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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Office of Economics and Analytics Seeks ) GN Docket No. 20-60 Comment on the State of Competition in the ) Communications Marketplace ) COMMENTS OF CTIA Thomas C. Power Senior Vice President and General Counsel Scott K. Bergmann Senior Vice President, Regulatory Affairs Dr. Robert Roche Vice President, Research Public Affairs Kara Graves Assistant Vice President, Regulatory Affairs Sarah K. Leggin Director, Regulatory Affairs CTIA 1400 Sixteenth Street, NW Suite 600 Washington, D.C. 20036 (202) 736-3200 April 27, 2020 TABLE OF CONTENTS I. INTRODUCTION........................................................................................................1 II. THE COMMUNICATIONS MARKETPLACE REMAINS ROBUST AND COMPETITIVE. ..........................................................................................................3 A. Wireless Devices, Connections, and Traffic are Growing Exponentially, and These Trends Are Expected to Continue. ...................................................3 B. Wireless Providers Are Expanding Their Footprints, Investing in Their Networks, and Offering More Advanced, High-Quality Services to Consumers Across the United States. ................................................................9 C. Wireless Providers Are Competing to Deploy New and Advanced Networks and Technologies. ............................................................................15 D. Cable Providers, Fixed Wireless Companies, and Satellite Operators are Fiercely—and Successfully—Competing for Customers. ...............................23 E. Competition in the Mobile Wireless Marketplace is Delivering More Value to Consumers. ........................................................................................30 III. COMPETITION AND INNOVATION IN THE WIRELESS SECTOR ARE CREATING IMMENSE OPPORTUNITY AND SPARKING U.S. LEADERSHIP IN THE NEW 5G ECONOMY. .....................................................33 A. 5G Will Power Innovation in Nearly Every Industry Vertical. .......................35 B. Increasing Demand for IoT is Fostering Innovation, Lowering Costs, and Increasing Productivity. ...................................................................................41 IV. THE WIRELESS INDUSTRY IS CONTINUING TO INNOVATE AND INVEST IN PROTECTING CONSUMERS AND PUBLIC SAFETY. ...............44 A. The Wireless Industry Continues to Invest in Networks and Solutions to Enhance Public Safety. ....................................................................................45 B. The Wireless Industry is Fighting Hard to Protect Consumers from Illegal and Unwanted Robocalls. .....................................................................52 C. The Wireless Industry Continues Efforts to Maintain Consumer Trust and Confidence in Messaging Services. .................................................................56 V. THE COMMISSION CAN FOSTER ADDITIONAL COMPETITION IN THE WIRELESS SECTOR BY ADOPTING AND SUPPORTING POLICIES INCREASING ACCESS TO SPECTRUM RESOURCES. ..............58 A. The Commission Can Promote Competition By Ensuring That Wireless Service Providers Have Access to Spectrum for Exclusive Licensed Use. .....58 B. The Commission Has Done an Excellent Job Reducing Barriers to Wireless Infrastructure Deployment and Should Continue to Promote Access to Resources That Support Next-Generation Services. .......................64 VI. CONCLUSION. .........................................................................................................67 EXECUTIVE SUMMARY The COVID-19 crisis has reinforced the critical importance of wireless connectivity and we are proud to see the billions of investment dollars by the wireless industry helping keep Americans connected. The mobile wireless marketplace in the United States continues to be highly competitive, and that competition is creating immense opportunities for consumers and sparking U.S. leadership in the new 5G economy. Long-time competitors and new entrants alike are aggressively positioning themselves to offer lower prices, greater speeds, enhanced coverage, and even more consumer-friendly options. As a result, more consumers are enjoying more choices and more value from their wireless offerings than ever before, a trend that will only continue as we move into the next generation of wireless. By any metric, the mobile wireless marketplace is robust and thriving. By way of just a few examples: • Usage. The average American smartphone user now consumes more than 6.5 GB of data per month, up from 1.1 GB per month five years ago, and the average American spends more than five hours on their smartphone per day. Global mobile data traffic also continues to grow at a staggering pace and is expected to reach 160 exabytes per month by 2025. In the United States alone, mobile data traffic grew from an estimated 2.33 exabytes per month in 2018 to 3.12 exabytes per month in 2019. To put that into perspective, the 2019 traffic accounted for more data use every month than all of the video traffic on the internet in 2015. And U.S. mobile data usage is predicted to reach 10.04 exabytes per month by 2023—an anticipated 331 percent increase from 2018. • Connections. In the past five years, the number of wireless subscribers has increased more than 25 percent. In addition, there are expected to be 3.4 mobile devices per capita in the United States by 2023, representing a total of 1.2 billion mobile-connected devices. Furthermore, roughly 96 percent of American adults and teens have cellphones, and smartphones dominate cellphone ownership. • Deployment of advanced networks. In 2018, the Commission found that more than 99 percent of Americans had access to 4G LTE service, and more than 98 percent could choose from at least three 4G LTE service providers. Since then, high-quality service coverage across the United States has continued to expand, including through the i deployment of 5G networks. As the Commission recently noted in its 2020 Broadband Deployment Report, “mobile wireless providers continue to improve their networks, notably through the deployment of 5G technology.” Wireless providers are competing aggressively to deploy 5G networks, building on significant initial deployments in late 2018 and throughout 2019. • Investment. Wireless providers reported $27.4 billion in incremental capital investment in 2018, 6.9 percent more than 2017, and a cumulative capital investment of $542 billion as of year-end 2018, an increase of 5.3 percent from 2017. Investment by wireless providers in improving network speeds has resulted in consumers benefitting from 90 percent faster download speeds than just five years ago. Consumers are reaping the benefits from this fiercely competitive market. Competition to attract and retain subscribers has led to myriad consumer benefits such as lower prices, enhanced coverage, and greater speeds. The industry is also innovating to protect consumers and public safety, and has demonstrated its ongoing commitment to assisting U.S. consumers in times of need, including through its response to the COVID-19 pandemic. Consumers continue to lead a mobile-first lifestyle. Consumers increasingly use their wireless devices to make daily tasks easier—for example, to work remotely (voice calls, video conferencing, and collaboration), to learn remotely, to buy household essentials, to pay bills, for banking, remote health care and medical appointments, and for transportation planning—and to access employment opportunities, healthcare resources, government services, and more. Indeed, one in five Americans is “mobile only.” By 2025, it is estimated that nearly three quarters of all internet users will access the internet solely through their mobile device. Competition is delivering more value to consumers. America’s wireless customers get the most value for their money when compared with peer countries around the world. According to a new, comprehensive analysis of wireless plans offered in 36 countries from NERA Economic Consulting, America’s wireless customers get the most value for their money, saving up to nearly $10 billion each year as a result of the superior value that U.S. wireless providers ii offer. The increasingly competitive wireless marketplace has prompted providers to think creatively to attract and retain customers. Wireless consumers are benefitting in the form of lower prices, device promotions, unlimited data services, bundled service offerings, additional incentives, free add-ons, and more. 5G will power an explosion of innovation and jobs across industries. Competition and innovation in the wireless sector are creating immense opportunity and sparking U.S. leadership in the new 5G economy. Nationwide wireless providers launched initial mobile 5G service in 2019, which represented a significant investment in resources and infrastructure. Rural and regional providers and other industry stakeholders are also implementing 5G deployment strategies. 5G will spur significant innovation across industries, including transportation, manufacturing, agriculture, education, retail, healthcare, energy, and more. The 5G mobile value chain alone could generate up to $3.6 trillion in revenue in 2035 and support more than 22.3 million jobs globally. New entrants are aggressively competing for customers. DISH is poised to enter the U.S. wireless market as a nationwide facilities-based network competitor and has committed to deploy a 5G broadband network capable
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