Federal Communications Commission fcc 08-28 Before the Federal Communications Commission Washington, D


Wireless Local Area Networks and Wireless-Wireline Convergence



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Wireless Local Area Networks and Wireless-Wireline Convergence


  1. Wireless local area networks (“WLANs”) are playing an increasingly important role as a competitor and supplement to the services offered by the CMRS industry.656 WLANs are widely deployed and enable consumers to obtain high-speed wireless Internet connections within a range of 150 to 250 feet from a wireless access point. The most prevalent WLAN technology is equipment manufactured in accordance with the IEEE 802.11 family of standards, commonly known as “Wi-Fi,” short for wireless fidelity. Basic WLAN data transfer rates range from speeds of up to 11 Mbps for 802.11b and up to 54 Mbps for 802.11a and 802.11g.

  2. WLAN users can access high-speed Internet connections at so-called “hot spots,” including locations such as restaurants, coffee shops, hotels, airports, convention centers, and city parks.657 Estimates of the number of public Wi-Fi hot spots in the United States vary considerably, ranging from just under 14,000 to over 63,000.658 In addition to public hot spots, WLANs are also proliferating in homes and businesses.659 One company, Skyhook Wireless (“Skyhook”), is using Wi-Fi access points, as an alternative to GPS systems, to determine the location of end users and develop various location-based services.660 Skyhook’s Wi-Fi Positioning System (“WPS”) platform tracks the existence of Wi-Fi access points and can be used to identify, within 20 meters, the location of any Wi-Fi enabled device.661

Map 4: Skyhook US Coverage662



  1. Several mobile telephone providers have entered the hot spot operation business through acquisitions, partnerships, or independent deployments.663 For instance, T-Mobile offers Wi-Fi access at nearly 8,500 HotSpot-branded locations in the United States, while Sprint Nextel’s Wi-Fi network includes more than 8,000 hot spot locations across North America.664 AT&T offers Wi-Fi connectivity at almost 15,000 hot spot locations in the United States as well.665

  2. To augment their wide-area data service offerings, mobile telephone providers have typically offered WLAN services for high-speed, in-building data access.666 Certain providers – including T-Mobile, Sprint Nextel, and AT&T – offer at least one dual-mode handset that operates on both cellular and Wi-Fi networks. For example, T-Mobile’s Dash™ and Wing™ devices can connect to the company’s GPRS/EDGE network and are also Wi-Fi-enabled for high-speed data access.667 Sprint Nextel’s Mogul™ device, introduced in June 2007, offers access to both Sprint Nextel’s EV-DO network and Wi-Fi access points.668

  3. The iPhone launched by Apple and AT&T in June 2007 runs on AT&T’s EDGE network and can connect to any Wi-Fi hot spot for Internet access service. The iPhone can seamlessly switch from an EDGE to a Wi-Fi connection, and will automatically display a list of new Wi-Fi networks in range as the user moves to a new location.669 By allowing users to access the Internet and other data capabilities at significantly higher speeds in hot spot locations, the iPhone’s Wi-Fi capability partly compensates for the slower speeds of the EDGE network and the device’s lack of connection to AT&T’s higher-speed WCDMA/HSDPA wireless broadband network.670 In September 2007, AT&T also began offering the Wi-Fi-configured BlackBerry® 8820.671 Like the iPhone, the device provides users with data access over AT&T’s EDGE and Wi-Fi networks, automatically defaulting to a Wi-Fi signal when available.672 Though currently sold by AT&T with Wi-Fi data service only, the device is also capable of Wi-Fi voice functionality.673

  4. In addition to using Wi-Fi as a means of data access, over the past year certain mobile operators have begun to use WLANs to augment their CMRS-based voice services with voice connections at Wi-Fi hot spots. For example, in June 2007, T-Mobile and Cincinnati Bell introduced new services – “HotSpot@Home” and “Home Run,” respectively – featuring dual-mode handsets that offer seamless voice connections on both Wi-Fi and the operators’ GSM cellular networks.674 Both services provide subscribers with improved, in-building coverage, as well as unlimited calling through a specified home or office Wi-Fi router and at all carrier-branded hot spot locations.675 With this feature, customers can avoid using the GSM voice minutes included in their monthly service plans when making voice-over-Wi-Fi calls while at home or in certain hot spot locations.676 Unlicensed Mobile Access (UMA) technology enables the seamless mobility afforded by these services, in which calls are automatically switched or handed off from a Wi-Fi to a cellular network, or vice versa, without interruption as a subscriber moves from one location to another.677

  5. In September 2007, Sprint Nextel launched a service similar to T-Mobile’s @Home service, called Airave, which allows subscribers to make unlimited wireless calls from their homes without deducting minutes from their monthly service plans.678 However, instead of connecting calls through a home Wi-Fi router, Airave relies on a femtocell device.679 A femtocell is a miniature base station that transmits in the licensed spectrum of the wireless operator offering the device and provides improved coverage within a subscriber’s home. It uses the subscriber’s home broadband connection for backhaul. As of October 2007, Sprint Nextel’s Airave service was available in Indianapolis and Denver.680


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