AT&T does not maintain in the ordinary course of business a nationwide list of all CMAs where its individual network is underutilized. With regard to the areas where AT&T's and T-Mobile USA's networks may be underutilized relative to each other, AT&T does not have this information on a CMA by CMA basis, nor does AT&T have engineering data that would provide this granular information for T-Mobile USA.
AT&T is providing Exhibits that contain information responsive to this request, consistent with its discussions with the Commission's staff. The .csv file in Exhibit 19-1 contains current (as of March 11, 2011) data usage for each UMTS site (by USID) measured in kilobytes, during the monthly busy hour, and separately for the uplink and the downlink. The .csv file in Exhibit 19-2 contains current (as of March 11, 2011) data usage for each GSM site, measured in Erlangs, combined for the uplink and downlink, for the monthly busy hour. At the Commission's request, AT&T also provides an estimate of GSM data usage in terms of Kilobytes, using a formula that converts Erlangs to Kilobytes. Both exhibits identify the CMA associated with each site.
AT&T will not be in a position to make any final determinations about possible changes in T-Mobile USA until it is able to obtain more detailed information about the operations of the company, which will occur later in the acquisition process. In addition, any preliminary plans are subject to the outcome of the regulatory process. AT&T has not yet begun detailed integration planning efforts.
AT&T has not yet begun detailed integration planning efforts relating to its marketing or advertising efforts or other operations.
AT&T has not yet begun detailed integration planning and its knowledge of T-Mobile USA's operations is necessarily limited at this early stage. The actual process of determining which specific T-Mobile USA sites to integrate and which to decommission will require substantially more data from T-Mobile USA regarding its network as well as a more thorough engineering analysis of each area's characteristics and capacity needs, which could change by the time the Transaction closes. Consequently, AT&T has not yet determined the exact number or location of T-Mobile USA towers or other locations used for transmission of signals that will be integrated into the combined company's network to increase network density.
AT&T does not maintain a central repository of plans, analyses and reports concerning local or regional advertisements. As explained by David Christopher, Chief Marketing Officer of AT&T's Mobility and Consumer Markets, in his Declaration and Reply Declaration filed with the FCC, AT&T has given its 27 vice-presidents/general managers ("VP/GM") authority to respond to local competition by varying and supplementing national advertising to respond to local market conditions, and VP/GMs may develop customized marketing plans for use in particular cities or areas within their respective territories. Such local advertising plans, therefore, may not always be reduced to writing, and even when such records are created, they may not have been maintained for the periods covered by this request.
Prior to the merger, AT&T's plan was to deploy LTE to 80 percent of the U.S. population by the end of2013. However, because of the scale, spectrum, and other resources resulting from the transaction, AT&T is now able to commit to expand LTE to 97 percent of the U.S. population.
Going from covering 80 to over 97 percent of the population will require AT&T to almost triple the land mass covered by its LTE network, from below 20 percent of the United States to approximately 55 percent. Additionally, it costs nearly twice as much per covered person in capital expenditures to provide mobile wireless services to sparsely populated areas than to densely populated areas. AT&T estimates that this expansion would cost approximately [Begin Confidential Information] [End Confidential Information] in additional capital expenditures...
In addition to the LTE goal, our proposed merger will:
· Increase cell density and effectively double the amount of network traffic that can be carried using existing spectrum in the areas served by those cell sites.
· Gain the equivalent of 8 years of new site build based on 2010 build rates
· Improve voice and data network performance in areas of various markets in as little as nine months.
quote: AT&T is forcing the FCC and DOJ to do the heavy lifting here, combing through a virtual public-library worth of pages. It's hard to escape the perception that AT&T just searched through their corporate database and dumped a bunch of documents on the FCC and DOJ, hoping to overwhelm its way to approval.