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CTIA Statement in Response to FCC Enforcement Bureau Field Office Closures

After the FCC Enforcement Bureau field office closures, I said:

“Spectrum management and protection against interference have been core FCC roles since its creation in 1934. Today, these roles are more important than ever. Consumers value wireless services and carriers invest based on an expectation of no harmful interference. The Field Offices play a vital role in fulfilling these expectations by protecting carriers and consumers from interference when efforts by licensees prove unsuccessful. We appreciate the FCC’s commitment to work with CTIA and other stakeholders in the coming weeks to develop a concrete mechanism for escalating interference complaints that includes specific performance metrics and definitive timelines for escalation to ensure wireless interference complaints are addressed in a timely manner. It is important for all of us to work together to deliver on Chairman Wheeler’s promise to not only maintain effective enforcement but improve it.”


Mobile Wireless Competition: The Proof is in the Numbers

This week, the record in the FCC’s Mobile Wireless Competition Report proceeding officially closes and it is an opportune time to take stock of a wireless marketplace that produces services and devices so compelling that 89% of Americans use them multiple times every dayPDF. After reviewing the initial round of comments, the facts speak for themselves: rapid increases in adoption and usage, coupled with countless industry innovations and investments, reveal a competitive market that delivers unparalleled benefits to consumers.

As of December 2014, there were approximately 355.4 million wireless connections nationwide. That’s an increase of nearly 20 million over the end of 2013 and nearly 30 million over the end of 2012. Not only that, but according to government data from the last half of 2014, more than half of U.S. households have a wireless – but not a wireline – telephone. Along with this surge in wireless adoption has come an increase in use of data-enabled devices: from the end of 2013 to the end of last year, data-only devices were up one-third and active wireless-enabled tablets and laptops increased more than 40 percent. It’s no surprise, then, that the demand for mobile data has skyrocketed, with reported mobile data traffic in 2014 up more than 25 percent from the end of 2013 to the end of 2014, and reported numbers showing that mobile data traffic in 2014 was 30 times the size of the entire global Internet in 2000. And there is no sign that these adoption and usage numbers are going anywhere but up.  Indeed, as Chairman Tom Wheeler recently noted, “[t]he opportunities being created by the wireless revolution are massive and will only continue to grow.”

Yet despite these numerous and compelling data points, the Commission in its last four reports on the state of mobile wireless competition has declined to determine whether or not the wireless marketplace is effectively competitive. The Commission pointed to two factors in the Seventeenth Competition ReportPDF as to why it could not find that the wireless industry is competitive: the “complexity of the various inter-related segments and services within the mobile wireless ecosystem” and the fact that there is “no definition of ‘effective competition’ widely accepted by economists or competition policy authorities such as the U.S. Department of Justice (DOJ).” Let’s dig deeper into this.

This Commission is right: the wireless market is complex and brimming with new consumer options.  Wireless carriers today are competing vigorously on a wide array of fronts. As Sprint pointed out, wireless carriers are increasingly expanding and upgrading their networks and providing high-quality service plans and equipment at a variety of consumer-friendly price points. Competition and price wars continue, as reflected in the Consumer Price Index for Wireless Service, which fell 13 percent in the period between May 2010 and May 2015 while the consumer price index for all items rose 9 percent in the same period. Competition is not only driving down prices, but, as AT&T reported, it’s also incentivizing carriers to customize plans to meet consumers’ individualized needs. Innovative and competitive pricing plans and service options like data sharing and roll-over and equipment installment plans are, as Mobile Future explained, “just the latest evidence of fierce competition among service providers.”

Wireless Price Index vs. Consumer Price Index

Wireless providers are also competing through network upgrades that improve consumers’ overall wireless experience. In 2014 alone, wireless carriers invested more than $32 billion in their networks, including by aggressively deploying LTE. Today, 98 percent of Americans have access to 4G LTE networks and there are 158 million LTE connections for the country’s population of 318 million. As PCIA stated, this enormous investment in wireless infrastructure has resulted in a number of pro-competitive benefits – including increased speeds and capacity to meet growing consumer demand and the expansion of the Internet of Things – and has made wireless broadband a competitor to (and, for some consumers, a substitute for) wireline broadband.

Not only that, but new consumer options are emerging in this market every day, including MVNOs and hybrid Wi-Fi/cellular networks, as well as over-the-top VoIP, messaging, and video applications. Verizon thus rightly noted that, in this dynamic space, consumers are reaping the ultimate benefits in the form of faster networks and greater choices among carriers and services. So, despite claims to the contrary, this diverse and complex ecosystem is exactly why the wireless marketplace should be found to be competitive.

The Commission cannot ignore the competitive nature of the wireless landscape simply by claiming it doesn’t know what “competition” means. At the very least, the Commission should take a cue from its own book and look at the factors recently usedPDF to find effective competition across the MVPD market – whether consumers have access to at least two unaffiliated providers serving at least 50 percent of households, and whether the number of subscribers in the area exceeds 15 percent. As the Free State Foundation correctly observed, applying the approach taken in the recent MVPD Effective Competition Order would offer “a consistent, objective basis for evaluating the market and thereby ensuring that its regulatory policy matches actual market conditions.”

Using this test, the Commission deemed the presence of just two nationwide DBS providers sufficient to presumptively find effective competition for every local MVPD market area. Compare that to the wireless market, where (as of January 2014), more than 99 percent of all Americans can choose from two or more mobile voice providers. Indeed, mobile customers in the U.S. benefit from the broad network coverage of four national providers as well as important regional operators, and the number of customers with four or more wireless choices (more than 91 percent of Americans) greatly eclipses the video experience today.

Comparing Effective Competitivge Choices

This comparison makes clear that competition in the wireless industry meets or exceeds the test set out for the MVPD market. Application of a test for wireless competition that is similar to the one used to assess the MVPD marketplace thus demonstrates the vigorous competition that characterizes the wireless ecosystem today.


With the Eighteenth Competition Report, the Commission has a prime opportunity to affirmatively recognize the truly competitive mobile wireless ecosystem and the consumer benefits that it produces. If the FCC can conclude that the MVPD market is presumptively competitive, there is no reason for it not to find the same for mobile wireless and balance the regulatory burdens it imposes on the industry accordingly. While we hope the Commission affirmatively recognizes the competitive nature of the wireless industry, it won’t change the fact that consumers do. They see the benefits, and we know that the investments and innovations we’re seeing today would not have occurred absent intense competition in the marketplace.

CTIA Statement in Response to Senator Blumenthal and Commissioner Rosenworcel Press Conference on Robocalls

After U.S. Senator Richard Blumenthal and Federal Communication Commissioner Jessica Rosenworcel held their press conference about robocalls today, I said:

“We appreciate Senator Blumenthal’s and Commissioner Rosenworcel’s focus on robocalls. No one wants robocalls, and the attention to stop them needs to focus on those bad actors who are willfully and blatantly ignoring the laws. As technology continues to evolve, these illegitimate users are updating their offerings to circumvent laws and blocking solutions. Instead of creating a ‘one-size-fits-all’ approach that would not slow bad actors down, it’s vital that communications providers have the flexibility to create new technologies and options to help consumers stop unwanted communications. It’s also important that consumers control who they want to hear from since what could be viewed as a nuisance call by one person would be a welcomed communication by another. That’s why CTIA and its members – individually and collectively – developed a variety of tools, many for free, so that consumers can stop these robocalls and unwanted communications from ‘blacklisting’ phone numbers to downloading apps. We provide a list divided by operating systems on our website, and we encourage consumers to take advantage of them today.”


CTIA Statement After the Senate Passed the Integrated Public Alert Warning System Modernization Act

After the United States Senate approved S. 1180, the Integrated Public Alert Warning System Modernization Act, I said:

“CTIA congratulates Senators Johnson and McCaskill on the Senate passage of the Integrated Public Alert Warning System Modernization Act. The bill’s unanimous approval is a testament to their thoughtful, bipartisan approach. CTIA greatly ...

Wireless Industry Delivers on Smartphone Anti-Theft Voluntary Commitment

Today, CTIA-The Wireless Association® announced the wireless industry’s fulfillment of the Smartphone Anti-Theft Voluntary Commitment that gives U.S. consumers – at no cost – new protections in the event their smartphones are lost or stolen. Included are capabilities to remotely lock and wipe missing devices while still enabling 9-1-1 ...

America is the Global Mobile Leader

Here’s how much mobile Americans used in 2014, according to CTIA annual survey. Some of the highlights include:

36 million more devices than people; 243.5 million smartphones and tablets accounting for 68% of all devices on mobile networks; and 4.1 trillion MB of data.

To meet these demands, wireless ...

CTIA Statement on Wireless Innovation Act (S. 1618)

After the introduction of the Wireless Innovation Act (S. 1618), I said:

“With this legislation, Senators Rubio, Wicker, Ayotte, Gardner and Johnson make clear their commitment to continued innovation and American leadership in mobile broadband. By creating a spectrum pipeline and encouraging more transparency and efficiency among federal spectrum users, this ...

CTIA Statement on the FCC June Open Meeting

After the FCC June Open Meeting, I said:

“CTIA appreciates the Commission’s leadership in continuing to modernize and strengthen the federal Lifeline program. Wireless is a critical tool that enables Lifeline to support the public safety, health care, educational, occupational and other important communications for millions of ...

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