The three main points Mr. Stephenson is making (which I agree with) are:
1. "Require spectrum holders to put the airwaves to work."
Mr. Stephenson goes on to explain that many of the spectrum owners are investment entities that never intend to actually build a network and suggests that timed build-out requirements are attached to all licenses.
I think this is a great idea and the FCC should definitely look into this. If I could add anything it would be that the FCC should also add coverage requirements to the structure suggested by Mr. Stephenson. The reason is that it would be quite easy to evade the license build-out requirement by activating one single base station before the time limit unless there was a coverage requirement.
I'm glad that AT&T is proposing increased and more transparent regulation when it comes to spectrum allocation. As I have advocated in the past, focusing blindly on spectrum auction revenue is detrimental to competition as well as efficient spectrum allocation.
2. "Quickly get spectrum where consumers need it most."
AT&T is saying that there are a lot of potential sellers of spectrum out there but that the review of those potential deals take too long. I agree that it should not take a year to complete a deal because of regulatory review. On the other hand, I think this process could be sped up a lot by introducing a transparent spectrum-cap policy. This way it will be easier to review each deal to see if it is allowed from a competitive standpoint. No detailed reviews are necessary if a policy is in place. The competitive part of the review could be as easy as making sure that they buyer does not own more than X amount of spectrum in any given market.
3. "Establish a national model for the local approval process that's required when wireless carriers need to build new mobile infrastructure."
Increased federal regulation on this point (as Mr. Stephenson is suggesting) would quickly improve the way networks are built. However, this will have to be a give and take between the wireless industry and the states and local communities. The carriers would have to agree to make some accommodations when it comes to design and placements of towers, especially tall macro cells, while being able to get much more leeway on sites placed on existing structures like buildings.
To sum up, I think it is great that AT&T now takes a proactive view on regulation. It may of course have something to do with their current lack of unused spectrum compared to their holdings in the past.