May 17, 2012 3:23 PM
As punishment for requesting their freedom, the Egyptian Pharaoh told the Israelite slaves that they had to maintain their quota of bricks, but with less of an essential input: straw
. The burden of meeting demand with less resources applies as well in today's mobile services marketplace. Wireless carriers face demands for greater bandwidth to support growing mobile data services but, for the intermediate term, cannot expect additional spectrum capacity--it's essential input--on either a firm-specific or industry-wide basis.
It's unanimous: no matter who you talk to about wireless data, everyone
agrees that "more bricks, less straw" is the unavoidable policy. Thus, as wireless data demand continues to show no sign of abating, wireless service providers will simply have to make do with less than optimal spectrum capacity. So if we're stuck in a "more bandwidth demand, less capacity supply" world, how do we solve the problem of how to ration capacity? Who Needs Spectrum When You Can Upgrade Your Capacity?
So what's a wireless operator to do? Well, for starters, you upgrade existing capacity like crazy by constantly deploying the most efficient technology. But this isn't cheap. Since wireless data exploded in 2007 with the iPhone, AT&T alone has gone through a 3G upgrade, an HSPA upgrade, an HSPA+ upgrade, and, more recently, is in the midst of an upgrade to LTE.
Other companies have accelerated their own pace of upgrades as well. From December '06 (right before the iPhone launch) through December '11 (when most firms still have a long way to go to realize full LTE deployment) industry capex has increased by almost 50%, according to CTIA (the actual numbers are in a report that I can't afford, so take my word for it). But, even these improvements won't keep up with surging demand.With No Spectrum Relief In Sight, Do You Play The Price Card?
Given the limited options for rationing capacity another, though unpopular, move is to raise prices. Over the last several months we've seen AT&T raise data prices
, after realizing that the government was not--anytime soon--going to allow AT&T to efficiently augment its own capacity. Verizon quickly followed suit
. For now, Sprint appears to be content to let its shareholders shoulder the costs
of increased wireless data demand. But to be sure, increased demand without increased supply does create network strain--regardless of who pays.
Last week, at the CTIA Conference, Chairman Genachowski maintained/reasoned/disputed
that the failure of the AT&T and T-Mobile merger last year had anything to do with AT&T's decision to raise prices. Yet, the Chairman knows better, as he has been a leading prophet of the spectrum shortage. How to Recover Costs of Spectrum-less Capacity Expansion?
Given the costs of constantly upgrading capacity, how does a carrier manage excess data demand? As I indicated above, raising prices sounds like a simple solution, but must account for the fact that big data users are contract customers. That's how smartphones, and data plans become affordable, and predictable.
You see, the problem with raising prices for wireless data is that you can really only raise prices to the marginal
., the person who's not your customer
yet). Crazy, right? "Raising prices" is a statement of frustration and designed to curb consumption. Carriers are telling prospective customers that the network is nearing capacity and use of the remaining capacity will cost you. This is a horrible situation--who wants to be the (unpopular Redskins owner) Dan Snyder
of wireless data? If Sophisticated Buyers Want to Subsidize Consumers, Let Them!
Carriers know that raising prices for mobile data, or throttling data speeds to the largest users of mobile data, is no way to treat your biggest fans. But with the popularity of mobile device applications, which constantly stream information to and from the customer's phone, customers can unintentionally (and unnecessarily) stress capacity. Applications can distort data consumption in a way that even the most conscientious web surfers cannot offset.
So, earlier this year, at a conference in Barcelona, an AT&T executive suggested that maybe some applications providers would want to buy capacity
in bulk in order to assure their customers that using the desired app wouldn't cause the customer to exceed their usage cap, or become subject to throttling. Not a bad idea, right? I mean the applications developer knows how much bandwidth their customers use, and they have a lot more buying power than the consumer.
Given the public's embrace of mobile data, and the cost of continually augmenting capacity, especially for firms with sub-optimal spectrum allocations, one would think the "public interest" would support options that allow customers to still enjoy wireless data, but at a lower cost/consumption threshold. One would think . . . .But Don't Tell Public Knowledge!
The AT&T suggestion seemed harmless enough, but the reaction from the self-proclaimed public interest group Public Knowledge
was alarmingly critical
. Then again, this is the same group that published a paper
arguing that all wireless carriers should provide flat-rated mobile data service. The irony, of course, is that flat-rated price structures cannot be profitable unless the majority of users pay for more data than they consume
The notion of "more bricks, less straw" is, for regulators and service providers, an unfortunate and dystopic reality. Uniquely, Public Knowledge seems to relish the "more megabytes, less capacity" future with a fondness that can't help but be compared with how the ancient Egyptian brick consumers' lobby must have felt . . . right before the brick supply crashed.
May 9, 2012 6:42 PM
[In case no one noticed, I've been on a "Vision Quest" for the last few months; but, in the words of the great John Riggins, "I'm bored, I'm broke, and I'm back."]
One thing I've noticed during my self-imposed absence is that there really isn't much of a dialogue in the public discourse on telecom policy these days. That's not a particularly astute observation for some areas of public discourse, like politics. After all, anyone can tell you that the big political parties mischaracterize each other and talk past one another all the time. But telecom issues aren't especially political, so what's the harm in listening to what someone is saying and--if you want to respond--providing a thoughtful response?
No where was the unfortunate temptation to characterize, rather than accept and address, an opponent's arguments more on display as it was in Chairman Genachowski's remarks
at the CTIA show yesterday. Rather than respond to AT&T's CEO Randall Stephenson's contention that the Commission's decision to oppose AT&T's purchase of T-Mobile had caused AT&T to increase its retail prices for wireless data, the Chairman chose to mischaracterize and dismiss Stephenson's observation. This was unfortunate, and a missed opportunity by the Chairman to validate a different view of the same spectrum shortage the Chairman has sought to publicize.
While Stephenson's statement
made headlines last week in advance of the CTIA show, AT&T's Stephenson has made this same observation consistently, in both December, and over 3 months ago in a conference call
with shareholders and analysts.
Chairman Genachowski, to his credit, has been one of the most vocal advocates for the need for more spectrum for the wireless industry. The Chairman has, for most of his tenure as FCC Chairman, understood that demand for wireless data services is outstripping the supply of spectrum and the ability of wireless operators to use different techniques to most efficiently use the spectrum that they have. The Chairman made all of these points in his remarks yesterday at CTIA.
Randall Stephenson, AT&T's CEO, has said nothing inconsistent with the facts the Chairman has used to argue for the need for more wireless spectrum to be brought to market. It only stands to reason that if there is insufficient spectrum (on an industry-wide basis) to satisfy the growth in aggregate demand for wireless data, then spectrum shortages will affect some firms earlier than others. The first firms to feel the spectrum crunch will necessarily be the first firms to react by managing demand (because input supplies are static). And, the only way to manage demand is through price increases. Indeed, avoiding this inevitable result of spectrum scarcity was AT&T's justification for its proposed merger with T-Mobile.
But, rather than accept the perspective of one of the industry's first firms to feel the spectrum crunch, the FCC Chairman chose to conflate the observations of AT&T's Stephenson into two arguments that Stephenson never makes. The first is that wireless competition is bad for consumers, and the second is that competition is bad for spectrum efficiency.
After reading Stephenson's observations, it makes more sense to interpret his statements as being that the "new" wireless industry is characterized by many firms lacking minimum efficient scale to meet the projected demand of their consumers. This is hardly a radical statement. Many industries demand significant scale in order to satisfy consumer demand--one reason we don't see "mom and pop" microchip manufacturers. A permanent increase in demand, which the Chairman perceives as a good thing, may well require a higher, firm-specific level of access to the vital input of spectrum.
The solution, which would best benefit consumers, would be for the Chairman to recognize that--if he is confident that more spectrum will come on the market soon--there cannot be any one static notion of how many firms should be in the market. In a world where spectrum can be expanded, so can the number of competitors. Any backward-looking concept of how competition should look reflects nothing more than an irrational time bias. In other words, if adequate spectrum (to support more firms in the market) is coming, then near term consolidation--if it maximizes industry output--will not lead to a less beneficial result for consumers in the long run.
Singapore is actively considering just such an approach, by reserving specific future spectrum for a new competitor
. Such an approach introduces the concept of "contestability" in a very real and certain way. Firms in the market are allowed to maximize current efficiency by using optimal blocks of spectrum. Yet these same firms understand that they will be facing certain competition by a potentially lower cost competitor in the foreseeable future.
Wireless broadband consumers benefit from solutions, not rhetoric. The FCC should stop viewing market participants as obstacles to consumer satisfaction, but rather as indispensable vehicles to satisfying consumer demand. In a world where a vital input like spectrum can be expanded, albeit slowly, does it really make sense to freeze firms' spectrum reserves at a pre-wireless-broadband level?
June 29, 2011 2:01 PM
Earlier this week, the FCC released its annual Wireless Competition Report
to Congress. Like last year, the Commission noted the overall complexity of the mobile wireless market, and the adjacent markets in the supply chain for wireless services. Based on this complexity, the Commission again decided not to make any conclusions as to whether the mobile wireless market was effectively competitive. Commissioner McDowell fairly expressed criticism
that the Commission shouldn't shy away from its directive simply because it is difficult.
I couldn't agree more with Commissioner McDowell. The FCC's failure to sift through all that complex data and reach a well-supported conclusion means that I had to read the report. This was, to say the least, tedious--yet informative. Regardless of what one might think about the Commission's indecision, the Report was obviously the result of a lot of hard work, and the Commission staff certainly deserved the compliments included in the Commissioners' separate statements.
Once you accept that the Commission wasn't going to reach any conclusions regarding the state of wireless competition in its Wireless Competition Report, you cannot help but be impressed by both the (perhaps unnecessary?) ambitiousness of the report, and the conclusion that--by just about any relevant measure--the mobile services market became more competitive over the time period measured.
Network capacity increased (in terms of network deployment and upgrades), output (as measured by consumer demand/subscribership) increased for both voice and data services, as did consumer choice for rural and urban consumers in terms of number of service providers and services/devices from which consumers could choose. The number of wireless Internet data subscribers more than doubled between 2008 and 2009. Through this time period, prices remained low (as measured by the Cellular CPI-Table 19), or declined (for most data users--see discussion at para. 90).
Continue reading How I Learned to Stop Worrying and [Like?] the Wireless Competition Report
February 24, 2011 1:27 PM
Who's to say, what's not to say, and what's fair to say
Let's ask Dr. Dre
Dr. Dre? . . .
, Eminem (with Dr. Dre), 2004
The truth is that, when it comes to the "transparency" disclosure rules in the FCC's Open Internet Order
(see Section 8.3, App. A, p. 88), the good Doctor
could probably provide as much useful information to consumers as any network provider will be able to offer--especially with respect to mobile wireless broadband performance. Hard to believe . . . but true.
At first glance, the "transparency" disclosure requirement seems
like the most reasonable
"net neutrality" rule . . . and the one most likely to actually help consumers. In fact, the rule seemed so rational
that it was the only net neutrality rule that the FCC deemed reasonable to apply to both mobile wireless and wireline broadband ISPs in equal measure. And, who could blame the Commission? After all, they were only following the requests of the largest manufacturers of smartphones, smartphone operating systems, and infrastructure equipment.
The Information Technology Industry Council ("ITIC")
, which represents (among others) Apple
, Nokia Siemens, Google, Microsoft, and RIM
, even told
the FCC that,
mobile wireless BBIA [broadband Internet access] service providers should be required to comply with robust disclosure requirements similar to those that should apply to wireline BBIA service providers
. These rules should require the disclosure of sufficient information to enable consumers . . . to make informed choices
regarding use of the BBIA service offered by the mobile wireless provider.ITIC PN Comments
at 8 (emphasis added). The FCC listened, and required all
broadband Internet access service providers to "disclose accurate information [regarding service performance, terms, and characteristics] sufficient for consumers to make informed choices regarding the use of such services . . . ." Open Internet Orde
r, App. A, p.88 (new Section 8.3 of FCC rules).
But, who's to say, what's fair to say, and what not to say? Personally, I would've thought that information was self-evident . . . until I read a very interesting article at Ars Technica
("Ars"), comparing iPhone service performance in Chicago on the AT&T and Verizon wireless networks
Before, I explain the significance of this article, let me explain that I am NOT taking sides for either carrier. I know that there are tech reviews that argue for the merits of Verizon in some places
, and AT&T in others--even nationwide
The Ars test, though, got "behind the bars" and was able to discern that certain "bellweather" indicators--like number of bars, and speed tests were not always indicative of actual performance. The results of the Ars test were that, on average--for the criteria tested (speed, large file app download, and Youtube video download)--AT&T's network out-performed Verizon's for the iPhone device. However, if you look at the individual data sets, there is a lot of variability even on the same network within the city of Chicago. So, depending on which areas you spend most of your time, your experience might be different than the results of the article suggest.
Interestingly, the article observes that,
the Speedtest results may say one thing, but they don't always translate to real-world network performance. Even in the cases where the Verizon iPhone got a faster download speed than the AT&T iPhone, the AT&T app download took noticeably less time than the same app download on Verizon--in one case, where AT&T was measured via Speedtest as slower (UIC test), the download time on AT&T was almost half that of Verizon.
What can wireless consumers learn from this "real world" performance test regarding information sufficient to allow them to make informed choices about their mobile wireless broadband service? Most importantly, that wireless networks will never have uniform performance, so--as Ars also notes, "when it comes to cell signal and quality . . . where you live and work and how the network is in your area trumps anything you'll read in any review."
This is why it's probably unreasonable for the FCC to require carriers to provide consumers with information that is likely to be misleading. Even if the carrier believes its performance information to be generally correct, it will never be accurate for any given customer, because accurate performance information is outside of the network provider's control.
But, does this fact render the "transparency" rule completely worthless? Well . . . maybe
. . . at least for wireless carriers. Although it's certainly in consumers' interest to have accurate information about every aspect of their service within the network provider's control, most wireless carriers already disclose this information as part of their voluntary compliance with the CTIA Consumer Code
So, for the most valuable "disclosure" information--accurate network performance--who's to say what's fair to say, and what not to say? For now, you might as well ask Dr. Dre . . .