcc.gov/file/1082768442509/AT&T Comments in TMUS Sprint 8-27-18.pdf
