Fun From San Diego: I Take A Pass At CTIA’s Discussion Questions
Fun From San Diego: I Take A Pass At CTIA’s Discussion Questions
Fun From San Diego: I Take A Pass At CTIA’s Discussion Questions

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    Gigi is out in San Diego today making a whirlwind appearance on spectrum. In addition to stopping by the FCC's workshop on mobile broadband and mobile applications (and delivering this amazing testimony here), Gigi is stopping by the International CTIA Wireless Conference to do a panel. As is often the case with these panels, they had some discussion questions to focus the group on the key issues and guide the conversation. While I expect Gigi will blog later about what actually happened, the discussion questions I saw looked pretty good to me. So I thought “hey, why not give my answers and show everyone why CTIA never invites me to speak at their conferences.”

    So here goes. CTIA Questions in italics.

    To kick things off, what are the biggest benefits wireless consumers stand to receive in the next two years and what is your organization doing to see that these gains are realized? What are the biggest threats to achieving these benefits?

    Elimination of handset exclusivity and early termination fees and the freedom to use whatever apps they want and access any content they want. We’re fighting for this at the FCC.

    It seems that annually there is some commotion in Washington over the OECD’s estimates on broadband. Again this year, the OECD’s broadband rankings neglected to include wireless broadband. Moreover, their assessment of the U.S. wireless industry (based on what CTIA deemed a flawed methodology) found us to be the most expensive market. In light of FCC data showing the incredible rate of wireless broadband adoption and Merrill Lynch / Bank of America data showing the high usage in the U.S., are the OECD’s rankings an accurate measure of U.S. wireless broadband?

    The problem is that in the US we use the term “broadband” to mean a lot of different things. I don’t know how many 11 year olds are doing their homework on mobile phones, for example, the way my son does with our FIOS subscription. Certainly people are using mobile devices for a lot of very cool, sophisticated things – such as avoiding SWAT teams at the G-20 summit with Twitter. So the OECD ranking is very relevant for telling us about a particular – and particularly important — service that has many uses that overlap with mobile, but that mobile simply does not replace (at least for now).

    As carriers continue to roll out 3G technologies and several carriers are migrating to 4G. 4G technologies plan to bring an “all-IP” network to the wireless world. How will the existing regulatory structure impact the ability of wireless providers in an all-IP world?

    There is no doubt we need to adjust the regulatory structure. As data replaces voice, we need to bring the rules that made wireless voice possible to data. Wireless voice could not become a viable service until Congress passed Section 332 which made mobile voice a telecommunications service with interconnection rights and required in exchange that carriers not mess with traffic. When everything is data, and voice is only an application, we need the same rules for data that we needed for voice. By the same token, we also need to mandate data roaming in the same way we mandated voice roaming – or else eliminate mandatory voice roaming. But we can’t pretend that these are different worlds subject to different rules when the network treats them as the same thing and where users expect to use all these services equally.

    CTIA has suggested that the Commission reallocate 800 MHz of spectrum for wireless broadband providers by 2015. In the short-term, how can the Commission ensure that wireless providers have the spectrum to provide the broadband service consumers demand?

    There is not enough spectrum. Period. Get over it. Or tell me how you are going to get around the military, the FAA, the FBI, etc. We need to find other ways than just more of the same. We have reached peak spectrum.

    It is time to do the spectrum equivalent of conservation and “green/renewable/reusable” spectrum. That means moving away from the “I got my license it's my property and everyone back off” and moving to a more rational approach. We start with better roaming (which is basically just a fun way of saying spectrum reuse by the non-licensee under a set of standards), then we move on to things like receiver standards and minimum standards for system robustness in neighboring bands. Yes, you heard me neighboring bands. Because we have a real problem right now that the first service in the neighborhood can be as crappy as it wants and thus impede uses by any neighboring services because you have to protect the first crappy use. While we need to provide adequate stability for investment, the fact is that we are all in this together, we need to protect locally to advance globally, and all other bad metaphors and cliches that show that we need to give up on the idea that we can keep expanding spectrum use forever under the existing model of carving up bands into exclusive little license slices.

    That doesn't mean eliminate licensing or exclusive licenses. But it does mean that “expand capacity” can no longer be equivalent to “find more spectrum.”

    The mobile wireless market has evolved significantly in the 18 months, changing from carrier-focused to a true ecosystem of players competing at every level of the industry. How does this new focus by consumers on applications and operating systems change the way you look at competition and innovation? How will the Chairman’s Net Neutrality proposal impact this area?

    This has come about in no small part from the push from C Block and the threat of NN. Yes, I know wireless operators and believers in the perfection of the free market are all programmed to say “no it didn’t” and act like Verizon announcing its openness initiative right before the 700 MHz auction when it was trying to keep Google out of the bidding was coincidence, or that this past week’s announcements by VZ and AT&T have nothing to do with the Chairman’s speech last week.

    But even if we play along with this joke and pretend that’s true, consider this – the wireless industry WAS TOTALLY WRONG ABOUT IT’S NEED TO MAINTAIN CONTROL. Before Tim Wu’s 2007 “wireless Carterfone” paper two years ago, you were all claiming that anything like the current market was impossible, that phones that also used wifi would destroy your networks, that allowing developers to offer lots of new aps and connect to other devices and networks would bring a plague of spam and viruses on users, etc. But in 18 months, with the assistance of a few regulatory nudges like C Block, you have all gone from “impossible” to “inevitable” to “good for us and a great way to make more money.”

    Similarly, net neutrality will be good for you. It pushes you out of your comfort zone and makes you work for a living – to your benefit as well as the consumer’s.

    The Chairman of the FCC has described the framework for Net Neutrality he intends to offer later this month as a Notice of Proposed Rulemaking. What impact will the rules have on wireless broadband?

    As Genachowski said in his opening speech at CTIA, the rules will take the real differences in technology into account when implementing. But as the Comcast/BitTorrent Order proved, you can generally do things in a neutral way and still address all the issues you claim to need a non-neutral network to address. Comcast swore up and down (once it admitted to throttling) that it absolutely needed to throttle or a handful of bandwidth hogs would bring down their entire system. Then it turned out they could “voluntarily” abandon throttling for an “application neutral” approach. When last I checked, contrary to the dire predictions at the beginning of the Comcast/BitTorrent complant proceeding, Comcast is still doing a nice business as a broadband provider.

    What are the top three trends in the mobile industry and marketplace that you believe will have the greatest impact on wireless networks in the future?

    A. Vertical integration. The wireless world is now AT&T and Verizon v. Everyone Else. That’s a huge challenge for the industry and for CTIA. This split will only get worse as AT&T & VZ build out their 700 MHz networks and dominate the LTE equipment market. It will get even more worse if Congress gives the D Block to public safety and they team up with Verizon and AT&T.

    B. The new spoilers: cable and Google. Cox is already deploying a wireless network in its territory to beat back competition from AT&T. Cablevision, after getting shut out of the AWS and 700 MHz auctions, launched its wifi network to compete with Verizon’s integrating wireless and FIOS. Expect this trend to continue as Comcast and Time Warner figure out what to do with all that spectrum they bought in the AWS auction. As for Google, it is getting into your operating system and it will change you. How is not clear at this time, but Google’s model is so fundamentally different from anything in the wireless world that it will shift user behavior in unaccustomed ways.

    C. International. People want to take their phones with them on travel. They want them to work predictably and not cost ridiculous amounts of money. And they want to do all the cool things with their phones that they see in Europe and Asia here.