AT&T tells FCC just how important T-Mobile is, in 381-page redacted document

Sean Hollister
S. Hollister|04.22.11

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AT&T tells FCC just how important T-Mobile is, in 381-page redacted document
AT&T has many strategies for trying to convince the US government to let it buy T-Mobile, but the one it emphasized was this -- it would attempt to make remaining carriers Verizon, Sprint and even a handful of rural entities look like "intense competition." Well, it seems that tack hasn't quite had the impact that the board of directors was hoping for, because it just delivered a gigantic new document to the FCC, which portrays itself as the victim of its own success. AT&T says it had to deliver 8,000 times percent more mobile data in 2010 than it did three years prior -- over 10 petabytes per month these days -- and foresees that it will deliver that same amount of data "in just the first five to seven weeks of 2015."

Meanwhile, T-Mobile is the knight in shining magenta armor to save AT&T from those "severe capacity constraints," but since AT&T can't let regulators think that T-Mobile's departure from the arena will result in less competition, Ma Bell simultaneously bashes its prospective conquest for having a "diminished market role" in the telecom industry and "no clear path to deploy LTE" -- even as it says that acquiring T-Mobile would result in the means to spread speedy Long Term Evolution across 97.3 percent of the general population. In case you're keeping track, that's up from the 95 percent the company last prognosticated. The seeming contradictions here are certainly amusing, but we have to admit the promised giant LTE network tempts us quite a bit. But is it worth building a GSM monopoly to do it? Envision the repercussions for yourself -- both good and ill -- by studying the following links.

Update: Fixed a few math errors -- AT&T processed over 10 petabytes per month (not year) in 2010, and that was 8,000 percent (not times) the amount of mobile data it carried in 2007. For comparison's sake, the entirety of YouTube was said to have streamed 31 petabytes per month in 2008, and Hulu did 17 petabytes per month over the same time period, according to a Cisco study.
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AT&T Files Public Interest Statement with FCC on T-Mobile Acquisition

DALLAS, Texas - April 21, 2011- AT&T Inc. (NYSE: T) today filed with the Federal Communications Commission its Public Interest Statement regarding its proposed acquisition of T-Mobile USA. The filing demonstrates the numerous benefits of the merger, including the deployment of 4G LTE network technology to more than 97 percent of the population. When the parties announced this transaction in March 2011, AT&T initially stated that it would deploy LTE to 95 percent of the U.S. population. After conducting a more refined analysis of the combined network, AT&T is increasing the scope of this commitment to 97.3 percent. This deployment will help fulfill this Administration's pledge to connect every part of America to the digital age, and it will create new jobs and economic growth in the small towns and rural communities that need them most.

The publicly available filing, with certain portions containing competitively confidential information redacted, is available at

Additional highlights of the filing include:

AT&T has helped make the United States the global leader in mobile broadband and smartphone sales. AT&T's mobile broadband leadership, however, presents it with unique spectrum and capacity challenges. A smartphone generates 24 times the mobile data traffic of a conventional wireless phone, and the explosively popular iPad and similar tablet devices can generate traffic comparable to or even greater than a smartphone. AT&T's mobile data volumes surged by a staggering 8,000% from 2007 to 2010, and as a result, AT&T faces network capacity constraints more severe than those of any other wireless provider.

AT&T is using up its spectrum at an accelerating rate, and the wireless broadband revolution is just beginning. Over the next five years, data usage on AT&T's network is projected to skyrocket as customers "mobilize" all of their communications activities, from streaming HD video and cloud computing to a range of M2M applications like energy management, fleet tracking, and remote health monitoring. In just the first five-to-seven weeks of 2015, AT&T expects to carry all of the mobile traffic volume it carried during 2010.

This merger provides by far the surest, fastest and most efficient solution to that challenge. The network synergies of this transaction will free up new capacity - the functional equivalent of new spectrum - in the many urban, suburban and rural wireless markets where escalating broadband usage is fast consuming existing capacity.

This transaction will thus benefit consumers by reducing the number of dropped and blocked calls, increasing data speeds, improving in-building coverage, and dramatically expanding deployment of next-generation mobile technology.

The transaction's benefits arise from the uniquely complementary nature of AT&T and T-Mobile's GSM/HSPA+ technologies and spectrum holdings.

The combined company expects to integrate a significant portion of T-Mobile cell sites into the AT&T network. Upon network integration, which will benefit customers in as little as nine months, this will equate to "instant" cell splits - increasing cell density and effectively doubling the amount of network traffic that can be carried using existing spectrum in the areas served by those cell sites.

Groups across the political spectrum, including a broad range of consumer, disability, civil rights, and rural advocacy groups have highlighted the transaction's potential to empower consumers, workers and small businesses to participate more fully in our nation's broadband society.

The U.S. wireless marketplace is fiercely competitive, characterized by escalating usage, product differentiation, rapid innovation, fierce advertising campaigns, new entry, and sharply declining prices for wireless service by unit of consumption (e.g., minutes or megabytes). In fact, the FCC found last year that approximately three-quarters of Americans live in localities contested by at least five facilities-based wireless providers. These other competitors are rapidly growing and investing and will ensure the wireless marketplace remains vibrantly competitive after the transaction.
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