City Says That If Mobilitie can Build a Tower in 2 Days, They Can Also Remove it in 2 Days.

You can't make this stuff up. Mobilitie allegedly erected a new mini-macro tower in Goliad, TX – which we posted about on LinkedIn previously. Subsequent to that, this story regarding Sprint approving a trial for Mobilitie to build mini-macro small cell towers without full regulatory compliance is found by reporters at Event-Driven.

In this case, Mobilitie claimed to the County they had all permits. City officials from Goliad investigate and find that Mobilitie did not build the tower in County limits but in the City. City officials then demand that Mobilitie remove the tower or they will do it for them. Mobilitie claims that they needed 2 weeks to do so- to which the City replied

“your firm constructed the tower over a two-day period, on a weekend. Surely, if you could install the tower in two days, you can dismantle it in the same time period.”

Not only did Mobilitie fail to build the tower outside City limits, they may have even failed to build it straight. As reported in the Goliad Advance-Guard, local homeowner

Harvey also claimed the tower is leaning to the north. Blueprints for the installation require a foundation 31 feet deep into the ground; Harvey who says he has had years of experience mounting poles, says a driller will hit bedrock at the 10-foot level.

County officials claim that this type of overnight tower erection was happening in other areas. See the quote below from the Advance-Guard.

“And it’s not just our community, it’s happening in San Patricio County as well,” City Alderman Nathan Lill told the group. “There’s list of other counties that have had the same issue with this exact same company. They’re building the towers at night and they’re not asking permission from anybody to do it.”

This isn't the only place where Mobilitie has been either fined or forced to remove what is alleged to be an improperly permitted tower- it has occurred in Baltimore, MD, and Denison, TX.

Sprint’s Really Odd Antenna Configuration Proposal

On one of our municipal client's towers, Sprint submitted a request to replace three existing antennas with new antennas that add 2.5GHz capability to their equipment.  The subject tower is in a difficult zoning jurisdiction and one where Sprint really doesn't have any other options.   Their collocation rent was on the higher side but not unreasonably so- and the three other wireless service providers were all paying the same or higher rent.  

Because the antennas were the same size or smaller, we did not recommend a rent increase for them.  However, Sprint was adding remote radio units and other equipment so we recommended a fairly nominal increase.  Rather than accept the newly proposed lease terms, Sprint instead asked whether they could replace the existing equipment on the tower with three of these antennas and get a reduction in rent. 

Sprint Proposed Canister Antennas
Possible Sprint Replacement Antennas

The proposed antennas are larger than the existing antennas, but Sprint appears to be wanting to go from 9 panels to 3 of these antennas.  (Not 3 of the canisters)  These panels will accommodate all of Sprint's spectrum bands but would seemingly limit their capacity and number of simultaneous users.   These appear more suitable for a mini-macro as opposed to a macrocell, but I would welcome any thoughts readers have regarding this topic.  

At the end of the day, we advised the client that the value of their tower is its unique location, not the specific loading that Sprint is placing or removing from the tower.   Obviously, there will be situations where a reduction in loading or equipment would justify a reduction in lease rate, but this isn't one of them.  

FL State Representative pushes Small Cell Legislation while his City Issues RFI on Leasing City Property for Macrocells

In the Florida House of Representatives, a bill is being pushed through to significantly limit the control that a local municipality can exert over small cell installations.  The bill also limits the fees that a city may charge for access to municipal poles.   

In committee hearings, Rep. Nicholas Duran (D-Miami) said that the “City of Miami actually is the second worst city in connectivity—digital divide—in our state and in this country in many respects, so for me, this is a question of how can we break down this digital divide.”  While the goal of decreasing the digital divide is certainly an admirable one, one has to question how likely it is that small cells will be deployed in areas that don't already have sufficient wireless coverage.   Certainly, increasing capacity in underserved areas is beneficial.   However, the bill doesn't encourage or regulate where small cells are deployed, letting the industry decide on its own where they should go.   One has to question whether this specific bill will remedy the issues related to the digital divide, especially when considering how the wireless companies tend to deploy infrastructure in the areas where they profit most, not where lower income and disadvantaged people reside.  For an example of this, see this article about how AT&T deploys fiber differently to rich and poor areas.  

Simultaneously, Miami/Dade, the combined City/County government in which Rep. Duran resides issued an RFI for the management of City/County owned properties.   This specific RFI has been debated for years.   Various requests and meetings have been put forth to the wireless industry over that time frame with the City/County choosing not to move forward for various reasons.   We previously attended a meeting at Miami/Dade ourselves.  

Image of Miami Dade RFI Request
From Miami Dade Website
The irony here though is hard to miss.  First, in delaying this RFI/RFP process for years, Miami/Dade has missed out on a significant amount of interest in its property.  Secondly, if the Florida legislature is successful at reducing the fee structure for what municipalities can charge for access to their poles, Miami/Dade will not only get far less than it would have without such legislation but it will also reduce the effectiveness of the RFI.   Respondents will have less incentive to respond because there is less incentive for wireless companies to build macrocells on public property if they can use the ROW at virtually no cost.  Furthermore, with the fee cap, Rep. Duran's specific district and its taxpayers will generate less revenue while incurring additional incremental costs from having to manage and maintain poles that were built with taxpayer money but which are being used by private companies for profit.  

Obviously, this is a tradeoff that Rep. Duran and others could have legitimately decided was worth taking.  We aren't trying to criticize him or anyone else for making that choice- just trying to point out how complex the issues related to small cells and densification are for state legislators.   While the wireless industry has been successful at simplifying them to "you are voting against technological advancement", the issues aren't remotely that simple and there will be far-reaching but inherently local impacts for years to come.  

Small Cells Aren’t Like a Pizza Box

Pizza Box Small Cells
Number of Pizza Boxes that Fit in 6 Cubic Feet or 28 Cubic Feet

WHAT THE INDUSTRY SAYS

The wireless industry has been pushing the fiction that small cells are the size of a pizza box.   Here is a quote in a Wireless Week article– 

"Americans will benefit tremendously from innovations like 5G and the Internet of Things, which require more small cell facilities – often the size of a pizza box – to build a denser network," CTIA's assistant vice president of regulatory affairs Scott Bergmann said. "Today’s action by the FCC recognizes the minimal impact of these facilities, but there is more work to be done. We must streamline infrastructure policies at all levels of government so that wireless providers can rapidly deliver the next generation of products and services to consumers.”  (emphasis added)

Furthermore, as reported by Wireless Estimator here,  "In the CTIA presentation, the trade group said that networks can now be extended on (sic) common structures like street lights and utility poles and that there will be 300,000 “pizza box-sized small cells needed in [the] next 3-4 years.”

WHAT THE INDUSTRY ACTUALLY WANTS

While some small cells are the size of a pizza box- many aren't.   The industry clearly doesn't think so either despite their public pronouncement otherwise.   In the newly proposed state legislation in 20+ states, there is language that allows the wireless industry to install up to 6 cubic feet of antennas and up to 28 cubic feet of equipment on each pole.  For example, see this language from the recently passed Virginia statute.   

"Small cell facility" means a wireless facility that meets both of the following qualifications: (i) each antenna is located inside an enclosure of no more than six cubic feet in volume, or in the case of an antenna that has exposed elements, the antenna and all of its exposed elements could fit within an imaginary enclosure of no more than six cubic feet; and (ii) all other wireless equipment associated with the facility is cumulatively no more than 28 cubic feet in volume, or facilities comprised of such higher limits as established by the Federal Communication Commission. The following types of associated equipment are not included in the calculation of equipment volume: electric meter, concealment, telecommunications demarcation boxes, ground-based enclosures, back-up power systems, grounding equipment, power transfer switches, cut-off switches, and vertical cable runs for the connection of power and other services."

In other words, the industry likes to present to municipalities that small cells are the size of a singular pizza box because it makes a compelling story.   However, the want to give their members the right to install substantially larger equipment than would fit in a single pizza box.   

Please feel free to use this image without attribution.   Also, for another good representation of what 28 cubic feet represents- see http://wireless.blog.law/2017/04/22/california-sb-649-big-lie-small-cells/.

 

Partial Retraction On Previous Mobilitie Related Articles


First Mobilitie Retraction Request: Mobilitie in Orlando

We received a demand letter from Mobilitie requesting that we retract certain statements made in previous articles regarding Mobilitie that we had written.

First, Mobilitie claims that Telemobilitie is not one of the 20 or so fictitious names that they use elsewhere. The letter also claims that Mobilitie did not submit the applications to the City of Orlando that we wrote about here- https://www.linkedin.com/pulse/crown-castle-vs-mobilitie-story-two-small-cell-ken-schmidt. If you examine the two links below, the City of Orlando interchangeably refers to Mobilitie as TeleMobilitie and Mobilitie. We did confirm that Mobilitie did not register the fictitious name "Telemobilitie" in the State of Florida. It is possible that the City was incorrect in their reference in these applications to TeleMobilitie.

http://www.cityoforlando.net/city-planning/wp-content/uploads/sites/27/2015/12/ARB2015-00082report.pdf

Here are the minutes of the meeting where these were reviewed.

http://www.cityoforlando.net/greenworks/wp-content/uploads/sites/27/2015/12/ARB2015-12Minutes.pdf

Furthermore, the person who is listed as the applicant for these applications has a profile that shows that she works for Mobilitie. Accordingly,

Steel in the Air retracts and expressly disavows its earlier statements made on March 16, 2017 claiming Mobilitie, LLC does business under the name "Telemobilitie," and submitted improper applications under the name "Telemobilitië." Mobilitie has never done business under the name Telemobilitie, nor did it submit improper applications under that name.

2nd Mobilitie Retraction Request: Building without permits in New York

In this case, Mobilitie claims that they did submit all proper permits related to the request to build three 120' poles in Washington County, NY. See the article we previously wrote. In it, we claimed that Mobilitie failed to submit the proper permits related to the installation of three 120' poles. We based our belief of this from this article where the reporter indicated "On Vaughn Road in Kingsbury, the company applied for a county highway work permit, which is normally used when a homeowner wants to put something temporarily in the county’s right-of-way. Usually, it’s traffic cones for a driveway resurfacing, officials said." Furthermore later in the article, the County Attorney advised the County to deny the permit requests. At this time, we do not have any separate information regarding whether Mobilitie's permit requests were ultimately approved or whether they ended up submitting different permits that the county approved later. Accordingly, until we can confirm otherwise by a call to the County,

Steel in the Air also retracts and expressly disavows its earlier statements made on April 2, 2017 that Mobilitie was "busted yet again trying to install 120' poles without following the proper local permitting and planning procedure." In both instances discussed in the April 2, 2017 article, Mobilitie followed the proper local permitting and planning procedure. Steel in the Air apologizes for these misstatements and for any misleading impressions created as a result thereof. 

Mysterious Small Cell Pole Erected without Permit- Sounds like Mobilitie

In Penitas, Texas, what appears to be a new small cell pole was erected overnight near a busy thoroughfare.   There is a great news story about this in the video below.  

If you watch the video closely, you will see a small microwave dish at the top which suggests that this is a mini-macro for Sprint, possibly built by Mobilitie.   Six or so months ago, we had heard a rumor that Sprint had ordered a few thousand steel poles but because we couldn't get any other confirmation of this, we didn't go public with that information.   This specific pole looks like it was clearly pre-manufactured and cookie-cutter.  We haven't seen drawings or plan submittals that look like this though anywhere.  

In reviewing the video, it appears that the company installing it has not added panels to the top of the pole but that there are mounts for them.   There is an odd shroud that we surmise may hide additional mounts for other small panels possibly for collocation by other wireless providers.

Another indication that this may be Mobilitie is a post that someone from Mobilitie made on LinkedIn.  (I don't care to call attention to the individual- just the content of the message- he is just doing his job)  

"Went out to the field to kick off our Mobilitie build program. I had an awesome time out in the field again. I miss it from time to time but My office has been very nice to me. Any one in the SE or NE want to be apart of the build program shoot me a message or give me a call. I was able to train a crew and at the same time build 9 sites in 4 days. The money is good even with the rush of the program."

If this pole is Mobilitie's, we expect that this type of news story will occur over and over again in recent months as we wonder whether Mobilitie is attempting to get these poles up and standing prior to the FCC proposed rule-making that will be discussed at the April 20th FCC meeting but not enacted for months.   Our read of the tea leaves is that the FCC will not be granting favorable treatment to 50' and taller poles and will likely require that they meet local zoning requirements.  If this is the case, Mobilitie may be trying to get poles standing in order to avoid potential zoning requirements that may be required in the future for such poles.  We have to wonder whether the entity that constructed this pole submitted and received approval from SHPO/NEPA. The news story says that there was no permit pulled for this pole installation. 

Further potential evidence of this is that Mobilitie posted 170+ jobs across the country just over a week ago- which included construction and network related jobs.  

If our suspicions are correct, there will be many news stories like this in the coming months.  New not-so-small cell poles will be erected "overnight" and municipalities will be left trying to figure out who built them.  

 

 

Sprint Enters the Lease Renegotiation Game Again

A landowner client of ours received this email from LCC, a company allegedly acting on behalf of Sprint where they claim that if the landowner doesn't agree to concessions, that Lendlease will consider relocating the Sprint site.  

Screen shot of email from Sprint
Email from Sprint Representative to Landowner

If you receive a similar request from Sprint, LCC, or Lendlease or another cell tower lease optimization company, please contact us.  We can help you evaluate the proposal and determine whether it is probable that Sprint would move in the event you choose not to accept their proposed rent reduction.

Top 10 Things the Wireless Industry Doesn’t Tell You about Small Cells

By Ken Schmidt, Omar Masry, and Rick Edwards

Are you a homeowner who's recently received a notice indicating that a new small cell antenna is going to be erected on or near your property? Or a lawmaker who has received one of the industry's new opinion papers about small cell antenna regulations? Or an FCC Commissioner who is considering small cell rule-making? Before you start citing from or buying into the pretty pictures and bright-eyed economic projections in the opinion papers below, you should know that these industry-commissioned studies do not tell the whole story:

    1. CTIA – Enabling the Wireless Networks of Tomorrow

    2. CTIA – How 5G Can Help Municipalities Become Vibrant Smart Cities

    2. WIA – Small Cells on Pole Facilities

What's wrong with them, you ask? Plenty. Here are the top 10 things the wireless industry doesn't tell you about small cell antennas:

#1: Despite the wireless industry's calls for collocation using shared infrastructure, in practice, carriers apply for individual small cells instead of shared infrastructure like DAS.

Small cells are standalone individual cells that can be installed separately. They're like miniature cell towers but without the tower. Like towers, a small cell requires both an antenna and equipment. Unlike towers though, the wireless industry likes to place the transmission equipment on the utility or other support structures. In effect, this means that the installation of small cells must either increase the visual blight of the pole or increase the diameter of the pole if the equipment is put inside.

Distributed Antenna Systems, in contrast, typically require less substantial infrastructure attached to each pole and can be more easily made to resemble street lights and signs (like the examples in #2). Common equipment can be placed within a centralized hub conveniently located underground or outside of view. Whereas small cells are single user installations, carriers can share DAS nodes. Multiple wireless service providers can share a DAS node, and multiple frequency bands (Carriers) can be facilitated on each node. This reduces the total number of sites needed and makes each site more attractive because most of the transmission equipment sits in a shared offsite DAS hub.

Given the benefits of DAS, you might wonder why the industry would prefer to build small cells instead of a constructing a DAS? There are 5 reasons – some of which are legitimately problematic for wireless carriers and some of which just require increased investment or time but aren't beneficial to the bottom line.

Reason 1: Each wireless provider has different objectives and may not need the same locations.

Reason 2: Each wireless provider has different deployment times and requiring DAS may force one carrier to wait if others are not ready.

Reason 3: DAS systems cost more because they're designed for the requirements of the most advanced user. So if carrier A needs feature X, even if carrier B doesn't, then the system will include feature X.

Reason 4: DAS systems require a concentrated, coordinated effort and someone to lead it.

Reason 5: Small cells are easier to deploy. DAS applications are reviewed in total – meaning that an objection to any part of the DAS application holds up the entire request.

The result: Providers submit applications for small cells even in downtown, urban core areas where DAS makes more sense. In some cases, providers apply for permits on adjacent poles where it's obvious that a DAS system would reduce visual clutter. Or even submit for new poles adjacent to other light/utility poles of similar height to avoid paying the rate schedules published by municipalities.

The map below shows the actual number of small cell application locations within the City of Houston by four different wireless entities. In a dense urban area like this – why not propose DAS nodes that all entities can share and decrease the number and impact of these facilities on the community?

The wireless industry needs to actually collocate rather than just talk about collocation. Furthermore, the FCC and cities themselves should mandate collocation when multi-carrier small cells are technologically feasible.

#2. The wireless industry associations want standardized federal, state, and local rules but don't even standardize themselves.

The wireless industry demands standardization of state and local government laws related to the erection of small cells. Their opinion papers suggest that without standardization, wireless applicants will be hit with a patchwork of wireless siting regulations. So they're putting forth a multi-pronged approach:

    1. Distributing Industry-Friendly Sample Ordinances

    2. Lobbying Heavily at State Level (see ALEC)

    3. Submitting a Petition for Relief to the FCC (see Mobilitie)

    4. Lobbying Heavily at the Federal Level

The wireless industry alleges — without providing any quantitative analysis — that most municipalities are applying costly, antiquated macrocell regulations to small cell applications. While many smaller municipalities do not have small cell policies in place at this time, that is because the wireless carriers aren't building many small cells in smaller towns and villages. But many larger municipalities (and those where 90% of small cell deployment are occurring) have begun to implement small cell regulations or will do shortly.

At the same time, the wireless industry's applicants can't even submit consistent small cell applications to their municipalities. It's blatantly hypocritical. For example, some cities report receiving location maps showing new small cells in the middle of ponds or on footbridges or in areas that are under another city or county's jurisdiction. Some applicants are not even submitting site-specific applications – instead submitting the same drawing over and over. If the wireless industry believes that standardizing the permitting process is necessary, they should be willing to standardize their own small cell antenna configurations and requests as well. All applications should provide for and include the same information so that the municipality does not have to ask multiple times for the applicant to complete the basic information. Every application should include a structural analysis wet-stamped by a state licensed engineer demonstrating that the new pole or existing pole is structurally sufficient for the current loading. Plans should include where power is coming from and how power will be metered, or better yet be subject to an unmetered wireless rate or utilize wireless smart metering

The WIA and CTIA should encourage standardized applications and requirements among their member constituents. But we believe their approach should not just consist of lobbying states, the FCC, and local governments. These organizations should work towards drafting common application requirements and best practices for their constituent members. They should then discipline or reprimand those members that do not follow such practices. Most importantly, wireless industry associations should focus on assisting member entities in developing and using shared infrastructure.

 

#3. What the industry installs looks vastly different than what they say is possible.

You may remember this article that went viral where Buzzfeed compared the fast food company photos of their food vs. what the consumer actually received.

Similarly, the wireless industry's glossy pictures show an idealized implementation that is far different from reality. Their reports showcase integrated poles with small cells contained within or Distributed Antenna Systems (DAS) nodes with an off-site equipment hub. These appear slim and attractive (relatively speaking). However, when these same wireless carriers or small cell companies submit the actual drawings and applications, the installations do not look anything like those pretty glossy pictures. Or, after they install the attractive poles, they bloat the view with additional equipment, creating a visual blight.

For example, below are photos promoted in the WIA Small Cell document. (Note these pictures are DAS nodes- not Small Cells – see #4 below)

Compare those to photos of actual small cell installations. They are nothing like the photos shown in wireless industry propaganda.

      

The reason for this is twofold: First, the industry likes to show pretty photos of DAS nodes because they are actual possibilities, even though the wireless carriers and tower companies are increasingly abandoning them. Wireless carriers are instead building small cells which usually have more equipment on the pole than DAS's central hub. Second, in many cases, the applicant omit to mention a part of the equipment that's to be mounted near or on the pole either because they're rushed or because they don't want to answer objections. The municipality is left holding the bag – inspecting each constructed small cell in order to confirm whether the applicant exceeded what they were authorized to install. Don't believe this actually happens? Look below to see what the industry submitted as a photo simulation versus what was eventually installed.

  

 

#4.  Once a site is erected, they can go back and increase its size ad nauseam provided that the changes do not exceed federal standards.

Once a small cell or DAS node is attached to a pole, the wireless carriers have the right under Section 6409(a) of the Middle-Class Tax Relief and Job Creation Act to expand their equipment. In other words, once a site is built, municipalities have little power to restrict further expansions of the pole's small cell antenna equipment if the applicants stay within the limits of 6409(a). Moreover, wireless companies can request to expand an unlimited number of times. So even if a small cell starts off looking small and svelte – it could be expanded in size immediately without the municipality being able to stop the expansion. And this can happen over and over again.

A GIF showing steps in a tower being expanded
How a small cell can be expanded into a mini cell tower.

Below is a photo showing what a small cell looks like after multiple expansions.

 

#5: The industry claims that wireless development will not occur without major policy changes. But in fact, wireless development has occurred and will continue to occur even without those changes.

Historically, the industry has made the same argument over and over again: that they will not be able to deploy infrastructure if wireless siting laws aren't loosened. They suggest that most any regulation that slows down wireless deployment limits technological advancement. The industry puts out derisive blacklists of cities and counties that one or more wireless company believes make it difficult or expensive to deploy wireless infrastructure. They label these cities as technologically backward and lobby decision makers to convince them that their city will not grow with such technological restrictions. For example, see this quote from Gary Jabara of Mobilitie about municipalities or counties who aren't receptive to Mobilitie's proposals to erect 120' mini-macro small cells in their city or county.

Nonetheless, even in expensive markets with incriminating reviews like the one above, small cell deployment still occurs. Wireless companies still build towers or even find private locations for rooftop cell sites. A quick examination of Verizon or AT&T's coverage map will show very few holes in urban or suburban areas.

Furthermore, in most states (35 or more) wireless companies have access to utility poles which are subject to pole attachment rates prescribed by the federal government. These pole access rates are fairly reasonable; they are typically less than $500/year per pole. However, working with the utilities can be time-consuming, which is why the wireless industry is pushing for easier access to municipal poles. Isn't it odd that wireless carriers claim to be utilities but aren't actually using utility poles?

Even in markets like Baltimore, MD where the small cell rates are somewhat high compared to other US cities, Baltimore is still receiving small cell applications at a pace comparable to communities with closer-to-average rental rates. In other words, while the industry claims that higher rates impede technological advancement for a city, the reality is that wireless carriers still build small cell sites and many of them. While small cell deployment would likely happen quicker with revisions to regulation and cheaper access to municipal structures, make no doubt about it, the development would occur either way.

 

#6: The industry labels any request for cost reimbursement or rents by a municipality as a "money grab" all while the industry itself is generating $60 billion in profit per quarter.

We participated in a meeting between one city and members of one of the national wireless trade groups. The trade group decried the city's rent requests for access to taxpayer-funded infrastructure as a "money grab." Meanwhile, each of the wireless carriers has generated 20% profit margins or better in recent years – with at least one generating margins over 40%. The Big 4 wireless carriers alone are generating nearly $60 billion a year or more in EBITDA margin while the wireless industry combined generated $85 billion.

To argue that municipalities are money grabbing by charging a reasonable price for access to publicly-funded infrastructure by for-profit entities is disingenuous at best.

If one assumes the industry is constructing 20,000 new small cell antennas a year, even if each pole fee was $3,000/year, the wireless industry AS A WHOLE would only lose out on $60 million or less than .1% of their annual profit. Yes, you read that right,- less than 1/10th of 1 percent of their annual profit.
To put in perspective, Verizon and AT&T alone spent half that amount on lobbying alone in 2016. (see Open Secrets for AT&T and for Verizon)

These arguments seem even more duplicitous when you see the headlines put out by the wireless industry that extol the tremendous revenue opportunities from 5G and other advancements. For example:

The Qualcomm "survey," says the 5G future will support up to 22 Million Jobs and $12 trillion dollars of goods and services.

Cisco says 50 billion things will connect to the internet. Read this article on why the hype on the number of connected devices is overblown.

CTIA citing an Accenture analysis suggests that 5G stands to create 3 million jobs in the US while yielding investment of $275 billion and encouraging GDP growth of $500 billion.

Simply put, the industry has every right to attempt to negotiate with municipalities for cheaper access to taxpayer funded and maintained municipal poles. But if they insist on making it about money, we believe those same taxpayers and municipalities should be prepared to point out the hypocrisy in their claims.

 

#7: The wireless industry wants to pay less for their small cell permit applications yet still receive faster review timelines from understaffed cities and counties.

Historically, we estimate that most cities rarely received more than 50 applications for new wireless sites per year from 2000-2015. Even in the boom years of 2008-2010, cities may have received just 150 applications for new wireless facilities. Contrast that to today: we have confirmed that the City of Houston received over 700 applications in 2016 alone for small cell infrastructure.

On the one hand, the wireless industry politely (or not so politely) asks for a quick turnaround on small cell antenna applications (complaining to the FCC and state representatives when they don't get it) but then on the other begrudges municipalities for charging fees to review the applications. For those of you not entrenched in the minutia of municipal red tape, these requests for the use of infrastructure or placement of equipment are rarely identical from one application to the next. Some companies are very good at drafting thorough and complete applications, but most are not. No matter what size the project is, the items to review in each application are the same. Each site still needs to be reviewed for structural, electrical, and physical safety.

Without standardization by the industry, these applications can't be reviewed easily. This, in turn, increases the cost to the municipality for reviewing such applications. The industry wants the best of all worlds – to submit hundreds of applications simultaneously, have those applications reviewed quickly regardless of their quality, and pay as little as possible for the city to review them.

Some members of the wireless industry have suggested that cities do not need to review the applications thoroughly as the wireless entities already do so internally. For proof of how ineffectively self-regulation works in the wireless industry, look no further than the 2007 Malibu Canyon fire which was caused by utility poles that were physically overloaded with telecommunication company antennas and equipment. Apart from safety concerns, the proliferation of poorly designed small cells can also degrade historic districts and draw noise complaints from neighbors when a carrier with loud cooling fans is mounted on a pole a few feet from a bedroom window.

 

#8: The wireless industry extols the wide-ranging benefits of the Internet of Things (IOT), smart cities, and self-driving cars, but fails to mention that many of these benefits can be obtained using current LTE-based technologies.

First, let's be clear that there are absolutely many wide-ranging benefits from 5G and small cell densification. Truly mobile IOT won't happen without wireless industry investment. No other private or public entity can or will develop sufficient wireless infrastructure in the US to enable pervasive low latency communications. Without wireless industry investment, remote control of sensitive machinery or vehicles simply won't occur. Self-driving autonomous cars will be possible but without the gains in safety and efficiency that would occur from a truly smart network of connected cars.

However, you can get the benefits of low bandwidth, non-essential IOT or smart city sensors and functions without small cells at all (or at least with fewer of them). The CTIA (Accenture) study above cites the benefits using smart meters and smart lighting. These include traffic management systems, public transportation location-based tracking, real-time public parking information, and gun-shot recognition. These are all benefits to be gained from IOT. However, neither Accenture nor the wireless industry makes any attempt to quantify or distinguish which smart city and IOT initiatives require wireless industry involvement and which don't.

Furthermore, these studies don't even remotely acknowledge which IOT benefits can happen on today's LTE networks versus those that need more robust densification of sites to occur. The wireless industry leads you to believe that you need the innovations they want to sell you to get any of these advances of the future. That is inaccurate.

 

#9: While the wireless industry claims densification of small cells is needed to enable smart city and IOT functions, they don't tell you that mobile video is the primary use of small cells both now and in the future.

Cisco, in its 2017 Global Mobile Data Traffic Forecast Update, indicated that video currently makes up 60% of mobile data traffic. Moreover, they forecast that three-quarters of the world's mobile data traffic will be video by 2021. Ericsson's own study states that mobile video traffic represents 55% of LTE/5G data traffic now, but is expected to grow to 95% (yes- 95%) of mobile data traffic by 2021.

Cisco states further that 50 billion IOT devices will be connected to the internet within 5 years. However, only 1.5 billion of these devices will have cellular connectivity. We have seen forecasts from other sources that IOT mobile data use will grow to 8% of total network mobile data use by 2021. In other words, IOT functionality only drives less than 10% of the bandwidth need for small cell densification.

This raises the question: how many small cells are necessary to enable Smart City and IOT initiatives versus how many are really needed to densify networks for the next generation of fixed wireless to home and mobile video?  For further information on why mobile and fixed wireless video is so important to AT&T and Verizon, see this article on the wireless industries efforts to compete with the cable companies.

To be clear, we aren't suggesting that mobile video or fixed wireless are inconsequential. Without the revenue generated from mobile and fixed wireless video, the wireless industry would not have the incentive to invest as much Capex in their wireless networks to enable some of the truly amazing IOT and smart city use cases – especially those that require low latency or secure and ultra-reliable communication.

We are, though, suggesting that any indication by the wireless industry that 5G and small cell densification is primarily about IOT and smart city functions is a half-truth at best. The reality is that small cells densification is more about paid consumer and commercial video than it is about IOT or smart cities.

 

#10.  The industry is willing to push select information about small cells but not willing to respond to substantive questions from municipalities.

Before a recent meeting began between one city and 20+ representatives of wireless and tower companies, each side exchanged questions. The wireless industry provided 30-40 questions to the city, and the city provided a list of 15-20 questions to the industry. The city's questions were fairly straightforward:

What do the wireless providers see in terms of other cities that require rental payments?

How many small cells does the industry contemplate installing in the city over the next 5 years?

What type of infrastructure/antennas does the wireless industry expect to need on the poles?

The city responded to all the industry's questions with substantive detail. In return, only ONE company responded to the city's questions. And most of those responses were cop-outs – claims that they couldn't answer due to competitive concerns. CTIA/WIA provided a glossy presentation that discussed all of the overarching benefits of IOT and 5G, but failed, for the most part, to provide any substantive and direct answers to the questions posed by the city itself.

At the end of the day, the wireless industry wanted to poke holes in the city's effort, but was unwilling to answer important questions that would have helped the city review and revise its own policy.

How can any city reasonably be expected to plan and prepare adequately for small cell infrastructure when the wireless industry continues to provide limited substantive information?

So Where Does this Leave Us?

Municipalities need to realize that wireless investment in small cells should be encouraged and reasonably managed and that doing so requires investment in staff and resources. They can no longer put their heads in the sand because it isn't a question of if, but of when and of how many small cells are coming. Reactionary policies and moratoriums almost always rushed and neither encourage thoughtful technological expansion nor protect the constituents.

Wireless carriers, tower companies, and industry associations need to provide better substantive guidance to their member constituents including model applications and construction/design criteria. They should truly encourage shared infrastructure use especially in dense areas where multiple providers want access to existing poles. These groups and companies should also be more forthright in their marketing materials and in answering legitimate questions and concerns by public entities.

We, as advisors to landowners and municipalities, will continue to help educate the public about the small cell leases and policies. Most landowners and municipalities are underrepresented and ill-informed when it comes to responding to the wireless industry's requests and/or demands. We hope that by highlighting the top 10 things the industry doesn't tell you about small cells, that you can better decide how to accomplish your goals. That small cell deployment will not be allowed to grow unchecked and unabated by an uninformed populace.

 

Comcast Wireless 2.0: This time it could actually work.

Image of cell phone with video playing
Mobile Video by Comcast
Implications for TowerCos and Construction Companies

Tickers: CMCSA, COMM, MTZ, DY, CCI, AMT, SBAC

Tags: Ken Schmidt, Wireless infrastructure

Background:

Analysts have been speculating about the winners of the FCC spectrum auction and the implications of those wins for the better part of a year. With the auction coming to a close and an announcement expected in the coming weeks, we took a look at the implications of Comcast’s (Nasdaq: CMCSA) expected entry into the wireless market.

On 4/6/2017, Comcast announced their Xfinity Wireless plans.  Much has been written on the details of those plans so we will not rehash them here other than to say that Comcast doesn't appear to be building its own network and that the plans are primarily intended to prevent Comcast customers from churning to AT&T or Verizon.   

Timing:

The FCC’s broadcast incentive auction was finalized on March 30, 2017. The FCC is expected to publicly announce the winning bidders sometime in the latter half of April. 

Expectations:

We expect that Comcast bid on and will win spectrum in the auction. CMCSA’s Q3 2016 cash flow statement, which was released publicly on Oct. 26, 2016, includes a $1.8B line item listed as a “deposit”; presumably an auction deposit by CMCSA to the FCC. Some analysts have suggested that CMCSA plans to acquire 30MHz of spectrum on a nationwide basis.  We believe that the more likely scenario is that CMCSA will win at least 10MHz of 600MHz spectrum in areas where CMCSA already has fiber/coax infrastructure, as shown on the map below.   Alternatively, if CMCSA does win nationwide licenses, we believe they will focus any buildout of equipment in just their current markets they serve now, at least until a compelling business case is developed otherwise.   

Map showing the areas of the US where Comcast provides Cable and Broadband Services
Comcast Availability Map
Source: www.cabletv.com/xfinity/availability-map

CMCSA’s Likely Strategy:

If we are correct and CMCSA wins spectrum in existing service areas, Comcast will use this spectrum to provide both mobile and fixed wireless services primarily to augment their cable services and reduce churn from wireless service providers’ forays into OTT video.  We see their plans as an extension of the recently announced Xfinity Wireless strategy.

Buildout Details

We anticipate that CMCSA will utilize a combination of WIFI and unlicensed spectrum to provide indoor and outdoor coverage and capacity, while using 600 MHz licensed spectrum for wide area coverage.   This will enable CMCSA to reduce payments to Verizon under their MVNO relationship and allow them to provide mobile video to customers without incurring per GB charges from Verizon which are reputed to be in the range of $7/GB. 

Competitive Dynamics

CMCSA’s product won’t attempt to compete with either Verizon or AT&T in terms of breadth of coverage. However, its product will be attractive to existing CMCSA cable subscribers who aren’t highly mobile and who don't require 20GB or more of data.  CMCSA's Xfinity Wireless is set at a competitive price point, particularly to existing customers via a “quad” package.

Marginal Positives for Infrastructure Players

Companies like COMM, MTZ, and DY should benefit marginally from increased need for CMCSA fiber and coax to the premise to accommodate additional bandwidth (inside and outside the premise). However, near-term expectations should be tempered as broadcasters have up to 39 months to relinquish the spectrum.

Implications for the TowerCos

The impact on TowerCos should be muted for two reasons.  First, broadcasters have up to 39 months to “repack” and return the spectrum to the winning bidders, so any tower lease revenue from CMCSA won’t materialize immediately. Secondly, we suspect CMCSA will attempt to control OPEX going forward by limiting the number of collocations on public tower company towers and by emphasizing small cells especially those that are attached on-strand to Comcast's existing fiber and coaxial cable runs in public right of ways.   Ironically, if the Wireless Industry Association is successful in pushing the FCC to override local zoning oversight and fee structures for small cells, they could be enabling competitors to their own constituent wireless carrier and TowerCo members. Nevertheless, there could be a small bump to TowerCos once the FCC announces the auction winners and the winners include entities that don’t currently lease tower space. The possibility of another potential customer could increase investor interest in TowerCos.

Risks and Unknowns:

The risks to this note include:

  1. CMCSA could be outbid / fail to acquire spectrum
  2. CMCSA could be acquired by or merge with an entity that owns spectrum already, and therefore would not need to acquire spectrum or build it out
  3. CMCSA’s near-term WiFi-First/MVNO-second wireless strategy could prove to be unsuccessful and/or discontinued, causing CMCSA to divest this spectrum prior to it being made available from the broadcasters.

Important Disclosures

This report is for informational purposes only and should not be construed as investment advice. It is not a recommendation of, or an offer to sell or solicitation of an offer to buy, any particular security, instrument or investment product. Our research for this report is based on current information obtained from public sources that we consider reliable, but we do not represent that the research or the report is accurate or complete, and it should not be relied on as such. Opinions and estimates expressed herein constitute judgments as of the date appearing on the report and are subject to change without notice.  Any reproduction or other distribution of this material in whole or in part without the prior written consent of Steel in the Air, Inc. is prohibited.  Any projections, forecasts, and estimates contained in this report are necessarily speculative in nature and are based upon certain assumptions. No representations or warranties are made as to the accuracy of such forward-looking statements. It can be expected that some or all of such forward-looking assumptions will not materialize or will vary significantly from actual results.  Steel in the Air, Inc. accepts no responsibility for any loss or damage suffered by any person or entity as a result of any such person or entity's reliance on the information presented. 

Verizon Appears to be Rivada Partner in FirstNet Bid

Capture

In examining the summary of the FirstNet/Rivada litigation as prepared by RCR Wireless, there may be confirmation that Verizon was the silent "carrier" partner of Rivada.  Specifically, in the recently made public documents, the court indicated "the first set of deficiencies related to ‘Rivada’s lack of financial stability, capacity, and required funding'” — including the riskiness of Rivada Mercury’s proposal to monetize the excess Band 14 spectrum through a wholesale marketplace, which required robust Band 4 device support in order to be adopted by non-FirstNet customers".   Band 4 consists of the AWS-1 frequencies acquired from SpectrumCo (cable company consortium) by Verizon in 2011.   In other words, Rivada intended to monetize the FirstNet spectrum by adding it to Band 4 (AWS-1) capable phones.   

While many people have suspected that Verizon was working with Rivada, we haven't seen any other evidence of it.  Of course, it is possible that another wireless carrier with AWS-1 (T-Mobile) could have been the partner, but we strongly doubt their participation given the substantial cost of building out a nationwide network to meet the coverage objectives of FirstNet.   Alternatively, perhaps Rivada was hoping for Verizon's participation- but based upon rumors we had heard previously, the discussions were farther along than that.