The Next 5G Spectrum Band: 12 GHz for the Win!

By Michael O’Rielly

It should be indisputable that the wireless industry in the U.S. needs access to more mid-band spectrum to compete in today’s modern communications marketplace.  Notwithstanding the substantial benefits that consumers will soon enjoy thanks to the Federal government’s recent actions to reallocate spectrum (like making Phase I of C-Band operational for 5G services), the mid-band spectrum currently available is not nearly enough to support the overwhelming demand for new wireless innovation.  And, the near-term spectrum pipeline is either lacking and/or many years away.  That’s a major reason why I believe it is absolutely imperative that Congress embrace the industry-led proposal to update old allocations to permit 5G use in 500 MHz of the 12 GHz band (12.2-12.7 GHz), while still protecting current incumbent users from harmful interference.  It is not hyperbole to suggest that this would be one the single greatest actions that could be taken this year to ensure the future success of the U.S. wireless industry and improve the lives of Americans.  

Spectrum Policy is Critical

Despite the vital principle of technology neutrality, there are certain inherent advantages to terrestrial wireless communications over its wired counterpart.  While the capacity of wireless networks may not fully equal that of fiber networks, modern wireless services and devices have significant advantages: an untethered connection is both faster and far cheaper to deploy.  Fiber will likely remain a main component of broadband networks – at least for the foreseeable future – but demand for wireless connectivity to support data, voice, and video is driving massive increases in network demand.  As we know, the popularity of mobile wireless services has increased exponentially since its early days.  As 5G America’s President Chris Pearson explained this month, the annual global mobile data growth rate is forty-four percent.  Put another way, mobile wireless network operators could experience a need to “double the size or capacity of their networks every 20 months to keep up with demand.”[i] 

A heavy driver of new wireless capacity needs is broadband traffic.  Sadly, a portion of American families do not yet have access to any broadband connection due to their household location.  Congress has made providing access to these families a national imperative and has allocated almost $100 billion for direct broadband access and another hundreds of billions that could be used for the same.  Wireless broadband solutions will make sense in many of these locations, but adding subscribers to these networks may be further challenged by capacity constraints. 

Unfortunately, achieving the capacity needed to meet growing consumer demand is extremely difficult.  The tried-and-true mechanisms include adopting new equipment and technologies, thereby pushing networks to be more efficient and effective.  But this can only do so much.  Instead, new resources (i.e., wireless spectrum) must be added to providers’ portfolios.  Because spectrum is a finite resource, finding new frequencies for these purposes is like participating in a perpetual automobile accident: few incumbent users are willing to even consider moving out of a band or to allow terrestrial wireless services to be used simultaneously in “their” band.  These spectrum fights have become common place and often demand difficult decisions on which incumbent users must be relocated, displaced, or made to share in order to obtain overall wireless progress.        

The 12 GHz Opportunity

Thankfully, the 12 GHz band provides a welcome opportunity.  While not all incumbent users are on board, a significant number of current licensees, including the primary direct broadcast satellite (DBS) user of the band, are willing to open the band to additional terrestrial wireless services.  This refreshing change represents a path forward, especially with current licensees helping to lead the charge.  And unlike many other bands, there are no government stakeholders in 12 GHz.  Moreover, there appears to be the political will to make the rule changes, even if opposition from some quarters remains, as long as the technical feasibility of potential harmful interference can be successfully documented. 

In simplest terms, the 12 GHz band is currently serving three main purposes and related industries.  First, it is used for downlinks between DBS services and their subscribers.  Second, non-geostationary satellite orbit Fixed Satellite Service (NGSO-FSS, i.e., mainly Starlink) use it to transmit broadband data from its satellites to subscriber receiver dishes.  Lastly, Multi-Channel Video and Data Distribution Service (MVDDS) licensees are allowed to use it to offer a one-way, lower-powered data link service.  Under current rules, both NGSO-FSS and MVDDS licensees in the band must not cause harmful interference to DBS.  In short, the DBS industry has the greatest protections afforded licensees in the band and the most to lose should the interference issue be handled improperly – a point that must be acknowledged as decisions are being made. 

Surmountable Challenges

At this time, the only relevant debate over opening the 12 GHz band should be about the potential harmful interference to incumbent services in the band.  The interference data submitted in the record provides a very favorable picture as it pertains to incumbent NGSOs.  In particular, the RKF Engineering Solutions’ technical report, filed by RS Access last year, studied the co-existence of 5G mobile services and Starlink’s NGSO system in the band.  The extensive and creditable Monte Carlo modeling found that “coexistence between robust deployments of 12 GHz spectrum, both for 5G and for NGSO FSS broadband, is achievable in nearly all deployment scenarios – even without coordination.”  Specifically, the study reported that “few, if any, of the 0.888% of nominally affected Starlink terminals will experience service interruption, or even service degradation, in actual practice for several reasons.”  Ironically, the loudest objector to opening 12 GHz for 5G would face a minuscule risk to harmful interference, according to RKF.  It is also worth noting that Starlink received its spectrum authorizations – which includes 15,000 MHz of other spectrum – without paying a penny.  And, Starlink’s approval for the 12 GHz band and subsequent investment was at its own risk.  In contrast, the current terrestrial MVDDS licensees purchased their licenses at spectrum auctions in 2004 and 2005 and are now asking for an update to outdated rules to support new 5G uses.

While opponents have tried to critique the RKF study, they have offered few compelling arguments and none have submitted expert data of their own to back up their claims.  Remember, the standard is not – and has never been – zero interference; it is harmful interference, which has been managed repeatedly in recent spectrum actions over the last few years (see C-Band, 5.9 GHz, and 6 GHz, etc.).  The D.C. Circuit recently affirmed this standard in a ruling related to the 6 GHz band.  The Court agreed that zero interference is not the standard for spectrum sharing and that statistical Monte Carlo analysis is superior to a worst-case-scenario analysis.

Complaints from some opponents to 5G in 12 GHz should be seen for what they are: attempts at spectrum protectionism.  As mentioned, it’s something faced in almost every spectrum reallocation when bands are not cleared or by services in surrounding areas.  The simple fact is that ceding spectrum – especially if obtained for free like Starlink did – without trying to obtain some type of compensation or understanding might violate its fiduciary obligations to shareholders or management.  The more these entities can raise objections or create a foggy situation, the more likely they can either be paid or push the issue for another day, in which it might get paid.  That, however, should not be a winning strategy, and it is certainly not a strategy that helps American consumers.        

Further, sound spectrum policy decisions cannot be made based on arguments presented by those seeking to block competition.  This can come in many forms, and somewhat depends on what new services are allowed into the band.  But make no mistake, a select portion of existing licensees often raise unfounded concerns and even challenges to additional band uses that ultimately could be used by consumers for substitute product lines or services.  The prospect of competing with innovative new wireless services makes existing providers do questionable things, even if the goal is to delay new service introduction by months or a few years.  In today’s vibrant broadband marketplace, a little delay can be all that is needed to gain an advantage or stifle new entrants.            

Lack of Reasonable Alternative Bands

Opening the 12 GHz band to 5G can be justified in its own right, but an examination of other potential options should add further justification for the case.  It is simply the best mid-band option available for future wireless services.  In other words, there is not a long list of viable mid-band spectrum that can or should be used in the alternative.  In fact, the list is short and quite dubious.  After a likely protracted process, exactly how much licensed spectrum should be expected from the 3.1 to 3.45 band, and how soon?  It’s hard to see that process concluding sooner than 2025 or without a completely mixed bag of encumbered blocks making sharing regimes or unlicensed regimes more likely.  Other bands that have been bandied about by experts – like 7, 8, 13-15 GHz – all come with substantial issues or are years away, at best.  It’s entirely feasible that another 100 MHz could come from the residual satellite use of C-band, but good luck unlocking it, given the way satellite providers were treated by the previous reallocation and the actions of the FAA with regards to the altimeter debacle.  It is hard to see any other momentum or movement on mid-band spectrum, other than 12 GHz.  Should anyone believe that this Administration wants to go an entire four years without identifying and making a new mid-band spectrum allocation?

Additionally, the wireless industry, both licensed and unlicensed, has made it clear that when it comes to 5G and higher spectrum bands, they need large blocks.  Specifically, they have sought blocks of 100 MHz or those that are easily interchangeable to assemble into a functioning whole.  Almost all of the alternative bands being discussed in spectrum circles are unlikely to meet this condition.  While I am certainly hopeful that the Department of Defense will open 3.1-3.45 to permit licensed, sharing, and unlicensed in sufficiently large units, I am somehow doubtful that it will under the current statutory restrictions.  That’s where the 500 MHz of 12 GHz comes in: it can provide exactly what is needed today.  Depending on construction of the band plan, it should be possible to configure in a way to ensure wide blocks for 5G services.

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The 12 GHz band represents an amazingly rare win-win spectrum opportunity for consumers, the wireless industry, and our telecom leaders.  New 5G services in this band are necessary for future wireless competitiveness, and, based on the expert engineering, can be done without unduly impeding incumbent uses. 

The opinions expressed in this blog are those of the author and are not intended to be a submission to the Federal Communications Commission with the intent to influence agency employees in the performance of their official duties in any current or future Commission matter.

 

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[i] Spectrum Crunch: Doubling Mobile Data Demand Every 20 Months - 5G Americas 

Congress Needs to Fix Major Funding Shortfall in Rip & Replace Program

By Michael O’Rielly

For years now, Congress has been appropriately focused on the national security concerns of our nation’s communications networks and those nation states or groups seeking to do harm to the American government and its people.  From banning specific companies from serving the U.S. market, ensuring the functionality of “Team Telecom”, funding removal and replacement of network equipment, and numerous other measures, Congress has sought to minimize key weaknesses and vulnerabilities in these networks.  Unfortunately, changes required of the private sector as a result of these measures are proving more expensive than originally anticipated.  In particular, applications for reimbursement under the so-called “Rip & Replace” program are now expected to total over $5.6 billion, when only $1.895 billion in Federal funding has been provided for this purpose.  Congress can and should promptly fix this, as the failure to do so would undermine a central national security effort and inappropriately leave communications companies holding the bag for these costs. 

Meeting Congressional Commitments

The principles established by Congress in the Secure and Trusted Communications Networks Act of 2019 are sound.  The applicable House Committee Report notes that “Given the pivotal role that private communications networks serve in connecting U.S. critical infrastructure functions, American networks are appealing targets for foreign adversaries.  The United States, therefore, has a clear interest in mitigating threats posed by vulnerable communications equipment and services.”[i]  A combination of this law and Federal Communications Commission actions effectively does this by requiring a broad swath of certain communications providers’ equipment (and services) capable of being abused to the detriment of U.S. national security, particularly that supplied by Huawei and ZTE, be identified and subsequently removed with cost reimbursements paid for by the government.  Specifically, Section 4 of the law, as amended, establishes a thoughtful mechanism for smaller providers (those with 10 million or fewer customers) and other key entities (e.g., non-commercial educational institutions, health care providers, and libraries) to remove, replace, and dispose of “communications equipment or service that poses an unacceptable risk to the national security of the United States or the security and safety of United States persons”.  In essence, these providers are obligated to remove untrustworthy equipment and be reimbursed for such costs, while minimizing opportunities for waste, fraud, and abuse.

Indeed, the necessity for the reimbursement program is especially strong.  Congress targeted resources to smaller broadband providers that unwittingly purchased cheaper equipment (i.e., Chinese origin), which had the unintended consequence of helping to strengthen the Chinese Government, improve its world influence, and expose U.S. networks for potential manipulation and abuse.  As House Energy and Commerce Subcommittee Chairman Michael Doyle stated on the House floor, smaller providers – unlike their larger brethren – “didn’t get the same heads-up by our government”[ii] of the risks generated by such equipment.  Thus, these entities purchased the troubling equipment without warning and now find themselves in the unenviable position of being told to remove it.  Similarly, Ranking Member Bob Latta stated, “This bill takes into account important concerns we have heard from small, rural providers that were previously unaware of possible security risks when selecting vendors and making purchasing.”[iii]  In other words, the U.S. government did not share, either intentionally or by negligence, vital information on potential threat exposures with smaller providers and now seeks their compliance for the equipment   removal effort.  

To put this in context, Congress and the FCC created the mandates that identified equipment used by certain communications providers be removed.  Applicable communications providers are in little position to ignore this requirement and it should not be seen as voluntary.  As such, the relevant issue, which was already answered once by the FCC and ostensibly by Congress, is whether cost to smaller providers for conducting this work and replacement equipment should be done without sufficient reimbursement.  In fact, when considering funding for the Rip & Replace program on the Senate Floor, Senate Commerce Committee Chairman Roger Wicker said, “Let me also make the point that some things are worth paying for, and protecting Americans, protecting our electronic system, our broadband communications from the Chinese-owned Huawei and ZTE is worth paying for.”[iv]

Any lack of additional funding above the $1.9 billion effectively creates a massive unfunded mandate of approximately $3.7 billion, as existing funding will be prorated to recipients.  Even though the statute prioritizes funding for very small providers (i.e., those with 2 million or fewer customers), this will not resolve the needs of these providers, necessitating prorated reimbursements at significantly reduced rates.  That’s means, smaller providers would be faced with untenable options, including the possibility of going out of business.  The result could be even further reduced broadband service in rural areas.  In the meantime, these companies are facing extreme uncertainty.

It’s important to note that there is history of Congress increasing initial funding levels after a statute has been passed when it was deemed necessary.  Consider the added funding Congress made available under the digital set top box program as part of the analog television conversion process.  In that instance, Congress created a two-step funding stream based on consumer demand for the program.  However, even with this structure, anticipated demand exceeded funding resources  and Congress stepped in to allocate an extra $650 million the program.  Likewise, Congress added additional funding as part of the successful Broadcast Incentive Auction.  Specifically, the initial costs for the repacking of broadcast stations exceeded the Congressional allotment of $1.75 billion.  With more programmatic experience, Congress added an additional $1 billion for the vital reimbursement purposes.  In the end, these added funds were essential to accomplishing the Congressional directives contained in the respective statutory provisions. 

National Security Needs

The risk of not fully funding the replacement costs for untrustworthy equipment is significant.  As House Energy and Commerce Committee Chairman Frank Pallone stated in the requisite House legislative hearing, which helped lead to the statutory provisions, “Communications networks are interconnected and that means that one weak link can harm the whole system.  We must help smaller carriers remove suspect equipment for the good of the entire country.”[v]  Yet, without sufficient reimbursement funds available, there is a high likelihood that smaller carriers will be simply unable to remove the troubling equipment in any scheduled timeline.  Many of these carriers cannot cease operations for a time period to install necessary equipment or conduct the necessary transfer to new equipment while still remaining financially viable.  Absent such equipment replacement, the U.S. would consist of a patchwork of upgraded and replaced networks on one hand and those that aren’t able to do so on the other hand.  Given the interconnected nature of wired and wireless broadband networks, any system that maintains suspect or untrustworthy equipment makes all networked systems more vulnerable to abuse or potential attack.   

To clarify the gravity of this situation, Section 2 of the statute explicitly identifies two threats by not replacing the requisite equipment.  First, such network equipment potentially could be used to route or redirect “user data traffic or permitting visibility into any user data or packets that such equipment or service transmits or otherwise handles.”  This indicates that this suspect equipment is capable of being manipulated for purposes of disrupting user communications or to gain access for some monitoring or perhaps nefarious purpose.  The consequences of these scenarios are potentially cataclysmic.  For example, disrupting communications could lead to a partial or total shutdown of critical user information, especially during emergencies.  Those that have experienced communications blackouts know how damaging this can be.  Moreover, allowing a foreign actor to collect and examine user communications could facilitate the building of extensive dossiers on all Americans or obtain the sensitive communications of our elected leaders.  Second, the statute identifies the possibility that the untrustworthy equipment could be disrupted remotely.  That implies that foreign adversaries could have the means and opportunity from afar and without detection to use weak entry points in the network via this equipment to gain complete control over any connected network.  The harms that could come from such an occurrence are immeasurable.

Timing Important for Broadband Access

Complicating the reimbursement program’s funding issue is the desire from the legislative and executive branches of the Federal government, as well as state and local officials, to see all Americans have access to broadband.  As opposed to those Americans with cost or adoption issues, those without broadband access are disproportionately likely to live in less dense or rural areas of the country.  These places tend to be where smaller broadband companies operate and thrive.  Furthermore, the smaller providers facing the major Rip & Replace program challenges are likely to be some of the same ones that can bring broadband to unserved Americans. 

The problematic Rip & Replace program funding is likely to keep some smaller broadband providers on the sidelines as it comes to expanding out their networks to neighboring areas or expanding to new markets.  Such uncertainty may feed into the rates paid for matching capital, when needed, or the willingness of states and other officials to select these providers as winning grantees for new broadband access money.  Additionally, it means that applications for broadband network access builds will be more expensive and generate fewer submissions.  If policy leaders want to ensure that every American has access to broadband it needs to make sure that those providers likely to bring solutions forward are not financially hamstrung by an underfunded reimbursement program. 

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The Rip & Replace program has a sound justification – help protect U.S. national security – and a solid structure.  But it lacks the necessary funds to make it effective.  That is something Congress can rectify, and I hope it does soon.   Absent doing so, we will be left with an under-protected communications network system that leaves Americans more vulnerable to harm and also threatens the viability of rural communications network providers. 

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[i] CRPT-116hrpt352.pdf (congress.gov)

[ii] CREC-2019-12-16-pt1-PgH10282.pdf (congress.gov)

[iii] Ibid.

[iv] CREC-2019-12-19-pt1-PgS7178.pdf (congress.gov)

[v] 2019.9.27.PALLONE. Supply Chain Leg Hearing.CAT_.pdf (house.gov)  

U.S. National Security and Trusted Global Manufacturers: Part 1

by Michael O'Rielly

One of the undeniable priorities of the federal government is to preserve the security of the nation – and as a result, the safety and security of the American people – against those who seek to do us harm.  At the same time, national security-based prohibitions and restrictions should not be used like a fishing net to capture unrelated matters or entities.  Their application must be narrowly tailored to only those relevant threats or risks.  Simply put, over-inclusiveness under the guise of national security stifles or stops dead legitimate and positive activities and commerce.  Yet recent telecom debates and the accompanying rhetoric have suggested that some people believe foreign equipment manufacturers are monolithic and all of equal risk to U.S. national security and its companion concern: supply chain breakdowns.  This kind of imprecision can negatively and unfairly impact the market.  Policymakers should carefully differentiate, in their words and when drafting legislative text, between foreign equipment manufacturers that are a real risk to national security and those global manufacturers that are not.  

To unpack the current provider market for telecom equipment, it’s worth understanding some of the past.  Until the mid-1990s, the U.S. had several fairly strong equipment manufacturers headquartered domestically and operating globally.  They supplied much of the old needs of the world’s telecom providers.  Because of a number of factors, including the development of new Internet equipment providers, poor management and decisions, implosion of the long-distance sector, and an overall bursting of the telecom industry stock bubble, U.S. manufacturers faced enormous pressures.  Equipment providers went through a very long and painful rebranding and industry consolidation, leading to some leaving the business and to foreign companies merging with and some ultimately purchasing U.S. providers.  As a result, much of the U.S. market, certainly the wireless sector, is serviced primarily by global telecom equipment providers that are, in fact, headquartered overseas. 

Deriding global equipment providers for being “foreign,” however, does a real injustice to their underlying U.S. roots.  In reality, three of the larger companies – Ericsson, Nokia, and Samsung – are headquartered in U.S.-allied countries.  They partner with U.S. law enforcement and intelligence agencies, as well as global intelligence agencies, as necessary and appropriate.  Moreover, these companies are de facto American, given their massive investments in facilities, workers, and responsibilities in this country.  Research and development is done here; their customer deployments are managed, led, and executed here; and their procedures and operations comply with all U.S. law.  At least one manufactures 5G equipment here.  They should be viewed not as foreign affiliates, but U.S. companies that also have affiliates throughout the world.  Given the unique histories of each of these companies, it’s irrational to think or expect that they would relocate their headquarters to the U.S.  Nonetheless, this is not a reason to treat them as anything other than trusted partners in the fight against risks to U.S. national security. 

The situation involving these trusted equipment providers differs substantially from at least two others.  The first are foreign-based equipment providers that originate or reside in adversarial countries known to directly generate national security risks, or that have obligations because of their headquarters within those foreign governments or regimes.  Because of these relationships, the practices of their host countries, and other considerations, equipment firms from Russia and China have appropriately received additional scrutiny and remediation efforts.  Treating these companies in adversarial countries differently, as U.S. lawmakers have done in recent times, can make sense under the right conditions.

Chinese companies, in particular, can raise certain political and economic tensions, given the Chinese government’s historic involvement in commerce and the operational requirements it imposes.  Added to this is extensive mistrust internationally from decades of sensitive and critical intellectual property and business secret-stealing by Chinese organizations.  Furthermore, financial arrangements and lending practices of the Chinese government, combined with the involvement of Communist Party officials in companies’ activities, produce additional national security concerns. 

The second category worthy of greater review are those equipment providers headquartered in the U.S. that effectively conduct all their work offshore or by foreign operators.  Having a shell of a company in the U.S. claiming to be a domestic provider should cause heightened attention.  At a very minimum, these companies should not be placed on a pedestal.  Yet, these types of companies have been lining up efforts to both receive favorable treatment as “U.S. firms” and impose penalties or competitive disadvantages on trusted global equipment providers.  That twists logic on its head. 

This circumstance is exactly why headquarters location is such a poor measurement of how “domesticated” or “U.S. nationalized” a company supposedly is.  The selection of a location for company headquarters is done for many reasons, like owners’ nationality or tax and legal purposes, and is difficult to determine based on this how exactly ingrained the company may be in U.S. soil or society.  It is also always subjective, as someone must make a judgment call about whether certain functions or services should count as domestic or foreign, and then determine if those rise above some arbitrary level.  In the end, it is a useless exercise, because domestication does not necessarily equal trusted partners and overseas producers don’t necessarily equal greater risk to U.S. national security.  

Instead, whether a firm can be trusted to protect U.S. national security should be the proper determination.  Is the equipment it builds, installs, manages, or sells trustworthy?  In other words, is its equipment properly secure from being used for nefarious or harmful purposes?  Does it alert proper authorities if or when a secure chain is compromised?  Does it provide equipment and service to the U.S. government for sensitive functions?  These are just some of the questions that are relevant when discussing trust, and they get to the heart of whether national security concerns may be raised by an equipment provider or servicer. 

While imprecision may be plaguing recent debates, official congressional actions through the legislative process have actually proven to be thoughtfully constructed and consistent with my points here.  Consider the Secure and Trusted Communications Act of 2019 (P.L. 116-124).  Section 2 requires the FCC to produce a public list, which it has done since, of covered communications equipment or services that “poses an unacceptable risk to the national security of the United States or the security and safety of United States persons.”  In section 8, the law requires the National Telecommunications and Information Administration (NTIA) within the U.S. Department of Commerce to “engage with trusted providers of advanced communications service and trusted suppliers of communications equipment or services.” It specifically defines “trusted” to only be those providers or suppliers, “not owned by, controlled by, or subject to the influence of a foreign adversary.”  This is certainly one direction for addressing national security that avoids a proximity examination of a company’s headquarters to U.S. homeland.  

That law differs substantially from other, misguided legislative efforts.  For example, a Senate amendment filed to the U.S. Innovation and Competition Act (formerly the Endless Frontier Act) would have created a new grant program to promote Open Radio Access Networks, or Open RAN, but limited funding to only companies that are U.S.-headquartered.  Thankfully, the amendment was not offered or approved, partly because it would have raised numerous violations of U.S. obligations to the World Trade Organization, and partly because it is lousy policy.  Likewise, the House is not immune from such wrongheaded efforts.  Report language was added to the House Armed Services Committee’s FY2022 National Defense Authorization Act favoring Open RAN and seeking reports from the U.S. Department of Defense on its efforts “supporting the development of a domestic industrial base for 5G.”  This is a blatant attempt to favor U.S.-headquartered companies at the expense of trusted global telecom equipment providers. 

In the end, the foreign headquarters location debate, and considering ways to inappropriately treat global equipment and service providers, are detrimental to national security by impeding such trusted companies.  These efforts ignore the real threats and seek to promote U.S.-headquartered companies, which typically are mere shells for work done overseas.  That means policymakers must stop drafting and advocating for imprecise or intentionally slanted efforts that focus on the wrong targets.  Congress has proven that it can and should center attention and added scrutiny on non-trusted providers, and the rhetoric leading up to any final law should match this approach. 

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The opinions expressed in this document are those of the author and are not intended to be a submission to the Federal Communications Commission (or any other government agency or proceeding) with the intent to influence agency employees in the performance of their official duties in any current or future Commission matter.

Introduction and Welcome

Today, I start a new offering in my private sector consulting and advocacy venture, MPORielly Consulting Inc., with the creation of this new blog feature: TMT and Me.  

I hope this outlet provides monthly value for those seeking real discussions on tech and telecom policy matters that have been my career’s work.  Call it weedy, meaty, or borderline boring, I intend to avoid some of the superficial conversations and dig deeper than most on what’s already in play and what should be happening.  Those who worked with me in the past will remember that even my one-pagers were packed with substance.  Certainly, there will be some easier reads, maybe along the lines of old Dear Colleagues from the Hill days, but the main direction will be thought pieces of various lengths. 

Through a nearly thirty-year professional career, I have been part of almost every policy debate involving telecommunications or technology issues.  The early House committee days became the Senate years and leadership positions.  Eventually I found myself as FCC Commissioner.  The path was unexpected but provided a catbird seat to lessons on how best to analyze issues and maneuver Washington D.C.  Along the way, I melded my conservative principles with a desire to get things done. 

For those interested, the blog shares its name with the title I heard from so many industry analysts over decades.  TMT -- Technology/Media/Telecommunications -- served as the heart of my government portfolio through so many jobs.  It remains a part of me as I extend my FCC blogging experience to this additive role.  Of course, I’ll still be active on other formats (e.g., op-eds, panels, speaking, advising, and etc.) so there will be multiple chances to see my views.   

I wrote an extensive blog collection while at the FCC and found the medium incredibly useful.  Yet, some question whether blogs have become passé has-beens replaced by Instagram or TikTok moments or do they remain old-school enriched content delivery mechanisms for a sugared-up world?  I guess we’ll find out.  It certainly provides a limitless platform to express my thoughts on the current debates in the telecom and tech ecosystems.  And I’ve got a lot to say.

If you’ve made it this far, I thank you and welcome your productive suggestions as I plug along on this adventure (and please keep any trolling or negativity for your local bartender). 

 All my best,

 

P.S. -- The opinions expressed in any blog, as well as any other work, are those of the author and are not intended to be a submission to the Federal Communications Commission with the intent to influence agency employees in the performance of their official duties in any current or future Commission matter.