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
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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
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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 of serving 70 percent of the U.S. population by June
2023. Cable companies continue to invest as infrastructure-based mobile virtual network
operators and are well positioned to deploy fixed and mobile 5G operations and compete directly
with mobile network operators on a nationwide basis. Satellite companies are also aiming to
provide wireless services that seek to meet the needs of consumers in traditionally unserved and
underserved areas. The growth of fixed wireless providers, which can provide gigabit residential
broadband speeds and flexible cost plans, is also indicative of the competitive nature of the
industry.
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Businesses harness wireless services to fuel their competitive edge. Businesses are increasingly dependent on wireless services and devices, such as innovative Internet of Things
(“IoT”)-connected devices and drones, to improve performance and streamline operations.
Consumers’ mobile-first lifestyle will create a growing number of opportunities for digital transformation—for businesses to tie technology to performance, ensure greater agility and flexibility, and experiment with how to best deliver value to customers, particularly as we transition to advanced 5G technologies.
Increasing demand for IoT is fostering innovation, lowering costs, and increasing productivity. The worldwide number of IoT-connected devices is projected to increase from
10.8 billion in 2019 to 24.9 billion in 2025—a compound annual growth rate of 15 percent. With the growth of IoT and home automation, consumers can use their smartphones to, for example, monitor their health from home and on the go, and manage various aspects of their households, including security, utilities, and home maintenance. Smart cities and smart infrastructure solutions powered by IoT devices can also help governments at all levels improve efficiency and stewardship of valuable resources.
Wireless providers are working to serve all Americans. Nationwide, regional, and rural providers have expended considerable resources to expand their LTE coverage and capacity by acquiring new spectrum and deploying new cell sites. These service providers are also planning and executing 5G deployment strategies, with a focus on addressing challenges unique to serving rural areas.
The wireless industry is fighting hard to protect consumers from illegal and unwanted robocalls. Wireless providers have been working diligently to protect consumers from the scourge of illegal and unwanted robocalls. For example, the wireless industry has led the way in
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deploying a variety of robust robocall mitigation tools, including network-level tools and data analytics consumers never see, consumer-facing tools that can be tailored to consumers’ needs, and enhanced call authentication services that help inform and empower consumers.
Access to mid-band spectrum for licensed use and an emphasis on deregulatory policies will further promote competition. While CTIA applauds the Commission’s actions to facilitate the deployment of 5G and wireless broadband infrastructure, CTIA proposes several steps that the Commission may take to further reduce barriers to entry, promote competition, and accelerate U.S. leadership in the race to 5G. Among other things, CTIA urges the Commission to adopt and support policies that increase access to spectrum resources, including mid-band spectrum for exclusive licensed use. Despite important actions by the Commission, the United
States faces a critical shortage of mid-band spectrum for licensed wireless services, and the
Commission should work with the Administration to ensure commercial access to the Lower
3 GHz band for licensed, commercial 5G use. We also urge the Commission to continue its work to reduce barriers to wireless infrastructure deployment, including infrastructure needed for
5G.
CTIA looks forward to working with the Commission to continue to ensure the communications marketplace remains highly competitive for years to come.
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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
CTIA1 respectfully submits these comments in response to the Public Notice released by
the Office of Economics and Analytics of the Federal Communications Commission
(“Commission”) in the above-captioned proceeding.2 The Public Notice “seeks input on the
state of . . . competition in the communications marketplace [to inform] its second
Communications Marketplace Report.”3 These comments highlight the vibrant competition in
today’s mobile wireless industry.
I. INTRODUCTION.
The mobile wireless marketplace in the United States continues to be highly competitive.
Metrics such as investment, usage, connections, and deployment of advanced networks continue
to leave no doubt that competition is particularly robust in the wireless industry. Traditional
1 CTIA – The Wireless Association® (“CTIA”) (www.ctia.org) represents the U.S. wireless communications industry and the companies throughout the mobile ecosystem that enable Americans to lead a 21st century connected life. The association’s members include wireless carriers, device manufacturers, suppliers as well as apps and content companies. CTIA vigorously advocates at all levels of government for policies that foster continued wireless innovation and investment. The association also coordinates the industry’s voluntary best practices, hosts educational events that promote the wireless industry and co-produces the industry’s leading wireless tradeshow. CTIA was founded in 1984 and is based in Washington, D.C. 2 Office of Economics and Analytics Seeks Comment on the State of Competition in the Communications Marketplace, Public Notice, 35 FCC Rcd 1577 (2020) (“Public Notice”). 3 Id. at 2.
players and new entrants such as cable companies, satellite operators, and fixed wireless providers are all aggressively vying for market share.
Consumers are reaping the benefits from the 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.
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 5G service in 2019, which represented a significant investment in resources and infrastructure.
Rural and regional providers and other industry stakeholders are also executing 5G deployment strategies. 5G will power an explosion of innovation across industries, including transportation, manufacturing, agriculture, education, retail, healthcare, energy, and more.
Even in a competitive mobile wireless marketplace, there are measures the Commission can take to further promote competition. CTIA urges the Commission to adopt and support policies that increase access to spectrum resources, particularly mid-band spectrum, for exclusive licensed use. Despite important actions by the Commission, the United States faces a critical shortage of mid-band spectrum for licensed wireless services, and the Commission should work with the Administration to make available the 3.1-3.55 GHz (“Lower 3 GHz”) band for licensed, commercial 5G use. CTIA also urges the Commission to continue its work to reduce barriers to wireless infrastructure deployment and foster deregulatory policies that will enable our new 5G economy.
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II. THE COMMUNICATIONS MARKETPLACE REMAINS ROBUST AND COMPETITIVE.
The wireless market exhibits the hallmarks of fierce competitive rivalry along virtually
every dimension, including expanded service coverage and offerings, the continuous deployment
of new technologies, and new entry by well-capitalized competitors. Service providers are
investing significant sums of capital to deploy advanced networks and meet consumers’ growing
and seemingly insatiable demand for data. 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 of this highly competitive marketplace,
consumers enjoy more choices and more value from their wireless offerings, a trend that will
only continue as providers compete to offer the next generation of wireless connectivity.
American consumers increasingly live a mobile-first lifestyle, using their wireless devices in nearly every aspect of their daily lives. In the past five years, the number of wireless subscribers has increased more than 25 percent4 and the average American spends more than five
hours on their smartphone per day.5 As a result, wireless use in the United States continues to
grow at an exponential rate—a trend that remains unchanged from the last Communications
Marketplace Report.6 Cisco’s report of mobile broadband usage predicts 3.4 mobile
4 Smarter and More Efficient: How America’s Wireless Industry Maximizes Its Spectrum, CTIA, www.ctia.org/news/smarter-and-more-efficient-how-americas-wireless-industry-maximizes-its-spectrum (last visited Mar. 31, 2020) (“Smarter and More Efficient: How America’s Wireless Industry Maximizes Its Spectrum”). 5 Eileen Brown, Americans Spend Far More Time on Their Smartphones Than They Think, ZDNET (Apr. 28, 2019), www.zdnet.com/article/americans-spend-far-more-time-on-their-smartphones-than-they-think. 6 Annual Internet Report Highlights Tool, CISCO, www.cisco.com/c/en/us/solutions/executive- perspectives/annual-internet-report/air-highlights.html (last visited Mar. 31, 2020) (“Cisco Annual Internet Report Highlights Tool”); see also Remarks of FCC Chairman Ajit Pai at the Information
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devices/connections per capita in the United States by 2023, representing a total of 1.2 billion mobile-connected devices.7 Moreover, the Pew Research Center has found that 96 percent of adult Americans now own a cellphone of some kind,8 and 95 percent of American teens own or have access to a smartphone.9 Today, the number of distinct models of smartphones offered to Americans is almost twice the number available to them ten years ago— more than 300 today, compared to 154 in
2010.10
Not only are there more subscribers and more devices, but also more data usage per device. The average
American smartphone user now uses more than 6.5 GB of data per month, up
Technology and Innovation Foundation (Feb. 6, 2020), https://docs.fcc.gov/public/attachments/DOC- 362334A1.pdf (“Remarks of FCC Chairman Ajit Pai at the Information Technology and Innovation Foundation”) (discussing the need to free up spectrum to meet the growing demand for mobile broadband). 7 Cisco Annual Internet Report Highlights Tool. 8 Mobile Fact Sheet, Pew Research Center (June 12, 2019), https://www.pewresearch.org/internet/fact- sheet/mobile/. 9 Teens, Social Media & Technology 2018, Pew Research Center (May 31, 2018), https://www.pewresearch.org/internet/2018/05/31/teens-social-media-technology-2018/#vast-majority-of- teens-have-access-to-a-home-computer-or-smartphone. 10 Counts based on contemporaneous review by CTIA Research of devices offered to consumers on wireless service providers’ websites in mid-2010 and March 2020.
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from 1.1 GB five years ago.11 Indeed, global mobile data traffic continues to grow at a staggering pace and is expected to reach 160 exabytes per month by 2025.12 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, and is predicted to reach 10.04 exabytes per month by 2023.13
Handset manufacturers are also introducing 5G devices in the United States, including
Samsung with its Galaxy S20 5G, Galaxy S20+ 5G, and Galaxy S20 Ultra 5G;14 Motorola with the moto z4 and forthcoming Motorola Edge+; and LG’s V60 ThinQ 5G and 5G Dual Screen devices.15 Additionally, wireless original equipment manufacturers (“OEMs”) are producing new 5G-oriented solutions and innovations, such as Ericsson’s first smart factory in the U.S. in
Lewisville, Texas, which has produced its first 5G base station.16 The solution, called the millimeter-wave Street macro solution, is part of Ericsson’s Radio System portfolio.17 Samsung
11 CTIA’s Wireless Industry Indices Report, CTIA, at 15 (rel. June 2019) (“CTIA’s Wireless Industry Indices Report”). 12 Global Millimeter Wave Technology Market to 2027 – Market Positioning of Key Players, BUSINESS WIRE (Mar. 17, 2020), http://www.businesswire.com/news/home/20200317005374/en/Global- Millimeter-Wave-Technology-Market-2027--. 13 S. O’Dea, Estimated Mobile Internet Traffic in the United States from 2018 to 2023, STATISTA (Feb. 27, 2020), https://www.statista.com/statistics/681392/total-mobile-data-traffic-per-month-in-the-us. 14 The Galaxy S20 5G supports 5G in low and mid bands. The Galaxy S20+ 5G and Galaxy S20 Ultra 5G support 5G in low, mid, and high bands. 15 See, e.g., Press Release, Capture Your World in a Whole New Way: Samsung Galaxy S20 5G Series Available Today, Samsung (Mar. 6, 2020), https://news.samsung.com/us/samsung-galaxy-s20-5g-series- available-today-capture-your-world; Larry Dignan, Motorola Enters Flagship Smartphone Fray, Launches Moto Edge, Edge Plus at $999, ZDNET (Apr. 22, 2020), https://www.zdnet.com/article/motorola-enters-flagship-smartphone-fray-launches-moto-edge-edge-plus- at-999/; AT&T Expands 5G Device Lineup with the LG V60 ThinQ 5G Coming Soon, AT&T (Feb. 26, 2020), https://about.att.com/story/2020/lg_v60_thinq_5g.html. 16 See, e.g., Press Release, Ericsson USA 5G Smart Factory Produces Its First Base Stations, Ericsson (Mar. 4, 2020), https://www.ericsson.com/en/press-releases/2020/3/ericsson-usa-5g-smart-factory- produces-its-first-base-stations. 17 Id.
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and Marvell announced a partnership to foster innovations across segments of the Radio Access
Network (“RAN”) to enable 5G-ready infrastructure.18 Intel offers 5G mobile modems for smartphones, tablets, PCs, and Internet of Things (“IoT”) devices.19 Nokia announced a partnership with Intel to develop technology advancements for Nokia’s 5G radio portfolio, including strengthening AirScale and further advancing the capabilities of its ReefShark chipset.20 HTC developed its 5G Hub, which combines a 5G hotspot, an Android hub, and a battery pack into a single device.21 And Nokia and Marvell have partnered to develop 5G multi-
Radio Access Technology silicon innovations, including several generations of silicon and infrastructure processors to expand the range of Nokia ReefShark chipsets for 5G solutions.22 A number of OEMs and brands have also selected the Qualcomm Snapdragon 865 Mobile Platform for their 5G device launches this year.23 Moreover, since the Qualcomm 5G RAN platform launch in May of 2018, a number of manufacturers and cellular infrastructure providers have
18 Press Release, Samsung and Marvell Drive Innovation in a New Generation of 5G Infrastructure Products, Samsung (Feb. 21, 2020), https://news.samsung.com/us/samsung-marvell-5g-infrastructure- products-innovation-new-generation/. 19 Intel Wireless Solutions, Intel, https://www.intel.com/content/www/us/en/products/wireless.html (last visited April 23, 2020). 20 Press Release, Nokia Collaborates with Intel on Silicon Technology Innovations for 5G New Radio and Cloud Infrastructure, Nokia (Mar. 5, 2020), https://www.nokia.com/about- us/news/releases/2020/03/05/nokia-collaborates-with-intel-on-silicon-technology-innovations-for-5g- new-radio-and-cloud-infrastructure/. 21 See 5G Hub, HTC, https://www.htc.com/us/5g/htc-5g-hub/ (last visited Apr. 9, 2020); see also Tom Warren, HTC’s 5G Hub is a 5G Hotspot, Android Entertainment Device, And Battery Pack, THE VERGE (Feb. 25, 2019), https://www.theverge.com/2019/2/25/18236326/htc-5g-hub-features-specs-release-date- mwc-2019. 22 Press Release, Nokia and Marvell Enter into Partnership on Silicon Technology for 5G, Nokia (Mar. 4, 2020), https://www.nokia.com/about-us/news/releases/2020/03/04/nokia-and-marvell-enter-into- partnership-on-silicon-technology-for-5g/. 23 Press Release, Flagship Qualcomm Snapdragon 865 5G Mobile Platform Powers First Wave of 2020 5G Smartphones, Qualcomm (Feb. 25, 2020), https://www.qualcomm.com/news/releases/2020/02/25/flagship-qualcomm-snapdragon-865-5g-mobile- platform-powers-first-wave-2020.
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begun using the platform as well.24 For its part, Apple is expected to launch 5G iPhones in 2020,
which are expected to include sensor shift technology, allowing for better quality videos and
photos when capturing motion, according to analyst reports.25 Companies like Assurant and
Asurion partner with wireless providers to offer consumers a variety of device insurance plans to
protect these devices from loss or damage, and offer personalized tech support to help consumers
get the most out of their wireless devices.26
As consumers progressively embrace digital assistants and IoT devices, and the greater
convenience and efficiency that come with them, even more of everyday life relies on wireless
data.27 With the growth of IoT and home automation, consumers can use their smartphones to,
for example, support their health, fitness, and well-being from home and on the go, as well as to
manage various aspects of their households, including security, utilities, and home
24 Press Release, Global Cellular Infrastructure Firms Select Qualcomm 5G RAN Technologies, Qualcomm (Feb. 25, 2020), https://www.qualcomm.com/news/releases/2020/02/25/global-cellular- infrastructure-firms-select-qualcomm-5g-ran-technologies. 25 Ahiza Garcia, Apple Expected to Launch Four 5G iPhones in 2020 JP Morgan Says, CNN BUSINESS (Dec. 2, 2019), https://www.cnn.com/2019/12/02/tech/apple-5g-iphones-2020/index.html. 26 See, e.g., Our Story, ASSURANT, https://www.assurant.com/ (last visited April 23, 2020); Supporting the Tech that Keeps You Connected, ASURION, https://www.asurion.com/ (last visited April 23, 2020). 27 Casey Crane, 20 Surprising IoT Statistics You Don’t Already Know, HASHEDOUT BY THE SSL STORE (Sept. 4, 2019), https://www.thesslstore.com/blog/20-surprising-iot-statistics-you-dont-already-know/; 6 Ways You’ll Directly Benefit from the Internet of Things, IEEE, https://innovationatwork.ieee.org/6-iot- benefits/ (last visited Mar. 9, 2020).
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maintenance.28 Smart cities and smart infrastructure solutions powered by IoT devices can also help governments at all levels improve efficiency and stewardship of valuable resources.29
Even with the growth of mobile broadband, consumers also continue to place more wireless calls and send more text messages than ever before. In the one-year span between 2017 and 2018, the number of voice calls and text messages increased by 9.6 percent and 15.8 percent, respectively, to total more than 2.38 trillion minutes, 1.7 trillion text messages, and 345.6 billion
MMS messages.30 Indeed, consumers send four times more texts than emails from their personal cell phones every day.31 This growth in traffic will drive the continued evolution of wireless networks.
28 Fredrik Dahlqvist et al., Growing Opportunities in the Internet of Things, MCKINSEY & COMPANY, https://www.mckinsey.com/industries/private-equity-and-principal-investors/our-insights/growing- opportunities-in-the-internet-of-things (last visited Mar. 24, 2020) (“McKinsey IoT Report”). See also,, e.g., Apple, Apple Home, https://www.apple.com/ios/home/ (last visited Apr. 9, 2020) (“With the Home app, you can easily and securely control your HomeKit accessories from all your Apple devices. Turn off the lights, see who’s at the front door, adjust your living room temperature, turn up the music, and so much more.”); Samsung, SmartThings, https://www.samsung.com/us/explore/smartthings/ (last visited Apr. 9, 2020) (“Monitor and control your home’s devices and appliances from just about anywhere. And do it all from your phone.”); LG, LG ThinQ, https://www.lg.com/us/discover/thinq/app (last visited Apr. 9, 2020) (“With the widest assortment of wi-fi enabled appliances and one app to manage them all, LG makes managing your smart appliances easy.”). 29 See Smart Cities Playbook: Building Your Connected Community, CTIA (2019), https://api.ctia.org/wp- content/uploads/2020/02/CTIA-Smart-Cities-Playbook.pdf (“Smart Cities Playbook”). For example, Southern Linc announced plans last year for net zero carbon emissions by 2050, which include advanced grid requirements, modernization of electricity production, and innovating their telecommunications infrastructure. See id. at 35. 30 Anne Freier, Use of Mobile Data Rising Rapidly – Jumps 82% in 2018, BUSINESS OF APPS (June 25, 2019), https://www.businessofapps.com/news/use-of-mobile-data-rising-rapidly-jumps-82-in-2018/; see also CTIA’s Wireless Industry Indices Report at 7. 31 State of Texting 2020, Zipwhip, https://www.zipwhip.com/state-of-texting-2020/ (last visited Apr. 2, 2020).
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To meet the continuing growth in data demand, the wireless industry has continued to invest significant amounts of capital to deploy and upgrade mobile broadband networks.
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 2017.32
As a result of this investment, more consumers now enjoy access to advanced wireless services than ever before. In 2018, the Commission found that more than 98 percent of
Americans had access to 4G LTE service from at least three service providers.33 Since then, high-quality service coverage across the United States has continued to expand.34 A July 2019
Tutela report, for example, revealed that since T-Mobile began its 600 MHz rollout in 2017, LTE coverage improved by 38 percent in Wisconsin, 28 percent in Wyoming, and 22 percent in North
Dakota; by 10 percent or more in Kansas, Maine, Michigan, Nebraska, and South Dakota; and by
32 See CTIA’s Wireless Industry Indices Report at 7. Further investment to support network advancements and deployment is expected to continue. By way of just one example, Verizon recently announced its decision to increase capex from $17-18 billion to $17.5-18.5 billion in 2020. Press Release, Verizon’s Networks Stand Ready for Increases in Data Traffic, Verizon (Mar. 12, 2020), https://www.verizon.com/about/news/verizons-networks-stand-ready-increases-data-traffic; Brian Sozzi, Why Verizon just made a big investment in America amid the coronavirus: CEO, YAHOO! FINANCE (Mar. 19, 2020), https://finance.yahoo.com/news/why-verizon-just-made-a-big-investment-in-america-amid- the-coronavirus-ceo-154612304.html. 33 See Communications Marketplace Report et al., Report, 33 FCC Rcd 12558 ¶ 41 and Fig. A-29 (2018) (“2018 Communications Marketplace Report”). 34 See Press Release, T-Mobile 600 MHz Extended Range LTE Now Live in More Than 1,250 Cities & Towns, Laying the Foundation for 5G, T-Mobile (Sept. 10, 2018), https://investor.t-mobile.com/news- and-events/t-mobile-us-press-releases/press-release-details/2018/T-Mobile-600-MHz-Extended-Range- LTE-Now-Live-in-More-Than-1250-Cities--Towns-Laying-the-Foundation-for-5G/default.aspx; Linda Hardesty, T-Mobile to launch 5G on 600 MHz in the second half of 2019, FIERCEWIRELESS (Apr. 26, 2019), https://www.fiercewireless.com/operators/t-mobile-to-launch-5g-600-mhz-second-half-2019.
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almost 10 percent in Iowa, Mississippi, Missouri, and Montana.35 AT&T, in 2019 alone, added
120,000 square miles to its network, inclusive of the FirstNet public safety communications platform, doubling its coverage area from 2018 and now “supporting more than 1 million connections from more than 10,000 subscribed first-responder agencies.”36 And Verizon, which commercially launched its 4G LTE network in December 2010, now has coverage to more than
326 million people across the U.S.37
Regional and rural service providers have also expended considerable resources to expand their LTE coverage. Southern Communications Services, Inc. (d/b/a Southern Linc), for example, fully transitioned to its new mission-critical 4G LTE network CriticalLinc from its legacy iDEN network in 2019.38 By 2020, the company is expected to have deployed 1,300 new sites to “provide[] better, broader coverage than what [it] had with the iDEN network” in the southeastern United States; moved from 1.4-megahertz channels to three-megahertz channels to take advantage of spectral efficiencies; and developed two core networks to offer consumers
35 See Mapping T-Mobile’s 600 MHz Rollout, TUTELA (July 2019), https://www.tutela.com/blog/mapping-t-mobiles-600-mhz-rollout-how-coverage-and-deployment-have- improved-over-two-years; Bevin Fletcher, T-Mobile Edges Out AT&T in Rural 4G Availability, Opensignal results show, FIERCEWIRELESS (Sept. 24, 2019), https://www.fiercewireless.com/operators/t- mobile-edges-out-at-t-rural-4g-availability-opensignal-results-show. 36 See Press Release, FirstNet Expands Nationwide LTE Coverage Area, AT&T (Feb. 25, 2020), https://about.att.com/story/2020/expanding_nationwide_lte_coverage.html; Power of FirstNet, FirstNet, https://www.firstnet.com/power-of-firstnet.html (last visited Mar. 25, 2020) (delivering a single, interoperable network for public safety); Donny Jackson, FirstNet Surpasses Marks for 75% Band 14 Buildout, 1 Million Connections and 10,000 Agencies Subscribed, URGENT COMMUNICATIONS (Dec. 4, 2019), https://urgentcomm.com/2019/12/04/firstnet-surpasses-marks-for-75-band-14-buildout-1-million- connections-and-10000-agencies-subscribed/. 37 Verizon, 4G LTE, https://www.verizon.com/about/our-company/wireless-network (last visited Apr. 9, 2020). 38 See Frequently Asked Questions about Southern Linc, Southern Linc, https://www.southernlinc.com/faqs/faqs-general.aspx (last visited Mar. 22, 2020) (offering “128,000 square miles of cell phone service coverage in both major metro and rural areas in Georgia, Alabama, southeast Mississippi and northwest Florida”).
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redundancy.39 U.S. Cellular delivers 4G LTE services to millions of consumers and businesses
and, earlier this year, the company announced that it launched its LTE-M network on more than
90 percent of its cell sites nationwide, with plans to have them 100 percent covered in the second
quarter of 2020, to support IoT devices in both urban and rural areas and hard-to-reach
environments.40 U.S. Cellular also partners with King Street Wireless to offer 4G LTE services
over King Street’s 700 MHz spectrum in 27 states throughout the country.41 To offer 4G LTE to
communities in Ohio, Virginia, and West Virginia, Shenandoah Telecommunications Company,
or Shentel, paid nearly $17 million for 90 megahertz of 2.5 GHz band spectrum in 2019.42
Approximately 280,000 of the 500,000 households in its new coverage area reside in rural areas
with only satellite or digital subscriber line, or DSL, options today.43 Shentel’s new LTE
offering, however, will soon provide these residents a low-latency alternative.44
This investment in deployment also extends to the next generation of wireless—5G. As
Chairman Ajit Pai recently stated, “5G networks will be an important platform for innovation
39 See Donny Jackson, Southern Linc Offers ‘Basic MCPTT’ and ‘High Performance MCPTT,’ Shuts Down Legacy iDEN System for LTE, URGENT COMMUNICATIONS (Apr. 30, 2019), https://urgentcomm.com/2019/04/30/southern-linc-offers-basic-mcptt-and-high-performance-mcptt-shuts- down-legacy-iden-system-for-lte/; see also Mission Accomplished – CriticalLinc is a critical win, Southern Linc, https://southernlinc.com/2019-fall-newsletter/ (last visited Mar. 22, 2020). 40 See Press Release, U.S. Cellular Launches LTE-M Network Optimized for IoT, U.S. Cellular (Feb. 7, 2020), https://www.uscellular.com/get-to-know-us/our-company/press-room/2020/u-s-cellular-launches- lte-m-network-optimized-for-iot. 41 See Wireless Services, King Street Wireless, https://www.kingstreetwireless.com/wireless-services/ (last visited April 23, 2020); U.S. Cellular: Everything You Need to Know, ANDROIDCENTRAL.COM (Nov. 20, 2019), https://www.androidcentral.com/us-cellular. 42 See Mike Dano, Shentel to Get Bigger Using Mix of Fiber, Cable & LTE Fixed Wireless, LIGHT READING (Aug. 7, 2019), https://www.lightreading.com/services/broadband-services/shentel-to-get- bigger-using-mix-of-fiber-cable-and-lte-fixed-wireless/d/d-id/753328. 43 See id. 44 See id.
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and investment in the coming years . . . .”45 Nationwide wireless providers are competing aggressively and devoted significant resources to deploy infrastructure to launch 5G service starting in 2018 and continuing through the end of 2019; this continues aggressively in 2020.
Indeed, as the Commission recently noted, “mobile wireless providers continue to improve their networks, notably through the deployment of 5G technology, which may have performance characteristics similar to fixed services in certain environments.”46 Verizon now offers its 5G
Ultra Wideband service, leveraging its millimeter wave spectrum, in parts of 34 cities.47
AT&T’s 5G offering appears in more than 100 markets, including more than 30 using sub-6 GHz spectrum.48 Low-band spectrum’s favorable propagation characteristics will enable AT&T’s
850 MHz signals to cover “roughly two-mile distances from towers, including […] ‘rural’ usage.”49 T-Mobile launched its 5G network nationwide, relying on 600 MHz low-band spectrum, in December 2019.50 Its network covers nearly 200 million people in 5,000 cities and
45 Remarks of FCC Chairman Ajit Pai at the Information Technology and Innovation Foundation at 1. 46 Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, 2020 Broadband Deployment Report, FCC 20-50, GN Docket No. 19- 285 ¶ 11 (rel. Apr. 24, 2020). 47 See Press Release, Verizon 5G Ultra Wideband Service Available in More Cities, Verizon (Jan. 30, 2020), https://www.verizon.com/about/news/verizon-5g-ultra-wideband-service-available-more-cities. 48 See Scott Mair, New Year, New Ways for AT&T Customers to Connect, AT&T (Jan. 3, 2020), https://about.att.com/innovationblog/2020/01/2019_5g_recap.html; Eric Zeman, et al., AT&T adds 20 new 5G US cities, bringing nationwide total to 100 markets, ANDROID AUTHORITY (Mar. 17, 2020), https://www.androidauthority.com/att-5g-cities-1057351/. 49 Jeremy Horwitz, AT&T Promises Low-Band 5G for 5 Cities in Weeks, 15 by Early 2020, VENTUREBEAT (Nov. 22, 2019), https://venturebeat.com/2019/11/22/att-promises-low-band-5g-for-5- cities-in-weeks-15-by-early-2020/. 50 See Press Release, T-Mobile 5G: It’s On! America’s First Nationwide 5G Network Is Here, T-Mobile (Dec. 2, 2019), https://www.t-mobile.com/news/americas-first-nationwide-5g-network; Christian de Looper, T-Mobile 5G Rollout: Here’s Everything You Need to Know, DIGITAL TRENDS (Mar. 3, 2020), https://www.digitaltrends.com/mobile/t-mobile-5g-rollout/.
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towns across more than one million square miles, much of that in rural America.51
Rural and regional providers and other industry stakeholders are also planning and executing 5G deployment strategies. U.S. Cellular, for example, launched 5G on 600 MHz spectrum in Iowa and Wisconsin and announced plans for millimeter wave 5G likely later in
2020.52 Bluegrass Cellular also announced a partnership with ClearSky Technologies to design
5G networks for two cities in its service area.53 Also last year, Cellcom invested nearly $1 million in acquiring 24 GHz and 28 GHz spectrum for 5G covering several counties in
Wisconsin.54 GCI launched 5G in Anchorage, Alaska this month and plans to expand service throughout the municipality and beyond.55 Other providers are working steadfast toward making their 5G networks capable in the near term,56 and companies like Ookla provide interactive 5G
51 Id. 52 See Mike Dano, U.S. Cellular to boost capex for 5G, adds Samsung as Supplier, LIGHT READING (Feb. 21, 2020), https://www.lightreading.com/5g/us-cellular-to-boost-capex-for-5g-adds-samsung-as- supplier/d/d-id/757664. See also Knoxville now covered by US Cellular’s 5G, JOURNAL EXPRESS (Mar. 6, 2020), https://www.journalexpress.net/news/local_news/knoxville-now-covered-by-us-cellular-s- g/article_577abd64-5fe3-11ea-8f61-a314ef7fdbfd.html; Catherine Sbeglia, With US Cellular launch, Wisconsin city gets a 5G network, RCR WIRELESS (Feb. 27, 2020), https://www.rcrwireless.com/20200227/5g/with-us-cellular-wisconsin-first-5g-network. 53 See Press Release, ClearSky Technologies, Inc., Bluegrass Cellular Employs ClearSky’s NetView 360 Service to Evaluate Design Options for 5G Wireless Deployment (July 9, 2019), https://www.prweb.com/releases/bluegrass_cellular_employs_clearskys_netview_360_service_to_evaluat e_design_options_for_5g_wireless_deployment/prweb16403550.htm. 54 Cellcom Spends Nearly $1 Million on Wisconsin 5G Spectrum, TELECOMPETITOR (June 19, 2019), https://www.telecompetitor.com/cellcom-spends-nearly-1-million-on-wisconsin-5g-spectrum/. 55 GCI Launches 5G Service in Anchorage, KTVA-11 (Apr. 20, 2020), https://www.ktva.com/story/42028288/building-stronger-wireless-connection-5g-technology-arrives-to- anchorage. 56 See, e.g., 5G Frequently Asked Questions, Appalachian Wireless, http://www.appalachianwireless.com/?page=5g_faq (last visited Apr. 23, 2020) (working toward making parts of its network 5G-capable in early 2021).
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Maps to help consumers track providers’ 5G network deployments.57
In addition to deploying these advanced networks, wireless providers are exploring new
opportunities to enrich the customer experience and deliver greater value with their LTE and 5G
services. For the 2019 Super Bowl, for instance, nationwide providers invested millions on new
capacity, small cells, distributed antenna systems (“DAS”), and overall upgraded LTE capacity
for the game to handle the massive data usage in and around the stadium—which amounted to
more than 35.7 terrabytes during the 2018 game.58 Building off the previous year’s success,
Verizon partnered with the National Football League at the 2020 Super Bowl to promote the
presence of Verizon’s 5G Ultra Wideband network, which delivered consumers “live in-stadium
wayfinding apps, live-streaming via multiple camera angles[,]” and “augmented reality […]
overlays of big plays, stats and other moments of the game[,]” as well as a heightened 4G
experience.59 Likewise, AT&T offers fans a 5G showcase at AT&T Stadium, home of the
Dallas Cowboys. This enhanced consumer experience offers fans a variety of unique 5G
activations using realistic 3D volumetric video and augmented reality, enabling fans to cheer or
dance with digital versions of real-life players, and engage with on-field augmented reality and
video game experiences—all powered by AT&T’s 5G network.60
57 See Ookla 5G Map, SPEEDTEST.NET, https://www.speedtest.net/ookla-5g-map (last visited April 23, 2020). 58 See Marguerite Reardon, Super Bowl 2019: Are the Wireless Networks Up to Snuff?, CNET (Feb. 1, 2019), https://www.cnet.com/news/super-bowl-2019-are-the-wireless-networks-up-to-snuff/. 59 See Monica Alleven, Verizon Plays Up 5G for Super Bowl, FIERCEWIRELESS (Jan. 30, 2020), https://www.fiercewireless.com/wireless/verizon-plays-up-5g-for-super-bowl. 60 See AT&T Reinvents the Live Sports Experience, AT&T (Sept. 5, 2019), https://about.att.com/story/2019/5g_at_att_stadium.html.
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Strong competition in the wireless marketplace continues to drive operators to innovate
and implement new technologies to improve their networks, services, and coverage. Wireless technologies depend on spectrum, and timely access to spectrum resources is critical when it comes to ensuring that wireless network operators can deploy new and advanced networks and technologies. As the industry works with policymakers and federal agencies to find new spectrum to bring to market, wireless providers are also investing heavily to make more efficient use of the spectrum holdings they have today. With the explosion of mobile data growth, wireless providers must look at all strategies to increase network capacity—incorporating new, more efficient wireless technologies into their networks and deploying densified infrastructure.61
Thanks to those efforts, America’s wireless providers have become 42 times more efficient since
2010, as measured by the amount of data consumed per megahertz of spectrum licensed to
mobile broadband providers.
61 See CTIA’s Wireless Industry Indices Report at 7.
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Source: Tom Sawanobori, Demand for Wireless Requires More and Efficient Use of Spectrum, CTIA (July 9, 2019), https://www.ctia.org/news/demand-for- wireless-requires-more-and-efficient-use-of-spectrum.
The wireless industry continues to improve the 4G wireless experience, and that includes continued enhancements to spectral efficiency. But the quest for greater efficiency continues with 4G technologies and is further enhanced with 5G innovations. Wireless providers will continue to make efficient use of spectrum assets in order to ensure they deliver the wireless experience that consumers demand—and help ensure that the United States continues to lead the world in wireless innovation as we transition to 5G. Many such operators are currently
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deploying a host of new technologies to, among other things, improve spectrum utilization,
reduce latency, lower deployment costs, and enhance wireless service quality.62
Massive MIMO. One such technology being deployed is multiple-input and multiple-
output (“MIMO”). Using MIMO for sending and receiving more than one signal simultaneously
using groups of antennas at the transmitter and receiver provides higher throughput and spectral
efficiency.63 Several handsets from multiple manufacturers, including Samsung, Apple, and
Google, support 4x4 MIMO and are commercially available.64 This 5G-precursor technology
expands the capacity of existing 4G networks by increasing the number of data paths between
cell sites and mobile devices, thus enabling greater efficiency from providers’ spectrum.65
Massive MIMO, an extension of MIMO, contains a larger number of transmitters, which enables
higher performance of a single data signal and hence a much higher boost in capacity and
throughput. Beamforming, for example, allows the signal to be maximized toward the mobile
receiver unit using accurate and narrow beams, and is capable of delivering data to multiple
subscribers simultaneously.66 Nokia has noted that this “spatial reuse of frequencies enables
high spectral efficiency, resulting in greatly increased system capacity.”67 Massive MIMO is the
62 See Michael Kratsios, Emerging Technologies and Their Expected Impact on Non-Federal Spectrum Demand Report, White House Office of Science and Technology Policy, at 1-6 (May 2019), https://www.whitehouse.gov/wp-content/uploads/2019/05/Emerging-Technologies-and-Impact-on-Non- Federal-Spectrum-Demand-Report-May-2019.pdf (“White House Emerging Technologies Report”). 63 See id. at 22-23. 64 Chris Hoffman, What is 4x4 Mimo and Does My Smartphone Need it?, HOW-TO GEEK (Nov. 7, 2018), https://www.howtogeek.com/394266/what-is-4x4-mimo-and-does-my-smartphone-need-it/. 65 See White House Emerging Technologies Report at 11. 66 See id. at 22-23. 67 Comments of Nokia, GN Docket No. 17-183, at 14 (filed Oct. 2, 2017).
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key technology for the use of millimeter wave spectrum bands for advanced wireless services.68
Samsung’s Massive MIMO, for example, creates sharp beams and extends networks’ coverage
by almost three times using a large number of antenna elements. This helps operators’ capital
expenditure investments go further by reducing the number of sites and equipment that must be
deployed and maintained to cover a fixed geographic area and customer base. It also provides
various beam scan range options so operators can selectively choose the best option for a certain
target deployment area.69
Increasing Spectrum Utilization. Wireless manufacturers and providers are
collaborating to further increase the spectral efficiencies gained by refarming spectrum and
transitioning to newer generations of wireless technology. Ericsson has deployed what it
describes as Dynamic Spectrum Sharing (“DSS”) to enable the use of the same spectrum
resources for both 4G and 5G technologies in order to enable the “best utilization of spectrum
band assets.”70 This technique will accelerate the transition to 5G by enabling 4G and 5G to use
the same blocks of licensed spectrum. Instead of manually refarming spectrum from 4G LTE to
5G, which often results in one of the two networks being more congested than the other, it will
allow wireless providers to “dynamically allocate some of their existing 4G LTE spectrum to
68 See White House Emerging Technologies Report at 23-24; Cardona, N., Correia, L.M. & Calabuig, D., Key Enabling Technologies for 5G: Millimeter-Wave and Massive MIMO, INT. J. WIRELESS INFO. NETWORKS, 24, 201–203 (2017), https://link.springer.com/article/10.1007/s10776-017-0366-z. 69 Massive MIMO Units: Fast Track for Outstanding 5G Experience Everywhere, SAMSUNG, https://www.samsung.com/global/business/networks/products/radio-access/massive-mimo-radio/ (last visited Mar. 29, 2020). 70 Ericsson Spectrum Sharing, ERICSSON, https://www.ericsson.com/en/portfolio/networks/ericsson- radio-system/radio-system-software/ericsson-spectrum-sharing (last visited Mar. 24, 2020).
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5G.”71 It will also allow providers to use existing 5G New Radio (“5G NR”)-capable radios to deliver 5G services with just “a software upgrade.”72 This will dramatically speed up the spectrum refarming process as providers transition their networks from legacy services to 5G.73
As part of their network transition to 5G, Verizon and AT&T are both planning to deploy DSS in
2020.74
NR-Light. 5G NR-Light (a/k/a “NR-Lite”) is another technology being developed to address new use cases with IoT-type requirements that cannot be met by enhanced machine-type communications (“eMTC”) and narrowband IoT (“NB-IoT”), including higher data rates, better reliability, lower latency, reduced cost and complexity, longer battery life, and wider coverage.
NR-Light can deliver 100 Mbps download speeds using only 10 or 20 megahertz of spectrum.75
Use cases are focused on enabling a single network to serve all uses in an industrial environment, with reduced latency for remote drone operation, cooperative farm machinery, time-critical sensing, and remote vehicle operation.76
71 Sue Marek, Marek’s Take: Dynamic Spectrum Sharing May Change the 5G Deployment Game, FIERCEWIRELESS (Apr. 19, 2019), https://www.fiercewireless.com/wireless/marek-s-take-dynamic- spectrum-sharing-may-change-5g-deployment-game. 72 Id. 73 Sean Kinney, DSS Lets Operators Sidestep ‘Need To Re-Farm’ Spectrum for 5G, RCR WIRELESS (Aug. 19, 2019), https://www.rcrwireless.com/20190819/5g/dss-spectrum-5g-ericsson. 74 Bevin Fletcher, AT&T Expects Major 5G Handset Upgrade Cycle to Start in 2020, Exec Says, FIERCEWIRELESS (Nov. 13, 2019), https://www.fiercewireless.com/operators/at-t-expects-2020-start- major-5g-handset-upgrade-cycle-exec-says (“Like competitor Verizon, AT&T in the future plans to use dynamic spectrum sharing (DSS) technology, which [AT&T SVP of Wireless Technology and Experience Delivery Igal] Elbaz said the carrier is now starting to test and plans to deploy in 2020.”). 75 3GPP Charts the Next Chapter of 5G Standards, QUALCOMM (Dec. 13, 2019), https://www.qualcomm.com/news/onq/2019/12/13/3gpp-charts-next-chapter-5g-standards. eMTC is a narrowband, cellular, low-power, wide area network radio technology standard to support machine-to- machine and similar IoT applications. NB-IoT is a similar IoT radio standard. eMTC requires greater bandwidth than NB-IoT, but it supports greater data throughput as well. 76 Amitabha Ghosh et al., 5G Evolution: View on 5G Cellular Technology Beyond 3GPP Release 15, IEEEAccess, Vol. 7, 2019, at 127647-48 (Sept. 19, 2019),
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Network Function Virtualization. Software Defined Networks (“SDNs”) and Network
Function Virtualization (“NFV”) are additional key features that allow operators to deploy and manage a more flexible, scalable, and powerful core network.77 This advancement will be
achieved by decoupling software from hardware. These technologies enable more efficient,
timely, and cost-effective deployment of software onto commercial off-the-shelf hardware.
These tools allow wireless providers to quickly respond and adapt to changes in business demand while also reducing operating and capital costs.78 SDN, in effect, gives network operators
centralized control over the network, and NFV allows the network to be built and operated by
software. The 5G SDN architecture enables network slicing, an end-to-end feature that will
allow the network to simultaneously support a diverse set of use cases and performance
requirements.79 Both AT&T and Verizon have plans underway to virtualize more than half of
their networks this year.80 In preparation for its 5G deployment throughout the United States, T-
Mobile recently completed its virtualized packet core buildout with Cisco, giving it the ability to
https://ieeexplore.ieee.org/stamp/stamp.jsp?arnumber=8826541 (“5G Evolution: View on 5G Cellular Technology Beyond 3GPP Release 15”). 77 Gianfranco Nencioni et al., Orchestration and Control in Software-Defined 5G Networks: Research Challenges, WIRELESS COMMUNICATIONS AND MOBILE COMPUTING (2018), https://www.hindawi.com/journals/wcmc/2018/6923867/ (“Orchestration and Control in Software- Defined 5G Networks”). 78 John Hanahan, How SDN and NFV Technologies Are Transforming Network Management, EQUINIX (Jan. 17, 2019), https://blog.equinix.com/blog/2019/01/17/how-sdn-and-nfv-technologies-are- transforming-network-management/. 79 Orchestration and Control in Software-Defined 5G Networks. 80 See Mike Robuck, AT&T on Target for Virtualizing 75% of Its Network by 2020, FIERCETELECOM (Jan. 3, 2020), https://www.fiercetelecom.com/telecom/at-t-target-for-virtualizing-75-its-network-by- 2020; Matt Kapko, Verizon CEO: Network Virtualization Is 60% Complete, SDXCENTRAL (Dec. 11, 2019), https://www.sdxcentral.com/articles/news/verizon-ceo-network-virtualization-is-60- complete/2019/12/.
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“launch new services with automated deployments, spending minutes to deploy what used to
take months.”81
Virtualized RAN. Another emerging technology, Virtualized Radio Access Network
(“vRAN”), extends network virtualization to the RAN. Specifically, it decouples software from
hardware, thus allowing operators to deploy RAN functionality in software that runs on
commercial off-the-shelf hardware. vRAN is based on the principles of NFV, and allows
wireless providers to cost-effectively scale capacity to meet rising traffic demands.82 A related
technology, Cloud-based RAN (“cRAN”), pools baseband processing for multiple cell sites at
central locations and connects each hub to its remote radio heads via a fiber fronthaul network.83 cRAN architecture enables a new class of time-sensitive wireless services, including orchestration and self-optimizing networks, and allows mobile operators to pool resources, reuse infrastructure, simplify network operations, reduce energy consumption, intelligently scale computing resources, and reduce capital and operating costs. The technology also allows mobile operators to harness the software and hardware decoupling benefits of vRAN to develop and deploy innovative end-to-end services quickly.84 The wireless industry is also developing Open-
RAN (“oRAN”), which combines the attributes of vRAN with open-architecture. oRAN will enable RAN modules from different vendors to interoperate at the same cell site, thus allowing
81 Press Release, T-Mobile Launches World’s Largest Virtual Packet Core with Cisco in Preparation for 5G, T-Mobile (Sept. 12, 2018), https://t-mo.co/2UJeVRM. 82 vRAN: The Next Step in Network Transformation, WIND RIVER—AN INTEL COMPANY, at 2 (2017) https://builders.intel.com/docs/networkbuilders/vran-the-next-step-in-network-transformation.pdf. 83 See White House Emerging Technologies Report at 18-19. 84 Imad Al-Samman et al., Heterogeneous Cloud Radio Access Networks: Enhanced Time Allocation for Interference Mitigation, WIRELESS COMMUNICATIONS AND MOBILE COMPUTING (2018), https://www.hindawi.com/journals/wcmc/2018/2084571/.
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operators to deploy a mix of RAN equipment from various vendors rather than relying on a
single vendor per market. Development and trials of oRAN are taking place and will be further
demonstrated by various parties as the technology develops.
Integrated Access and Backhaul. Another technology being developed, Integrated
Access and Backhaul (“IAB”), will reduce acquisition and deployment costs by using wireless
spectrum for the backhaul connection of base stations.85 IAB nodes, which use the same
spectrum for access and backhaul to create a hierarchical wireless multi-hop network between sites, can be deployed to resolve coverage gaps and provide backhaul where fiber deployment would be cost-prohibitive.86 Indeed, using high throughput millimeter wave spectrum, IAB can
function as a fiber replacement, which may become increasingly important as wireless operators
continue to densify their networks to meet business and consumer demand. For example,
Verizon estimates that IAB could be used for 10-20 percent of its 5G sites.87 Another major
advantage of IAB is that it allows operators to reuse the same spectrum and antennas for both
access and backhaul, increasing spectrum utilization and reducing costs.88
As shown here, even as the industry works with policymakers and federal agencies to
find new spectrum to bring to market, wireless providers are investing heavily to make more
efficient use of the spectrum holdings they have today. U.S. wireless providers are continually
85 5G Evolution: View on 5G Cellular Technology Beyond 3GPP Release 15 at 127644. 86 Id. 87 Mike Dano, Verizon to Use ‘Integrated Access Backhaul’ for Fiber-Less 5G, LIGHTREADING (Oct. 10, 2019), https://www.lightreading.com/mobile/5g/verizon-to-use-integrated-access-backhaul-for-fiber-less- 5g/d/d-id/754752. 88 Breaking the Wireless Barriers to Mobilize 5G NR mmWave, QUALCOMM (Jan. 2019), https://www.qualcomm.com/media/documents/files/webinar-breaking-the-wireless-barriers-to-mobilize- 5g-nr-mmwave.pdf.
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improving their networks, as well as refarming existing spectrum assets and deploying new
frequencies quickly,89 and will continue to make efficient use of spectrum assets to ensure that
they deliver the wireless experience that consumers demand.90
A number of existing and new entrants are leveraging existing networks and creating
their own competing networks, providing competition in the wireless ecosystem to the benefit of
consumers.
Cable Companies. Cable companies continue to invest as infrastructure-based Mobile
Virtual Network Operators (“MVNOs”) and remain well positioned to deploy fixed and mobile
5G operations and compete directly with mobile network operators on a nationwide basis. The
dense hybrid fiber-coaxial networks of Comcast, Charter, Altice, and others create last-mile
footprints that will become increasingly valuable strategic assets as reliance on small cells
increases.91 Altice, for instance, has already deployed 20,000 LTE small cells that sit atop its
wired network in Long Island, New York.92 The Charter and Comcast partnership agreement
also permits the cable operators to share each other’s operating platforms, further accelerating
mobile broadband deployment.93 These companies, along with Mediacom Communications
89 Smarter and More Efficient: How America’s Wireless Industry Maximizes Its Spectrum. 90 Id. 91 See, e.g., Mari Silbey, Cisco: Cable Nets Can Backhaul Small Cells, LIGHT READING (Oct. 18, 2017), https://www.lightreading.com/cable/docsis/cisco-cable-nets-can-backhaul-small-cells/d/d-id/737372. 92 See Mike Dano, Charter Is Preparing to Build a Wireless Network, LIGHT READING (Sept. 13, 2019), https://www.lightreading.com/mobile/4g-lte/charter-is-preparing-to-build-a-wireless-network/d/d- id/754100. 93 See Press Release, Charter, Comcast and Charter Announce Mobile Operating Platform Partnership, Charter (Apr. 20, 2018), https://corporate.charter.com/newsroom/comcast-charter-announce-mobile- operating-platform-partnership.
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Corporation, the nation’s fifth largest cable operator with roughly 2.7 million total customers, have participated in wireless service field testing in the 3.5 GHz Citizens Broadband Radio
Service (“CBRS”) band.94 Analysts believe that “a 2x20 MHz swath of CBRS spectrum” could be more than enough for cable companies to reduce their reliance on existing wireless networks and build out their own competing wireless networks on the edge of their wired footprints.95
Quickly growing subscriber bases illustrate how cable companies’ alternative offerings bring a new competitive element to the wireless industry. Comcast’s Xfinity Mobile added
261,000 wireless subscribers as of Q4 2019.96 This growth marks the company’s largest gain yet in a single quarter and puts it past two million wireless customers in total.97 Nearly 288,000 subscribers joined Charter Spectrum Mobile in Q4 2019, growing Charter’s wireless subscription base to 1.1 million subscribers.98 Altice introduced its own MVNO offering in September 2019 and entered into a national roaming contract with AT&T.99 Altice also continues to deploy LTE
94 See, e.g., Mike Dano, Charter Tests Massive Private LTE Network in 3.5GHz CBRS Spectrum, LIGHT READING (May 29, 2019), https://www.lightreading.com/services/managed-services/charter-tests- massive-private-lte-network-in-35ghz-cbrs-spectrum/d/d-id/751807; Mike Dano, Cable Op Midco Hints at Interest in CBRS Spectrum Auction, LIGHT READING (Feb. 19, 2020), https://www.lightreading.com/4g-3g-wifi/cable-op-midco-hints-at-interest-in-cbrs-spectrum-auction/d/d- id/757606; Monica Alleven, Comcast Seeks New Experimental CBRS License, FIERCEWIRELESS (Mar. 29, 2019), https://www.fiercewireless.com/wireless/comcast-seeks-new-experimental-cbrs-license. 95 Mike Dano, Anticipation Mounts for 3.5GHz Midband Spectrum Auction, LIGHT READING (Jan. 13, 2020), https://www.lightreading.com/mobile/5g/anticipation-mounts-for-35ghz-midband-spectrum- auction/d/d-id/756761. 96 See Monica Alleven, Comcast Adds 261,000 Wireless Subscribers in Q4, Its Largest Gain Yet, FIERCEWIRELESS (Jan. 23, 2020), https://www.fiercewireless.com/wireless/comcast-adds-261-000- wireless-subscribers-q4-its-largest-gain-yet. 97 See id. 98 See Linda Hardesty, Charter’s Mobile Service Crosses 1M Subscriber Mark, FIERCEWIRELESS (Feb. 3, 2020), https://www.fiercewireless.com/operators/charter-s-mobile-service-crosses-1-million-subscriber- mark. 99 See Mike Farrell, Altice USA Launches Wireless Service, MULTICHANNEL NEWS (Sept. 5, 2019), https://www.multichannel.com/news/altice-usa-launches-wireless-service.
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small cells across its own wired network,100 and Altice Mobile’s nascent subscriber base has already increased from 15,000 as of November 2019, three months after its launch, to 54,000 by year-end 2019.101
DISH Network. 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 of serving 70 percent of the U.S. population by June 2023.102 DISH has committed to bringing full, standalone 5G to America, built upon a secure, oRAN architecture, delivering innovation to benefit both consumers and enterprises.103 The company will also soon begin serving Boost customers while aggressively growing the business as a new competitor, committing to bring lower prices, greater choice, and more innovation to consumers.104
Fixed Wireless Providers. The growth of fixed wireless providers also exemplifies the competitive nature of the industry.105 These technologies can provide gigabit residential speeds
100 Linda Hardesty, Welcome to Wireless: Apple Makes Demands on Comcast and Charter, FIERCEWIRELESS (June 14, 2019), https://www.fiercewireless.com/wireless/welcome-to-wireless-apple- makes-demands-comcast-and-charter; Mike Dano, Charter Is Preparing to Build a Wireless Network, LIGHT READING (Sept. 13, 2019), https://www.lightreading.com/mobile/4g-lte/charter-is-preparing-to- build-a-wireless-network/d/d-id/754100. 101 See Linda Hardesty, Altice Mobile Garners Its First 15,000 Subs and $3M in Revenue, FIERCEWIRELESS (Nov. 6, 2019), https://www.fiercewireless.com/operators/altice-mobile-garners-its- first-15-000-subs-and-3m-revenue. See also Alan Breznick, Altice USA Makes Mobile, Gigabit, M&A Waves, LIGHT READING (Feb. 13, 2020), https://www.lightreading.com/cable-video/altice-usa-makes- mobile-gigabit-manda-waves-/d/d-id/757484. 102 See Press Release, DISH to Become National Facilities-based Wireless Carrier (Jul. 26, 2019), https://www.prnewswire.com/news-releases/dish-to-become-national-facilities-based-wireless-carrier- 300891740.html. 103 See Mike Dano, Dish Network Mostly Mum on T-Mobile's Big Day, LIGHT READING (Apr. 1, 2020), https://www.lightreading.com/5g/dish-network-mostly-mum-on-t-mobiles-big-day/d/d-id/758615. 104 See Press Release, DISH to Become National Facilities-based Wireless Carrier (Jul. 26, 2019), https://www.prnewswire.com/news-releases/dish-to-become-national-facilities-based-wireless-carrier- 300891740.html. 105 For example, Verizon is developing next-generation 5G fixed-wireless services to complement its mobile wireless offerings. See Mike Dano, Verizon Relaunched Fixed Wireless Service with 5G NR, DIY
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and offer flexible-cost plans. As one example, Starry continues to roll out its pre-standard 5G,
point-to-multipoint fixed wireless technology that it says will deliver gigabit-capable broadband
to the home.106 The company currently advertises a service capable of delivering 200 Mbps
speeds.107 The company is now focusing on expeditiously deploying this service to its rapidly
growing subscriber base of 1.5 million.108 By acquiring more than one hundred 24 GHz licenses,
the company will now also be able to wirelessly connect nearly 40 million households, almost
doubling the number of households that it previously aimed to reach.109
Tarana Wireless is another fixed wireless provider that plans to offer a gigabit broadband
service capable of overcoming certain propagation and attenuation concerns. Tarana relies on a
technology that “enable[s] long-distance wireless internet connections [using primarily
unlicensed spectrum] that hold steady even when physical objects such as buildings or trees are
in a signal’s path.”110 AT&T, Deutsche Telecom AG, EchoStar Corporation, and others have
infused more than $100 million in the company over the past two years.111 This recent capital
Installs, LIGHT READING (Oct. 21, 2019), https://www.lightreading.com/mobile/5g/verizon-relaunches- fixed-wireless-service-with-5g-nr-diy-installs/d/d-id/755026. 106 See Jon Brodkin, Starry Aims to Bring Its $50, 200Mbps Broadband to 25 More US States, ARS TECHNICA (June 19, 2019), https://arstechnica.com/information-technology/2019/06/starry-aims-to-bring- its-50-200mbps-broadband-to-25-more-us-states/ (“Starry aims to bring its $50, 200Mbps broadband to 25 more US states”). 107 See Internet, STARRY, https://starry.com/internet (last visited Mar. 20, 2020). 108 See Lucas Matney, Wireless Broadband Startup Starry Files to Raise Up to $125 million, TECHCRUNCH (Apr. 25, 2019), https://techcrunch.com/2019/04/25/wireless-broadband-startup-starry- files-to-raise-up-to-125-million/; see also Starry aims to bring its $50, 200Mbps broadband to 25 more US states. 109 See Starry Aims to Bring its $50, 200Mbps Broadband to 25 More US states. 110 Caleb Henry, EchoStar, Khosla Ventures Invest $60 Million in Wyler-backed Broadband Venture, SPACENEWS (Mar. 22, 2019), https://spacenews.com/echostar-khosla-ventures-invest-60-million-in- wyler-backed-broadband-venture/. 111 See id.
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influx will permit the company to expand its existing network, demonstrating “broadband connectivity to over 100 sites—mostly non-line of sight—at distances up to 15 km from a single sector base-node.”112
Satellite Companies. Satellite companies—primarily operating just hundreds of kilometers from the Earth in low-Earth orbit (“LEO”)—are also aiming to provide wireless services that can meet the needs of some consumers, including in traditionally unserved and underserved areas. For example, Space Exploration Holdings (“SpaceX”) has launched more than 350 satellites in less than one year and is expected to commence its commercial broadband offering this year,113 and Telesat Canada (“Telesat”) continues to experiment with prototypes.114
Once fully deployed, SpaceX and Telesat are seeking to offer added throughput capacities of
23.7 Tbps and 2.66 Tbps, respectively, and a wide range of broadband and communications services to users in hard-to-reach areas worldwide.115 Amazon.com Services also recently proposed its own 3,236-satellite constellation that plans to bring “high-capacity, low-latency broadband to tens of millions of unserved and underserved consumers throughout the United
112 See Press Release, Tarana Secures first $24 Million of New $60 Million Equity Financing, Tarana Wireless (Feb. 20, 2020), https://www.businesswire.com/news/home/20200220005732/en/Tarana- Secures-24-Million-New-60-Million. 113 See Jackie Wattles, Amid Pandemic, Spacex Launches Another Batch of Starlink Satellites, CNN (Mar. 18, 2020), https://www.cnn.com/2020/03/18/tech/spacex-launch-starlink-coronavirus-scn/index.html; Caleb Henry, SpaceX Launches 60 Starlink Satellites, Begins Constellation Buildout, SPACENEWS (May 23, 2019), https://spacenews.com/spacex-launches-60-starlink-satellites-begins-constellation-buildout/; Inigo del Portillo, et al., A Technical Comparison of Three Low Earth Orbit Satellite Constellation Systems to Provide Global Broadband, 69th International Astronautical Congress 2018, at 11 (Oct. 1, 2018), http://www.mit.edu/~portillo/files/Comparison-LEO-IAC-2018-slides.pdf. 114 Kendall Russell, Telesat Celebrates Launch of Its First LEO Satellite, VIA SATELLITE (Jan. 12, 2018), https://www.satellitetoday.com/business/2018/01/12/telesat-celebrates-launch-first-leo-satellite/. 115 See Inigo del Portillo, et al., A Technical Comparison of Three Low Earth Orbit Satellite Constellation Systems to Provide Global Broadband, 69th International Astronautical Congress 2018, at 11 (Oct. 1, 2018), http://www.mit.edu/~portillo/files/Comparison-LEO-IAC-2018-slides.pdf.
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States and around the world.”116
Mobile-Satellite Service (“MSS”) operators also continue to expand their presence in the
United States. Iridium Communications replenished its original constellation by successfully deploying all 75 of its second-generation “Next” satellites.117 The fleet supplies reliable connections for the aviation, maritime, land-mobile, and IoT-related industries, including essential safety services.118 Other MSS providers such as Globalstar and Omnispace intend to deploy terrestrial satellite networks that could introduce competition in the wireless market from terrestrial service providers.119 Globalstar holds authority to use an 11.5-megahertz portion of its
MSS spectrum in the S-band frequencies (2483.5-2495 megahertz) for a terrestrial low-powered service.120 The Third Generation Partnership Project (“3GPP”) recently approved a 5G variant of Globalstar’s Band 53, which enables the company to serve compatibly with small cell networks while acting as a “traffic channel or as an anchor for other licensed or unlicensed bands
116 Letter from Mariah Dodson Shuman, Corporate Counsel, Amazon, to Marlene H. Dortch, Secretary, FCC, IBFS File No. SAT-LOA-20190704-00057 (filed Feb. 24, 2020); see also Caleb Henry, Amazon Lays Out Constellation Service Goals, Deployment And Deorbit Plans to FCC, SPACENEWS (July 8, 2019), https://spacenews.com/amazon-lays-out-constellation-service-goals-deployment-and-deorbit- plans-to-fcc/. 117 See Caleb Henry, Iridium Ends Legacy Satellite Service, Switches All Traffic to Next Fleet, SPACENEWS (Feb. 6, 2019), https://spacenews.com/amazon-lays-out-constellation-service-goals- deployment-and-deorbit-plans-to-fcc/. 118 See Solutions, IRIDIUM, https://www.iridium.com/solutions/ (last visited Mar. 20, 2020). 119 See generally Terrestrial Use of the 2473.5-2495 MHz Band for Low-Power Mobile Broadband Networks, et al., Report and Order, 31 FCC Rcd 13801 (2016) (“2473.5-2495 MHz Band Report and Order”); Mobile Satellite Ventures Subsidiary LLC, Application for Minor Modification of Space Station License for AMSC-1, et al., Order and Authorization, 19 FCC Rcd 22144 (2004); Bevin Fletcher, LigadoOffers Immediate Opportunity for FCC, Verizon, T-Mobile – Analyst, FIERCEWIRELESS (Nov. 25, 2019), https://www.fiercewireless.com/regulatory/ligado-offers-immediate-opportunity-for-fcc-verizon-t- mobile-analyst; Redefining Connectivity for the 21st Century, Omnispace, https://omnispace.com/wp- content/uploads/2019/04/Omnispace_Overview_Brochure_SP2.pdf (last visited Mar. 3, 2020). 120 See generally 2473.5-2495 MHz Band Report and Order.
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in 5G networks.”121 Omnispace also continues to tout its 5G MSS service that will provide seamless connectivity via a single global network, without roaming charges and rate complexities. To date, the company operates one satellite in orbit and, like Globalstar, will use 2
GHz frequencies.122
Satellites the size of wine bottles also seek to deliver low-cost IoT connectivity to the low-power-consumption devices that myriad industries use to promote precision agriculture, increase industrial efficiency, track assets, and connect cars, among other things.123 Kepler
Communications, for example, received Commission authority to operate a 140-satellite constellation and to date has deployed two satellites that can transmit near-100 Mbps connectivity.124 The Commission’s concurrent initiation of multiple non-geostationary satellite orbit processing rounds reveals that small satellite operators, such as Hiber, Myriota Pty Ltd,
Kinéis, and Swarm Technologies, are also eager to offer competitive IoT products in the United
States.125 Swarm, for example, will support Ford Motor Company’s efforts to build a “cloud-
121 Jeffrey Hill, Globalstar 5G Variant Band Receives 3GPP Approval, VIA SATELLITE (Mar. 24, 2020), https://www.satellitetoday.com/5g/2020/03/24/globalstar-5g-variant-band-receives-3gpp-approval/. 122 See License, Omnispace LLC, ELS File No. 0038-EX-CM-2016 (granted Nov. 7, 2016); Omnispace Supports WRC-19 Decisions on Sharing of Spectrum Resources, PR Newswire (Dec. 12, 2019), https://www.prnewswire.com/news-releases/omnispace-supports-wrc-19-decisions-on-sharing-of- spectrum-resources-300973755.html. 123 See, e.g., What are SmallSats and CubeSats?, NASA (Feb. 26, 2015), https://go.nasa.gov/3dtQMqy. 124 See Kepler Communications Inc. Petition for Declaratory Ruling to Grant Access to the U.S. Market for Kepler’s NGSO FSS System, Order and Declaratory Ruling, 33 FCC Rcd 11453 (2018); see also Annamarie Nyirady, Kepler Delivers First Arctic High-Bandwidth Satellite Service, VIA SATELLITE (Nov. 8, 2019), https://www.satellitetoday.com/broadband/2019/11/08/kepler-delivers-first-arctic-high- bandwidth-satellite-service/. 125 See, e.g., Satellite Policy Branch Information Myriota Pty. Ltd. Petition Accepted For Filing IBFS File No. SAT-PDR-20190328-00020 Cut-Off Established For Additional NVNG MSS Applications Or Petitions For Operations In the 399.9-400.05 MHz and 400.15-401 MHz Bands, Public Notice, 34 FCC Rcd 7185 (2019); Satellite Policy Branch Information Myriota PTY. LTD. Petition Accepted For Filing, IBFS File No. SAT-PDR-20191118-00135 Cut-off Established For Additional NVNG MSS Applications
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based platform that connects the different components of mobility systems, including vehicles, mass transit, city infrastructure, and service providers.”126
Competition is intensifying as companies expand their service offerings to compete in an ever more connected world. As documented in the media, the increasingly competitive wireless marketplace has prompted providers to think creatively to attract and retain customers.127
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.128 Many
Verizon wireless plans, for example, come with a year of Disney+ streaming service at no
Or Petitions For Operations In The 137-138 MHz and 148-150.5 MHz Bands, Public Notice, DA 20-238 (rel. Mar. 5, 2020). 126 Doug Mohney, #CES2019 – Swarm Technologies and the Ford Connection, SPACE IT BRIDGE (Jan. 11, 2019), https://www.spaceitbridge.com/ces2019-swarm-technologies-and-the-ford-connection.htm. 127 Monica Alleven, Q4 summary: T-Mobile Revels in High Industry-Wide Churn, FIERCEWIRELESS (Feb. 27, 2020), https://www.fiercewireless.com/operators/q4-summary-t-mobile-revels-high-industry-wide- churn (“If there’s one thing that stood out about the fourth quarter in terms of industry metrics, it was the high level of competition by way of promotions and other activities among the biggest carriers in the U.S.”). 128 For example, Cellular One offers affordable bring-your-own-device plans with unlimited talk and text, flex pay-as-you-go plans, and more. See Cellular One Plans, CELLULAR ONE ONLINE, https://www.cellularoneonline.com/plans (last visited April 23, 2020).
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cost.129 AT&T wireless offers plans with complementary access to HBO’s streaming service.130
T-Mobile similarly offers its customers Netflix as part of certain service plans.131
Today, America’s wireless customers get the most value for their money when compared
to 36 peer countries around the world, including G7 countries, according to a study from NERA
Economic Consulting.132 NERA compiled data on 1,554 wireless plans from 213 wireless providers and derived the value offered by each country’s wireless providers by determining the difference between the expected cost of service and the actual cost subscribers pay. The data included key factors like minutes, amount of data included, SMS inclusion, number of lines, network coverage, download speeds, and price. NERA also gathered country-specific attributes like geographic size and per capita income, as these factors can drive differences in cost and value considerations. Each country NERA studied received a score for its position in different country peer groups. Combining the scores of each peer set, the United States ranked first in value proposition. Indeed, NERA found that U.S. consumers save nearly $10 billion per year due to the superior value that U.S. wireless providers offer.133
129 Disney+ on Us for the First Year, VERIZON, https://www.verizonwireless.com/solutions-and- services/disneyplus/ (last visited Mar. 25, 2020). 130 HBO with AT&T Unlimited Plus Enhanced and AT&T Choice Enhanced, AT&T, https://www.att.com/support/article/wireless/KM1261921 (last visited Mar. 25, 2020). 131 Netflix is Included with Your Magenta® Family Plan, T-MOBILE, https://www.t- mobile.com/offers/netflix-on-us (last visited Apr. 21, 2020). 132 Christian M. Dippon and Jason Claman, A Comparison of the Mobile Wireless Value Proposition, NERA ECONOMIC CONSULTING (Mar. 2, 2020), https://api.ctia.org/wp-content/uploads/2020/03/Final- Study.pdf. 133 U.S. Wireless Consumers Get the Most Value for their Money, CTIA (Mar. 2, 2020), https://www.ctia.org/news/report-united-states-wireless-consumers-get-the-most-value-for-their-money.
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The value to U.S. consumers is also reflected in wireless operators’ cash flows and other
key metrics. The average monthly revenue per active revenue generating unit (“ARPU”) fell 2.1
percent from 2017 to 2018 ($38.66 to $37.85).134 Indeed, quarterly postpaid ARPU of the
nationwide providers has declined since 2015, falling by about 15 percent over that period.135
Furthermore, the Bureau of Labor Statistics’ Consumer Price Index for wireless telephone
services in U.S. cities fell from an annual average of 62.4 in 2010 to 46.4 in 2019—more than a
25 percent decrease.136
The aggressively competitive state of the wireless communications marketplace is also
reflected in advertising spend. In 2018, T-Mobile spent $1.7 billion, AT&T spent $5.362 billion,
134 CTIA’s Wireless Industry Indices Report at 8. 135 Mike Dano, The US Wireless Market in 10 Charts, LIGHT READING (June 14, 2019), https://www.lightreading.com/financial/the-us-wireless-market-in-10-charts/d/d-id/752180. 136 Wireless telephone services in U.S. city average, all urban consumers, not seasonally adjusted: 2010 – 2020, U.S. Bureau of Labor Statistics, https://data.bls.gov/timeseries/CUUR0000SEED03?output_view=data (last visited Mar. 25, 2020).
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U.S. Cellular spent $230 million, Verizon spent $2.682 billion, and Comcast spent $6.122 billion
promoting their services, including their wireless services, differentiating their offerings, and
communicating their value to consumers.137 And in 2019, the wireless industry also vigorously advertised the additional value that 5G in particular would bring to consumers. “Verizon has spent an estimated $86 million [in 2019] on TV ads with 5G in the title, while AT&T has spent roughly $90 million on ads with 5G in the title.”138 In just the Fall of 2019, T-Mobile spent $28
million on television advertising for its 5G campaign.139
III. COMPETITION AND INNOVATION IN THE WIRELESS SECTOR ARE CREATING IMMENSE OPPORTUNITY AND SPARKING U.S. LEADERSHIP IN THE NEW 5G ECONOMY.
Competition and innovation in the wireless sector are supporting consumers’ mobile-first lifestyle, which is creating opportunities across industry sectors. In the United States, mobile device and smartphone adoption is at an all-time high. As noted above, roughly 96 percent of
American adults and teens have cellphones,140 and “[t]he share of Americans that own
smartphones is now 81 percent, up from just 35 percent . . . in 2011.”141 Indeed, one in five
Americans is “mobile only.”142 Reliance on smartphones for internet access is most common
among young adults, minority groups, and lower-income Americans. By 2025, it is estimated
137 Leading National Advertisers 2019 Index, AD AGE (June 24, 2019), https://adage.com/article/datacenter/ad-age-leading-national-advertisers-2019-index/2178026. 138 Martha Degrasse, 2019: The Year US Carriers Waged a 5G Advertising War, LIGHT READING (Dec. 30, 2019), https://www.lightreading.com/mobile/5g/2019-the-year-us-carriers-waged-a-5g- advertising-war/d/d-id/756400. 139 Id. 140 See, supra, page 4. 141 Mobile Fact Sheet, PEW RESEARCH CENTER (June 12, 2019), https://www.pewresearch.org/internet/fact-sheet/mobile/. 142 Id.
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that nearly three quarters of all internet users will access the internet solely through their mobile
device.143
Consumers increasingly use their wireless devices to make daily tasks easier—for
example, to buy household essentials, to pay bills, for banking, and for transportation planning—
and to access employment opportunities, healthcare resources, government services, and more.
Apple’s App Store—which offers consumers applications for services ranging from banking and
news, to streaming television, gaming, music, fitness, and much more—is visited by more than
half a billion people each week.144 More than 58 million Americans, for example, have
downloaded the Walmart mobile app onto their smartphones.145 And in the second quarter of
2019 alone, the food delivery app DoorDash was downloaded more than seven million times.146
Businesses are also increasingly dependent on wireless services and devices, such as innovative
IoT-connected devices and drones, to improve performance and streamline operations.
Consumers’ mobile-first lifestyle will create a growing number of opportunities for digital
transformation—for businesses to tie technology to performance, ensure greater agility and
flexibility, and experiment with how to best deliver value to customers, particularly as we
transition to advanced 5G technologies.
143 Lucy Handley, Nearly three quarters of the world will use just their smartphones to access the internet by 2025, CNBC (Jan. 24, 2019), https://www.cnbc.com/2019/01/24/smartphones-72percent-of-people- will-use-only-mobile-for-internet-by-2025.html. 144 See Apple Rings In New Era of Services Following Landmark Year, APPLE (Jan. 8, 2020), https://www.apple.com/newsroom/2020/01/apple-rings-in-new-era-of-services-following-landmark-year/. 145 Ron Shevlin, Walmart Tops Starbucks, Amazon And Uber For Mobile App Adoption Dominance, FORBES (May 20, 2019), https://www.forbes.com/sites/ronshevlin/2019/05/20/walmart-tops-starbucks- amazon-and-uber-for-mobile-app-adoption-dominance/#197707fb7a1c. 146 Julia Chan, Top Food Delivery Apps in the U.S. for Q2 2019 by Downloads, SENSORTOWER (July 12, 2019), https://sensortower.com/blog/top-food-delivery-apps-united-states-q2-2019.
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As the United States transitions to 5G, wireless services will play an even more critical
role in our society. 5G will catalyze transformation across industries to the benefit of the U.S.
economy, businesses, and consumers. As Niklas Heuveldop, President and CEO of Ericsson
North America has stated, “[t]here is no industry out there that is not considering and trying to
understand what 5G can do to transform their business.”147
Transportation. 5G is set to transform every facet of the transportation industry. The percentage of 5G-connected cars is expected to grow from 15 percent in 2020 to 94 percent in
2028.148 The low-latency and high-capacity features of 5G will enable connected vehicles to
keep drivers informed about road and traffic conditions in real time. The 5G NR
communications standard can ensure seamless vehicle-to-everything communications
interoperability,149 which “will make roads safer and more environmentally friendly, while
allowing buses and public transportation to run more efficiently.”150 For example, autonomous
vehicles will ease driver stress and reduce driver error, and wireless-enabled self-driving cars are predicted to save up to 21,700 lives and $447 billion each year.151
147 See Ericsson North America’s Niklas Heuveldop at CTIA 5G Summit (Apr. 5, 2019), https://www.youtube.com/watch?time_continue=227&v=PwAzDIK3UzQ&feature=emb_title. 148 Charles McLellan, Connected Cars: How 5G and Iot Will Affect the Auto Industry, ZDNET (Feb. 3, 2020), https://www.zdnet.com/article/connected-cars-how-5g-and-iot-will-affect-the-auto-industry/. 149 5G NR based C-V2X, QUALCOMM, https://www.qualcomm.com/media/documents/files/5g-nr-based-c- v2x-presentation.pdf (last visited Mar. 22, 2020). 150 Smart vehicles and transport, ERICSSON, https://www.ericsson.com/en/5g/use-cases/smart-vehicles- and-transport (last visited Mar. 9, 2020). 151 5G & Transportation: 5G Take the Wheel, CTIA (Sept. 20, 2018), https://www.ctia.org/news/5g- transportation-5g-take-the-wheel.
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Manufacturing. With 5G, manufacturers will be able to rely on smart equipment and monitor remote operations in real time. Bringing the next generation of wireless connectivity to factories offers the promise of making production lines more nimble and streamlined. With pieces of the production line operating untethered by the typical bulky cables and cords that crowd factory floors, manufacturers are able to be more flexible in adjusting production practices and factory flow, which in turn saves time and makes processes more efficient. Ericsson is partnering with manufacturers in Lewisville, Texas, to create the first fully automated, 5G-
powered smart factory in the United States.152 By 2028, manufacturing will account for nearly a
quarter of total generated revenue in 5G ultra low-latency use cases.153
Agriculture. 5G-enabled agriculture will allow farmers to more easily monitor crops,
weather changes, livestock, and equipment. 5G will support autonomous vehicles for field tasks;
sensors to predict maintenance needs for farming equipment; augmented reality for learning
purposes; and sensors, tracking, and data for efficient logistics. Cisco, for example, is testing 5G
devices useful for agricultural purposes, including 5G-connected collars for dairy cows that help track milking schedules.154 In total, 5.3 percent of global agricultural output is projected to be
5G-enabled by 2035.155
152 Press Release, Ericsson selects Lewisville, Texas for company’s first 5G smart factory in the United States, Ericsson (Sept. 19, 2019), https://www.ericsson.com/en/press-releases/6/2019/ericsson-selects- lewisville-texas-companys-first-5g-smart-factory-united-states. 153 Leo Gergs, 5G and the Factory Floor, ABI RESEARCH (Dec. 13, 2019), https://www.abiresearch.com/blogs/2019/12/13/5g-and-factory-floor/. 154 Matthew Stock, 5G-connected Cows Test Milking Parlor of rhe Future, Reuters (Apr. 11, 2019), https://www.reuters.com/article/us-telecoms-5g-cows/5g-connected-cows-test-milking-parlor-of-the- future-idUSKCN1RN1IY. 155 Karen Campbell et al., The 5G Economy: How 5G Will Contribute to the Global Economy, IHS MARKIT (Nov. 2019), https://www.qualcomm.com/media/documents/files/ihs-5g-economic-impact- study-2019.pdf (“The 5G Economy: How 5G will Contribute to the Global Economy”).
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Education. 5G will support a number of educational use cases, expanding educational
opportunities and increasing educational attainment. For example, 5G’s faster speeds mean a
more robust video experience, which “will get students and faculty closer to a seamless
experience.”156 With the improvements that 5G will bring to devices’ response times,
augmented reality and virtual reality could become essential tools that inspire students and immerse them in their subjects in ways that were never before possible.157 Augmented and
virtual reality can also be used to assist the accessibility community. For instance, these
technologies can allow students with autism or other cognitive disabilities to learn practical
skills—such as crossing a heavily congested street—through simulations in a safe and controlled
setting before attempting them in the real world. 5G networks can also help support more e-
learning by users of all communities across the country, allowing users to acquire additional skill
sets or certifications that can enhance their employability and earning potential.158
Retail. 5G is poised to create a personalized, immersive, connected retail shopping
experience that will create a seamless blend between physical and digital spaces. Qualcomm
projects that in 2035, there will be $1.198 trillion in 5G-enabled global output in wholesale and
retail, which is equal to about 5.1 percent of industry sales.159 Enhanced digital signage from
5G-supported alternative reality could be a key attraction and differentiator for in-person retail
156 Larry Bernstein, How 5G Will Advance Educational Technology on Campus, EDTECH (Jan. 16, 2020), https://edtechmagazine.com/higher/article/2020/01/how-5g-will-advance-educational-technology-campus. 157 Id. 158 Smart Cities: How 5G Can Help Municipalities Become Vibrant Smart Cities, ACCENTURE STRATEGY, at 4 (2017), https://api.ctia.org/wp-content/uploads/2017/02/how-5g-can-help-municipalities- become-vibrant-smart-cities-accenture.pdf. 159 The 5G Economy: How 5G will contribute to the global economy at 4.
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shopping.160 The low-cost, low-power consumption of 5G transmitters161 enables smart shelving for real-time inventory monitoring.162
Healthcare. 5G will transform the way healthcare is provided in the United States.
Geographic separation between patients and providers is often a major impediment to care delivery, but 5G will enable solutions that address the difficulty of providing specialized care over long distances. As Commissioner Jessica Rosenworcel stated, “telemedicine can collapse distance and time and enhance the quality of care while also improving outcomes and lowering costs.”163 Indeed, 5G’s large bandwidth and low latency will enable a data-rich user experience and can support new telemedicine services and tools, such as for remote teleconferencing, monitoring, and diagnosis.164 This will be particularly beneficial for patients in rural and underserved areas.165 5G telemedicine will support real-time, high-quality videos; connect rural area residents to doctors and specialists through telemedicine appointments; and allow doctors to remotely gather data from wearable IoT devices to improve patients’ personalized and preventive
160 This Is 5G Revolutionizing Retail On Intel, Intel, https://www.intel.com/content/www/us/en/wireless- network/5g-technology/5g-retail.html (last visited Mar. 23, 2020). 161 Dexter Johnson, The 5G Dilemma: More Base Stations, More Antennas—Less Energy?, IEEE Spectrum (Oct. 3, 2018), https://spectrum.ieee.org/energywise/telecom/wireless/will-increased-energy- consumption-be-the-achilles-heel-of-5g-networks (“According to recent research, the ultra-lean design that 5G networks are capable of will make it possible to put more components to sleep for a longer time, reducing energy consumption by almost 10 times compared to current systems when there are no users.”). 162 3 Ways 5G Will Boost Retail, AT&T BUSINESS, https://www.business.att.com/learn/tech-advice/how- 5g-will-boost-the-retail-industry.html (last visited Mar. 23, 2020). 163 See Promoting Telehealth in Rural America, Statement of Commissioner Jessica Rosenworcel, 33 FCC Rcd 6574, 6614 (2018) (“Promoting Telehealth in Rural America Report and Order”). 164 Dan Sullivan, 5G Network Infrastructure Fuels Telehealth Advances, Healthcare Cost Reduction, CISCO (June 14, 2019), https://www.cisco.com/c/en/us/solutions/enterprise-networks/5g-network- infrastructure-telehealth.html. 165 See Promoting Telehealth in Rural America Report and Order at Statement of Commissioner Jessica Rosenworcel.
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care.166 Using 5G-enabled artificial intelligence, augmented reality, virtual reality, and spatial
computing, doctors can also better predict potential diagnoses and perform more effective, less-
invasive medical procedures.167 Intel projects that 5G-connected health will reduce health costs
by $650 billion by 2025 in the United States alone.168 These are just some of the many ways
consumers continue to derive tremendous value from service providers’ investments. It is
therefore not surprising that two-thirds of U.S. health care providers have or are developing
telehealth programs.169
Energy. Wireless-enabled smart energy innovations can help utilities and cities across
the country respond to increasing consumer demand, while protecting against outages and
efficiently using resources. As Commissioner Geoffrey Starks has observed, “5G networks will
connect billions of devices that will allow us to maximize energy efficiency and minimize
environmental impact on a national, local and individual level.”170 Smart grids can integrate data
inputs from millions of wireless devices to adjust the production and distribution of electricity, or
to adjust power consumption in order to save energy, reduce losses, and enhance the reliability of
166 See 5 Ways 5G Will Transform Healthcare, AT&T Business Editorial Team, AT&T BUSINESS, https://www.business.att.com/learn/updates/how-5g-will-transform-the-healthcare-industry.html (last visited Mar. 25, 2020). 167 See id. 168 5G Connected Health: Life-Changing Technology From Intel, INTEL, https://www.intel.com/content/www/us/en/wireless-network/5g-connected-healthcare-infographic.html (last visited Apr. 23, 2020). 169 Ron Malenfant, Industry Voices—5G has the potential to transform healthcare for rural communities, FIERCEHEALTHCARE (July 16, 2019), https://www.fiercehealthcare.com/tech/industry-voices-5g-has- potential-to-transform-healthcare-for-rural-communities. 170 Remarks of FCC Commissioner Geoffrey Starks before MWC19 Los Angeles (Oct. 23, 2019), https://docs.fcc.gov/public/attachments/DOC-360393A1.pdf.
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the power grid.171 For example, Panasonic and Ericsson have begun trial development of a new, sustainable energy-as-a-service solution, leveraging efficient energy grid and tower technology at hundreds of sites across America to support the transition to 5G.172 As Qualcomm President
Cristiano Amon said, “5G will be a fundamental enabler for smart cities, supporting a massive scale of connections between everything from streetlights to water meters to security cameras.”173 Furthermore, 75 percent of Americans consider themselves excited about 5G- enabled smart energy grids.174 Indeed, there are manifold benefits to a highly connected grid.
For example, energy and power companies will deploy 5G-powered drones to inspect their energy sources, grids, and other assets. Using drones to conduct these inspections will not only improve safety for workers, but they are also estimated to cost 80 percent less than traditional reviews.175
Weather. 5G-powered weather sensors will be able to share rich amounts of data in real time, which will help solve gaps in existing weather forecasting by dramatically enhancing the
171Smart Grid Powered by 5G SA-based Network Slicing, GSMA (2020), https://www.gsma.com/futurenetworks/wp-content/uploads/2020/02/5_Smart-Grid-Powered-by-5G-SA- based-Network-Slicing_GSMA.pdf; see also Mike Freeman, Qualcomm touts smart streetlights, water meters and other smart cities tech, THE SAN DIEGO UNION-TRIBUNE (Sept. 20, 2019), https://www.sandiegouniontribune.com/business/technology/story/2019-09-19/qualcomm-touts-smart- streetlights-water-meters-and-other-smart-cities-teconference-seeks-to-spark-smart-cities-technologies- smart-streetlights-water-meters-energy-meters (“For cities, connecting and analyzing data from connected street lights, water meters, energy grids and environmental sensors has the potential to improve safety, ease traffic jams and preserve scarce resources.”). 172 How Renewable Energy Will Power 5G Mobile Service, PANASONIC, https://na.panasonic.com/us/trends/how-renewable-energy-will-power-5g-mobile-service (last visited Apr. 23, 2020). 173 Smart Cities Playbook at 9. 174 HarrisX & T-Mobile 5G Consumer Index, HARRISX (last visited Mar. 23, 2020), https://harrisx.com/5gconsumerindex/. 175 Mark Scott, Energy Giants Turn to Drones and Sensors in New Embrace of the Digital World, N.Y. TIMES (Nov. 3, 2016), https://www.nytimes.com/2016/11/03/business/energy-environment/energy-giants- turn-to-drones-and-sensors-in-new-embrace-of-the-digital-world.html.
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quality and comprehensiveness of weather and environmental data. These powerful sensors can
be placed on the ground, poles, buildings, and even drones, allowing data to be collected at
varying altitudes. They will provide data about changes in weather factors like wind,
temperature, humidity, and precipitation, leading to better weather forecasting and preparedness.
Drones, for example, can follow flight patterns, be outfitted with customizable sensors, are fairly
inexpensive to deploy, and can supplement data collected by weather radars and weather
balloons.176
All of these technological advances have very concrete economic benefits. Supported by
smart policy-making, the United States will see benefits across the country, including an
anticipated three million new jobs, $275 billion in new investment, and $500 billion in economic
growth.177
The massive expansion of IoT services is one reason why 5G promises to have such a transformative effect on the U.S. economy. The communications efficiency, connection density, and position accuracy that 5G provides will continue to enhance IoT functionality and create new
use cases.178
Connected devices are already changing the way we do things today. The number of
businesses that use IoT technologies has increased from 13 percent in 2014 to about 25 percent
176 How 5G Will Improve Weather Forecasting & Preparedness, CTIA BLOG (July 2, 2019), https://www.ctia.org/news/how-5g-will-improve-weather-forecasting-preparedness. 177 The 5G Economy, CTIA, https://www.ctia.org/the-wireless-industry/the-5g-economy (last visited Mar. 26, 2020). 178 White House Emerging Technologies Report at 67.
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today.179 The worldwide number of IoT-connected devices is projected to increase from 10.8
billion in 2019 to 24.9 billion in 2025—a compound annual growth rate (“CAGR”) of fifteen
percent.180 Cellular IoT connections represent a large segment of IoT networks currently in
operation with a projected CAGR of 25 percent between 2019 and 2025.181 Indeed, the forecast
for cellular IoT connections is expected to reach five billion in 2025.182 Narrowband cellular IoT
technologies known as Massive IoT, such as NB-IoT and LTE Category M1 (“Cat-M1”), will
continue to support this tremendous growth.183 “Massive IoT primarily consists of wide-area use
cases, connecting massive numbers of low-complexity, low-cost devices with long battery life
and relatively low throughput.”184 By the end of 2025, NB-IoT, Cat-M1, and Cat-M2185 are
projected to account for 52 percent of all cellular IoT connections.186
Broadband IoT, in contrast, “mainly includes wide-area use cases that require higher
throughput, lower latency and larger data volumes than Massive IoT technologies can
179 McKinsey IoT Report at 2. 180 Ericsson Mobility Report, Ericsson, at 17 (Nov. 2019) https://www.ericsson.com/4acd7e/assets/local/mobility-report/documents/2019/emr-november-2019.pdf (“Ericsson Mobility Report”). 181 Id. 182 Id. 183 Id. Cat-M1 is a 3GPP standardized technology that operates at 1.4 megahertz bandwidth, which enables faster data rates than NB-IoT (up to 1 Mbps). See, e.g., Shanqing Ullerstig et al., Know the Difference Between NB-IoT vs. Cat-M1 for Your Massive IoT Deployment, ERICSSON BLOG (Feb. 7, 2019), https://www.ericsson.com/en/blog/2019/2/difference-between-NB-IoT-CaT-M1. 184 Ericsson Mobility Report at 17. 185 Cat-M2 is a wireless standard similar to Cat-M1, but it can use greater bandwidth and supports more data throughput than Cat-M1. Only Cat-M1 is being supported today. Id. 186 Id.
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support.”187 Many use cases in this segment are already supported by LTE.188 By the end of
2025, 28 percent of cellular IoT connections will be broadband IoT, and 4G will power the
majority of those connections.189
Wireless operators and new entrants have introduced a number of IoT-specific services
and offerings to meet this increasing segment of the wireless market. In mid-2019, T-Mobile for
Business and Roambee launched a NB-IoT asset tracking service designed to serve airlines, logistics providers, retailers, oil and gas companies, and “basically any business with a need to remotely track their valuable assets.”190
IoT America is piloting IoT services in rural America using long-range, wide-area network technology to capture sensor data from fields and remote locations.191 In fall 2018, U.S.
Cellular partnered with IoT America to offer smart agriculture IoT services using CDMA or LTE
connectivity and LoRa technology.192 And, as noted above, U.S. Cellular launched an LTE-M
network on 90 percent of its cell sites to offer expanded IoT capabilities to customers.193
187 Id. 188 Id. 189 Id. 190 Press Release, T-Mobile Launches America’s First Narrowband IoT Asset Tracking Solution, T- Mobile (July 15, 2019), https://www.t-mobile.com/news/beeaware-narrowband-iot-asset-tracking. 191 Claire Swedberg, LoRaWan Brings IoT Connectivity to Rural U.S., RFID J. (Aug. 5, 2019), https://www.rfidjournal.com/articles/view?18787. 192 Press Release, U.S. Cellular Teams Up with IoT America to Provide Advanced IoT Solutions Targeted for Agricultural Customers, U.S. Cellular (Sept. 25, 2018), https://www.uscellular.com/get-to-know- us/our-company/press-room/2018/uscellular-teams-up-with-iot-america-to-provide-advanced-iot- solutions-targeted-for-agricultural-customers. 193 Bevin Fletcher, U.S. Cellular boasts LTE-M network for enhanced IoT capabilities, FIERCEWIRELESS (Feb. 11, 2020 at 8:27 AM), https://www.fiercewireless.com/operators/u-s-cellular-boasts-lte-m-network- for-enhanced-iot-capabilities.
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Many sectors are investing heavily in IoT solutions. According to the International Data
Corporation, “[t]he industries that are forecast to spend the most on IoT solutions in 2019 are
discrete manufacturing ($119 billion), process manufacturing ($78 billion), transportation ($71
billion), and utilities ($61 billion).”194 The majority of transportation IoT spending is expected to be used for freight monitoring.195 Utilities’ IoT spending is expected to predominantly be
used for smart grid activities.196 Investment in IoT is projected to rapidly increase in several
other sectors. Insurance (17.1 percent), federal/central government (16.1 percent), and
healthcare (15.4 percent) are projected to see the fastest CAGRs from 2017 to 2022.197 Airport
facility automation, electric vehicle charging, agriculture field monitoring, bedside telemetry,
and retail contextualized marketing are expected to be among the burgeoning use cases.198
IV. THE WIRELESS INDUSTRY IS CONTINUING TO INNOVATE AND INVEST IN PROTECTING CONSUMERS AND PUBLIC SAFETY.
The wireless industry works every day to deliver connectivity to communities across the
nation, and especially during emergencies. To protect consumers and public safety, the wireless
industry continues to invest resources in building more resilient networks, finding better ways to
maintain service, improving coordination with other stakeholders and, during disasters or
emergencies, restoring service as swiftly as possible. The industry’s response to the COVID-19
pandemic is one example of its commitment to assisting U.S. consumers in times of need. The
wireless industry also protects consumers by working to shield them from the scourge of illegal
194 Press Release, IDC Forecasts Worldwide Spending on the Internet of Things to Reach $745 Billion in 2019, Led by the Manufacturing, Consumer, Transportation, and Utilities Sectors, International Data Corporation (Jan. 3, 2019), https://www.idc.com/getdoc.jsp?containerId=prUS44596319. 195 Id. 196 Id. 197 Id. 198 Id.
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and unwanted robocalls, which includes developing and deploying innovative robocall
mitigation technologies.
Wireless Network Resiliency. The wireless industry is aware of the central role that
wireless plays in our lives—especially during an emergency—and remains committed to
maintaining service as Americans face emergency and disaster events that are increasing in
frequency, scope, and duration. CTIA’s member companies are focused more than ever on
building increasingly resilient networks, improving practices to maintain service, enhancing
coordination with other stakeholders and, in the aftermath of any disaster or emergency,
restoring service as quickly as possible. Consistent with the recommendations made by the
Commission’s Broadband Deployment Advisory Committee Disaster Resiliency and Recovery
Working Group,199 the Commission should continue to recognize that best practices and
reasonable, flexible expectations will continue to ensure providers can invest in innovative
resiliency solutions that respond to the diversity of emergency events.
The wireless industry prides itself on delivering connectivity every day and particularly
during emergencies. Through their investments, wireless providers are developing networks
with redundant, diverse, and densified infrastructure that are already yielding some positive
results. For example, 96 percent of cell sites remained operational throughout the areas in
California affected by last year’s preemptive public safety power shutoffs—even though more
199 See FCC Broadband Deployment Advisory Committee Disaster Response and Recovery Working Group Report and Recommendations (Mar. 27, 2020), https://www.fcc.gov/sites/default/files/bdac- disaster-response-recovery-approved-rec-03272020.pdf.
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than 2.7 million Californians were without power.200 In January of this year, 68 percent of cell sites remained operational in Puerto Rico after a 6.4 magnitude earthquake knocked out infrastructure and electric power across the island, a statistic that improved to more than 80 percent of cell sites within 48 hours.201 These statistics do not diminish the challenges that communities faced during these devastating events, but do offer insight into the state of wireless resiliency today.
The wireless industry is also investing billions of dollars to densify their networks that will result in more redundant and resilient networks.202 Among other things, providers deployed some 25,000 additional cell sites in 2018,203 the vast majority of which were new small cell deployments that create redundancy, diversity, and densified infrastructure. Moreover, before a storm, wireless providers take numerous steps to fortify networks, including verifying cell site battery backup, moving portable generators into readily available staging areas, topping off backup generator fuel tanks, and moving additional fuel and refueling trucks into place to prepare for power outages.204 The wireless industry also stages recovery and response teams for
200 Strengthening Commc’ns Networks to Help Americans in Crisis Before the H. Subcomm. on Commc’ns and Tech., 116th Cong., at 6-7 (2020) (statement of Matthew Gerst, Vice President, Regulatory Affairs, CTIA), https://docs.house.gov/meetings/IF/IF16/20200227/110641/HHRG-116-IF16- Wstate-GerstM-20200227.pdf. 201 Id. at 7. 202 See, e.g., Letter from Joseph P. Marx, Assistant Vice President, AT&T Services, Inc., to Lisa M. Fowlkes, Chief, Public Safety and Homeland Security Bureau, FCC, PS Docket No. 11-60, at 1 (noting AT&T’s investment of “billions of dollars in [its] network to help plan and prepare for emergencies”), attached to Letter from Christi Shewman, Assistant Vice President-Senior Legal Counsel, AT&T Services, Inc., to Marlene H. Dortch, Secretary, FCC, PS Docket No. 11-60 (filed Nov. 26, 2018) (“AT&T Framework Response”). 203 See Press Release, Mobile Data Use Nearly Doubles, CTIA Annual Survey Shows, CTIA (June 20, 2019), https://www.ctia.org/news/mobile-data-use-nearly-doubles-ctia-annual-survey-shows (“In 2018, the industry reported 349,344 cell sites in operation—an increase of more than 25,000 sites from 2017.”). 204 See, e.g., Response of T-Mobile USA, Inc., PS Docket No. 11-60, at 7 (filed Nov. 26, 2018) (stating that T-Mobile “pre-stages assets[,] . . . temporary microwave/satellite communications, and supplies”
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rapid deployment, using a wide range of assets such as Cells on Wheels (“COWs”), Cells on
Light Trucks (“COLTs”), and Cells on Drones to temporarily enhance or restore wireless coverage.205 Before, during, and after each event, wireless industry response teams work tirelessly to prepare and respond to the emergency, including through around-the-clock engagement with stakeholders from the federal government,206 state Emergency Operations
Centers (“EOCs”),207 utilities, and other wireless providers,208 among others.209 CTIA and its member companies also work to ensure that consumers have the information and services they need by sharing tips about preparing for and using mobile devices in an emergency, targeting this information to consumers in the affected region via websites or social media.210
while “mobiliz[ing] expert recovery and restoration teams . . . and coordinat[ing] with vendors that may be used in the recovery process”) (“T-Mobile Framework Response”). 205 See, e.g., id. at 5 (discussing deployment of COWs and COLTs to restore service and ensure communications). 206 See, e.g., id. at 8 (discussing regular, close coordination with federal and state officials so that government stakeholders remain “apprised of restoration activities in impacted areas”). 207 See, e.g., AT&T Framework Response at 2 (discussing AT&T’s embed with North Carolina’s EOC, which allowed AT&T “to quickly deploy a satellite COW to an affected area before the roads became impassable”). 208 See, e.g., Verizon’s Response to Letter from Lisa M. Fowlkes, Chief, Public Safety and Homeland Security Bureau, to William H. Johnson, Senior Vice President, Verizon, PS Docket No. 11-60, at 7 (referencing the lack of “impediments in implementing or honoring the mutual aid requests that other providers asked of [Verizon] or that Verizon asked of other providers”), attached to Letter from Robert G. Morse, Associate General Counsel, Federal Regulatory and Legal Affairs, Verizon, to Marlene H. Dortch, Secretary, FCC, PS Docket No. 11-60 (filed Nov. 26, 2018) (“Verizon Framework Response”). 209 T-Mobile Framework Response at 8 (discussing use of regularly updated list of PSAP emergency contacts and dedicated communications channels with PSAPs “to improve tracking of communication with PSAP emergency contacts”); Verizon Framework Response at 12 (sharing information and regularly updating emergency management authorities regarding “the status of recovery efforts”). 210 See, e.g., Press Release, Hurricane Dorian: Preparation Tips for T-Mobile and Metro by T-Mobile Customers, T-Mobile (Aug. 27, 2019), https://www.t-mobile.com/news/tropical-storm-dorian- preparation-tips-for-t-mobile-and-metro-by-t-mobile-customers.
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The Wireless Network Resiliency Cooperative Framework (the “Framework”)—which
CTIA and a group of prominent wireless voice service providers created before the 2016
hurricane season with diverse stakeholder support, including from the Commission211—has
encouraged providers to engage in many of these efforts. By enhancing collaboration among
wireless providers, the Framework creates greater network resiliency and faster restoration of
service without the need for inflexible regulations that could divert providers’ time and resources
away from restoring networks. These efforts are necessary because each disaster is different and
providers need the flexibility to respond to evolving challenges. The investments that each
wireless provider makes in time, material, and people to employ the best possible set of tools to
prepare for and respond to the unique nature of an emergency have strengthened our nation’s
networks.
Wireless Emergency Alerts. CTIA and its member companies have supported the
Commission’s efforts to continuously enhance the Wireless Emergency Alerts (“WEA”) system
through new features, such as expanded message content and enhanced geographic targeting.
The WEA system is one of our nation’s most effective emergency alerting tools for federal, state,
and local alert originators.212 Last year, CTIA member companies, including wireless providers
211 See Letter from Joan Marsh, AT&T Services, Inc., Scott Bergmann, CTIA, Charles McKee, Sprint, Steve Sharkey, T-Mobile USA, Grant Spellmeyer, US Cellular, and William H. Johnson, Verizon, to Marlene H. Dortch, Secretary, FCC, PS Docket Nos. 11-60 and 13-239, at 1 (filed Apr. 27, 2016) (creating and explaining the Framework); see also Improving the Resiliency of Mobile Wireless Communications Networks, Reliability and Continuity of Communications Networks, Including Broadband Technologies, Order, 31 FCC Rcd 13745 ¶¶ 2, 7 (2016) (commending “the wireless industry for coming together on this issue and proposing a collective way to improve resiliency” and noting that “APCO, CCA, and Wireless Infrastructure Association support the CTIA voluntary framework”). 212 See Letter from Matthew Gerst, CTIA, to Lisa Fowlkes, Chief, Public Safety and Homeland Security Bureau, FCC, PS Docket No. 15-91 (filed Nov. 21, 2019) (“CTIA Nov. 21, 2019 Letter”) (“Since the system’s first launch in 2012, more than 49,000 WEAs have been sent throughout the United States to warn and inform millions of wireless consumers about imminent threats (such as tornados, wildfires, and hurricanes), abducted children (AMBER alerts), and various other emergencies.”).
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and chipset and handset manufacturers, worked diligently with the Commission and the Federal
Emergency Management Agency (“FEMA”) to deliver a broad suite of new capabilities through
wireless networks and handsets.
As Chairman Pai has noted “[t]he American people want, expect, and deserve the best
possible public safety services—including the most precise targeting available for wireless
alerts.”213 For this reason, the Commission adopted enhanced geotargeting requirements in 2018
requiring more precise delivery of WEA messages (“WEA 3.0”).214 The Commission also adopted rules in 2016 requiring participating service providers to support longer WEA messages
(from 90 to 360 characters), specific new categories for Public Safety messages and State/Local
WEA tests, and Spanish-language messages, as well as to support the capability to present the
WEA on the mobile device as soon as it is received (“WEA 2.0”).215
Implementing these enhancements to the WEA system required significant investments
and collaboration among participating wireless providers, equipment manufacturers, and FEMA.
In particular, CTIA’s member companies worked diligently to achieve the WEA 3.0
enhancements by: (1) creating and adopting new standards through ATIS and 3GPP; (2)
developing compliance test plans to test the C-Interface between the Federal Alert Gateway and
the Commercial Mobile Service (“CMS”) Provider Gateway Interface; (3) working with
213 News Release, Chairman Pai Calls for Continued Progress on Wireless Emergency Alerts, FCC, https://www.fcc.gov/document/chairman-pai-calls-continued-progress-wireless-emergency-alerts (Feb. 6, 2019). 214 See Wireless Emergency Alerts; Amendments to Part 11 of the Commission’s Rules Regarding the Emergency Alert System, Second Report and Order and Second Order on Reconsideration, 33 FCC Rcd 1320 ¶ 14 (2018). 215 See Wireless Emergency Alerts; Amendments to Part 11 of the Commission’s Rules Regarding the Emergency Alert System, PS Docket Nos. 15-91, 15-94, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 11112 ¶ 85 (2016).
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equipment vendors to develop new devices (with chipsets, drivers, and software) necessary for
enhanced geo-targeting; (4) integrating new interfaces into handsets and software; and (5)
updating core networks to support the WEA system enhancements.216 Testing with FEMA’s
Integrated Public Alert and Warning System (“IPAWS”) gateway was a critical and final step to
complete the implementation of new WEA features and to ensure the WEA system can reliably
support the enhancements, and wireless providers worked diligently and collaboratively with
FEMA to expedite the testing and implementation of the connectivity as quickly as possible.
The new enhancements to the WEA system announced in December 2019217 have already made
it an even more powerful tool in the toolbox for public safety officials to keep us safe.
COVID-19. Wireless service providers’ response to the COVID-19 pandemic has also demonstrated providers’ ongoing commitment to public safety and to assisting U.S. consumers in times of need. The nation’s largest wireless providers—AT&T, T-Mobile, Tracfone, U.S.
Cellular, and Verizon—quickly adopted the Commission’s Keep Americans Connected Pledge, committing to: (1) not terminate service to individuals or small businesses unable to pay bills;
(2) waive late fees; and (3) open Wi-Fi hotspots to all Americans.218 Additionally, wireless providers are reaching out to their consumers more directly to help them through potentially difficult times.219
216 See CTIA Nov. 21, 2019 Letter. 217 See New Enhancements to Wireless Emergency Alerts Will Be Available on December 13, 2019, Public Notice, 34 FCC Rcd 11042 (2019). 218 Keeping Us Connected Through COVID-19, CTIA BLOG (Mar. 26, 2020), https://www.ctia.org/news/blog-keeping-us-connected-through-covid-19 (“Keeping Us Connected Through COVID-19”); Press Release, Chairman Pai Launches Keep Americans Connected Pledge, FCC (Mar. 13, 2020), https://docs.fcc.gov/public/attachments/DOC-363033A1.pdf. 219 For example, Bluegrass Cellular is actively encouraging consumers experiencing financial hardship related to the economic fallout from COVID-19 to call or email the company to discuss their financial situation, work towards a creative solution, and ensure they remain connected. See Bluegrass Cellular,
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Wireless providers also have quickly taken action to manage the increased usage of their
networks. In response to providers’ requests, the Commission moved quickly to grant access to
additional spectrum under Special Temporary Authority (“STA”) to U.S. Cellular, AT&T,
Verizon, T-Mobile, Bluegrass Cellular, Union Wireless, and a variety of others, allowing these
providers to increase network capacity and accommodate U.S. consumers’ need to remain
connected while homebound.220 Timely coordination with the Commission to address network
congestion through use of STAs has had a meaningful impact. For example, during the
pandemic, T-Mobile has increased capacity for its 600 MHz spectrum coverage by 58 percent
while providing its customers with unlimited smartphone data on the T-Mobile network.221
Furthermore, wireless providers are helping students participate in remote learning during
school closures. Verizon tripled the monthly data allowance for its Innovative Learning schools
and committed $10 million to nonprofits directed at supporting students and first responders.222
T-Mobile increased the data allowance to 20 GB/month for free to schools and students using its
EmpowerED digital learning programs.223 AT&T offered unlimited wireless data service at no
Bluegrass Cellular’s Response to the Coronavirus, “Financial Concerns,” https://bluegrasscellular.com/covid-19 (last visited Apr. 23, 2020). Apple released a new COVID-19 app and website based on CDC guidance and in partnership with the White House Coronavirus Task Force and FEMA to make it easier for people to get trusted information during the pandemic. Press Release, Apple Releases New COVID-19 App and Website Based on CDC Guidance, Apple (Mar. 27, 2020), https://www.apple.com/newsroom/2020/03/apple-releases-new-covid-19-app-and-website-based-on- CDC-guidance/. 220 See, e.g., Press Release, FCC Grants AT&T and Verizon Further Temporary Spectrum Access to Keep Americans Connected During Coronavirus Pandemic, FCC (rel. Mar. 20, 2020), https://docs.fcc.gov/public/attachments/DOC-363211A1.pdf. 221 A Message from Our CEO to Customers: An Update on COVID-19, T-Mobile, https://www.t- mobile.com/brand/ceo-update-covid-19 (last visited Mar. 24, 2020). 222 Keeping Us Connected Through COVID-19. 223 Id.
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cost for 60 days to qualified schools activating new lines on qualified data-only plans for school-
issued tablets, 4G LTE-enabled laptops, and hotspot devices.224 And U.S. Cellular provided an
extra 15 GB of hotspot data to customers on an Unlimited Everyday or Even Better plan to adjust
to any shifting and varying work, or homework, arrangements.225
CTIA’s member companies have been working diligently to defend consumers from the
scourge of illegal and unwanted robocalls. As the Commission, Congress, and industry have
recognized, Americans are fed up with robocalls.226 Indeed, the Commission made fighting
robocalls its “top consumer protection priority”227 and gave industry more tools to protect
consumers.228 And the landmark near-unanimous TRACED Act will promote additional actions
to protect consumers by removing barriers and enhancing the Commission’s authority to stop
robocallers at the source.229 These actions will help the wireless industry build upon the various
robocall mitigation capabilities launched to protect consumers while protecting legitimate calls.
224 Id. 225 Our COVID-19 Response & Commitment to You, U.S. Cellular, https://www.uscellular.com/covid-19 (last visited Apr. 9, 2020). 226 See Advanced Methods to Target and Eliminate Unlawful Robocalls, Second Report and Order, 33 FCC Rcd 12024 ¶ 4 (2018) (“We have received hundreds of comments from consumers stating that they no longer answer their phone when it rings.”). 227 Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor, Statement of Chairman Ajit Pai, 34 FCC Rcd 4876, 4925 (2019) (“Since the beginning of 2017, fighting illegal robocalls has been the FCC’s top consumer protection priority.”). 228 See, e.g., id. ¶ 2 (permitting providers to “immediately start offering call-blocking services by default”). 229 See Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (S. Res. 151), Congress.gov, 116th Congress, https://www.congress.gov/bill/116th-congress/senate-bill/151 (last visited Mar. 23, 2020) (listing a vote of 417-3 in the House of Representatives and a vote of 97-1 in the Senate).
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The wireless industry is answering the call to protect consumers by developing and deploying a variety of innovative robocall mitigation technologies that benefit consumers. These include network-level tools that work without any action from consumers, and consumer-facing tools that can be downloaded and tailored to consumers’ needs.230 The wireless industry also partners with analytics engines,231 third-party app companies,232 and device manufacturers233 to leverage the power of analytics and other solutions to launch an even more effective defense against illegal and unwanted robocalls. Wireless providers help ensure consumers can leverage the various anti-robocall tools available to them by providing educational information and
230 See generally Comments of CTIA, CG Docket No. 17-59, WC Docket No. 17-97, at 10 (filed July 24, 2019); Comments of CTIA, CG Docket No. 17-59, WC Docket No. 17-97, at 10 (filed Jan. 29, 2020) (“CTIA Jan. 29, 2020 Comments”). 231 AT&T has partnered with Hiya, which evaluates each individual phone call and applies spam detection to screen “potentially threatening phone calls before they ever reach a person’s phone.” Jonathan Nelson, Hiya Powers Today’s Best Solution to Protect Against Robocalls, HIYA (Mar. 23, 2018), https://hiya.com/blog/2018/03/23/hiya-powers-todays-solution-to-prevent-robocalls/. U.S. Cellular, and Verizon work with Transaction Network Services, which offers anti-robocall tools that crowd-source data “to create accurate and comprehensive reputation profiles differentiating legitimate users . . . from abusive, fraudulent and unlawful users” and more accurate Caller ID. Transaction Network Services, Call Guardian, https://tnsi.com/product/robocall-protection/ (last visited Apr. 23, 2020). T-Mobile works with First Orion, a firm whose products “allow[] a provider to sign calls originating from its network[] and . . . authenticate calls coming in from another network.” See CTIA Jan. 29, 2020 Comments at 10. 232 Nomorobo has stopped more than 1.5 billion calls. Stop Spam Calls Once and For All, Nomorobo, https://www.nomorobo.com/?v=2&utm_expid=.2DEZTl1mTgWfQVAd00GbyA.2&utm (last visited Apr. 21, 2020) (“Nomorobo has stopped over 1,588,221,769 robocalls.”). RoboKiller reports reducing spam calls by 90 percent within 30 days through its software. Don’t Just Block Spammers, Get Revenge, RoboKiller, https://www.robokiller.com/ (last visited Apr. 20, 2020) (estimating that RoboKiller’s software reduced spam calls by 90 percent “within 30 days”). YouMail uses patent-pending technology to predict unwanted calls based on call patterns, user feedback, and various databases to prevent tens of millions of robocalls from reaching consumers. YouMail Call Blocker FAQ, Call Blocker, https://www.youmail.com/home/feature/call-blocker (last visited Mar. 20, 2020). 233 Apple allows iPhone users to “block[] phone numbers that [the user has] never been in contact with and [does not] have saved in [her] contacts list.” Detect and Block Spam Phone Calls, Apple (Sept. 19, 2019), https://support.apple.com/en-us/HT207099. Samsung’s Smart Call lets consumers know who is calling even when the number is not on their contact list, and lets consumers block and report the call when it is spam. See Smart Call, Samsung, https://www.samsung.com/global/galaxy/apps/smart-call/ (last visited Mar. 29, 2020).
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customer support.234 At the same time, voice service providers are focused on supporting the completion of legitimate calls, including public safety calls. Protecting legitimate calls is a goal that providers share with call originators, and providers have procedures and dedicated personnel that address issues as they arise.235
The wireless industry has also led the way in implementing STIR/SHAKEN (Secure
Telephone Identity Revisited and Signature-based Handling of Asserted Information using toKENs), an industry-developed, innovative call authentication solution that, when paired with call analytics, will help protect consumers from robocalls.236 The nationwide wireless providers began deploying STIR/SHAKEN on their networks in 2019, and have made significant progress upgrading their networks, validating calls, and exchanging authenticated traffic with other voice service providers.237 As the Commission has recognized, these actions will help combat illegal
234 For example, Union Wireless describes best practices for consumers to reduce the number of robocalls they receive. And the Wolf Devoured the Lamb: How to lessen the dangers of spoof calls, UNION WIRELESS BLOG, https://www.unionwireless.com/and-the-wolf-devoured-the-lamb-how-to-lessen-the- dangers-of-spoof-calls (last visited Mar. 21, 2020). Bluegrass Cellular provides instructions on how users may implement device-based solutions. Support FAQs, Mobile Safety, Bluegrass Cellular, https://bluegrasscellular.com/support/faq (last visited Mar. 21, 2020) (“How do I block Robocalls on my device?”). Carolina West educates its customers by providing updated links to the Commission’s online robocall educational tools. Carolina West Wireless, Support, FAQs, https://www.carolinawest.com/support/faqs (last visited Mar. 21, 2020) (including a section on robocalls and number spoofing). Tracfone explains the benefits of installing call blocking apps and provides information on various apps’ capabilities. How to Block Calls on Your TracFone Phone, TRACFONEUSERMANUAL.NET, https://tracfoneusermanual.net/how-to-block-calls/ (last visited April 23, 2020). 235 See generally Reply Comments of CTIA, CG Docket No. 17-59, WC Docket No. 17-97 (filed Feb. 28, 2020). 236 Call Authentication Trust Anchor, Implementation of TRACED Act Section 6(a) — Knowledge of Customers by Entities with Access to Numbering Resources, Report and Order, FCC 20-42, WC Docket No. 17-97, WC Docket No. 20-67, ¶¶ 17-18 (2020) (“STIR/SHAKEN R&O”) (recognizing that numerous providers have been “working hard” to implement STIR/SHAKEN). 237 See Letter from Cathleen A. Massey, T-Mobile, to Marlene H. Dortch, FCC, WC Docket No. 17-97 (filed Jan. 30, 2020) (reporting capability to sign and authenticate 100 percent of SIP traffic that both originates and terminates on its own network, and deployment of cross-network call authentication based on STIR/SHAKEN standards); See Letter from Joan Marsh, AT&T, to Marlene H. Dortch, FCC, WC
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spoofing, facilitate faster tracebacks, and give consumers more information about the calls they
receive.238 All of these efforts are necessary defenses for consumers in the multi-pronged effort
to end illegal and unwanted robocalls. Although measuring effectiveness is complex, available
call-blocking data indicate that the wireless industry and its robocall mitigation partners have
protected consumers from tens of billions of illegal and unwanted robocalls.
While industry is leveraging the available tools to stop robocalls, consumers and the
Commission continue to call for additional solutions. To further incentivize aggressive efforts to
fight robocalls on all fronts, the Commission should adopt a broad safe harbor to protect voice
service providers from liability for inadvertent blocking, mislabeling, or misidentification of a
call’s trust level.239 The safe harbor should be based on reasonable analytics, which may include
STIR/SHAKEN call authentication information. Congress also recognized the need for the
Commission to establish a safe harbor in the TRACED Act, and the Commission should
expeditiously do so. CTIA’s member companies look forward to supporting the Commission’s
efforts to implement this and other aspects of the TRACED Act, and continuing industry
progress in stopping illegal robocalls at the source.
Docket No. 17-97, at 1 (filed Feb. 5, 2020) (estimating that approximately 90 percent of its wireless customer base (prepaid and postpaid) are STIR/SHAKEN capable); Letter from Grant B. Spellmeyer, U.S. Cellular, to Marlene H. Dortch, Secretary, FCC, WC Docket No. 17-97, at 1 (filed Jan. 27, 2020) (reporting implementation of STIR/SHAKEN into its network in 2019 and has already migrated 110,000 Voice over Long-Term Evolution (“VoLTE) customers to its STIR/SHAKEN platform); Letter from Joe Russo, Verizon, to Marlene H. Dortch, FCC, CG Docket No. 17-59, WC Docket No. 17-97 (filed Feb. 7, 2020) (reporting completed implementation of STIR/SHAKEN for its wireless customer base and is using STIR/SHAKEN to inform its analytics for call-blocking decisions). 238 STIR/SHAKEN R&O ¶ 2. 239 See Letter from Patrick Halley, Senior Vice President, Policy & Advocacy, USTelecom – The Broadband Association, Matthew Gerst, Vice President, Regulatory Affairs, CTIA, and Steve Morris, Vice President & Deputy General Counsel, NCTA – The Internet & Television Association, to Marlene H. Dortch, Secretary, FCC, CG Docket No. 17-59, WC Docket No. 17-97 (filed Feb. 21, 2020) (outlining proposed safe harbor).
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Text messaging is one of the most trusted and widely used forms of communication
among consumers.240 CTIA’s Messaging Principles and Best Practices set expectations among wireless ecosystem stakeholders to protect consumers from unwanted messages. Consistent with these principles and best practices, wireless providers use advanced tools and analytics to protect the platform and consumers from unwanted messages. Today, data show that only three percent of text messages are spam and 93 percent of Americans view messaging as a trusted form of communication.241
The first version of the Best Practices was published in January 2017, consistent with
previous industry messaging guidelines, and was designed to support a robust and dynamic
wireless messaging community and help stop text messaging spam. Last year, CTIA released an
updated version of its voluntary set of industry best practices—the Messaging Principles and
240 See, e.g., Petitions for Declaratory Ruling on Regulatory Status of Wireless Messaging Service, Declaratory Ruling, 33 FCC Rcd 12075 ¶ 1 (2018) (“Texting has evolved into one of the most popular forms of communication for Americans, with trillions of wireless text messages sent each year in the United States.”). 241 See CTIA Updates Messaging Principles and Best Practices to Further Protect Messaging from Spam, CTIA (July 19, 2019), https://www.ctia.org/news/ctia-updates-messaging-principles-and-best-practices- to-further-protect-messaging-from-spam.
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Best Practices—in order to “support new uses and business opportunities in wireless messaging
services while maintaining protections for [c]onsumers from [u]nwanted messages.”242
The updates reflect new messaging tools that allow businesses, non-profits, political
campaigns, and other organizations to send large volumes of text messages to consumers using
platforms that historically have just been used by friends and family to communicate with each
other. The new updates also clarify that any organization sending text messages to consumers
should receive clear, opt-in consent, consistent with consumer expectations. For example, one
survey showed that more than four in five adults believe wireless providers should require
organizations to obtain opt-in consent before sending them messages.243 Messages from organizations that have not obtained opt-in consent may be subject to robocall mitigation measures to help protect consumers from unwanted messages. The Best Practices also include steps and recommendations that organizations should use to avoid messages being caught in spam filters and other platform protections.
As businesses, non-profits, and other organizations increasingly rely on messaging to interact with consumers, CTIA and its member companies encourage the Commission to continue enabling the wireless industry to protect consumers from spam, and maintain the integrity of the wireless messaging services for all users.
242 Messaging Principles and Best Practices, CTIA, at 5 (July 2019) at 5, https://api.ctia.org/wp- content/uploads/2019/07/190719-CTIA-Messaging-Principles-and-Best-Practices-FINAL.pdf (July 2019). 243 Memorandum from Morning Consult to CTIA (June 19, 2019) (on file with the author) (detailing a June 14-16, 2019, national sample poll of 2,200 registered voters, weighted to approximate a target sample of registered voters based on age, race/ethnicity, gender, educational attainment, and region, with a margin of error of plus or minus two percentage points).
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V. THE COMMISSION CAN FOSTER ADDITIONAL COMPETITION IN THE WIRELESS SECTOR BY ADOPTING AND SUPPORTING POLICIES INCREASING ACCESS TO SPECTRUM RESOURCES.
Competition is flourishing in the mobile wireless marketplace, but the Commission can
do even more to ensure that consumers benefit as companies race for market share. Specifically,
CTIA urges the Commission to adopt and support policies that increase access to spectrum
resources, particularly mid-band spectrum, for exclusive licensed use. CTIA also applauds the
actions that the Commission already has taken to reduce barriers to wireless deployment and
encourages the Commission to take additional actions to further clarify its rules and promote
access to resources that support next-generation services.
Leadership in 5G technology will have tremendous implications for competition and
economic growth in the United States. 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, of which $768
billion in revenue and 2.8 million jobs will be in the United States alone.244 To understand the
potential impact of 5G leadership, one needs to look no further than the effects of the United
States’ role in 4G, which accounted for nearly $100 billion of the increase in annual GDP by
2016.245 As we transition to 5G, the United States must act quickly to ensure that American
consumers and businesses benefit from our new 5G economy and the exponential growth that
promises to ensue.
244 The 5G Economy: How 5G will contribute to the global economy at 4. 245 See How America’s 4G Leadership Propelled the U.S. Economy, RECON ANALYTICS LLC, at 9 (Apr. 16, 2018) at 9, https://api.ctia.org/wp-content/uploads/2018/04/Recon-Analytics_How-Americas-4G- Leadership-Propelled-US-Economy_2018.pdf.
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Spectrum Availability, With a Focus on Mid-Band. To meet the exponential growth in
mobile data demand driven by American consumers and reap the full benefits of the 5G
economy, wireless service providers need resources to build high-capacity, low-latency 5G networks that can reach communities across the United States. In short, they need spectrum, a non-fungible resource that is in limited supply. As CTIA has reiterated on numerous occasions, mobile wireless providers have made tremendous progress developing and implementing technologies that increase spectrum efficiency.246 But these technologies are not enough to
eliminate the need for more spectrum to support competition.
Access to the right combination of spectrum assets is the linchpin to ensuring robust
competition in next-generation mobile wireless services and will place American service
providers in a position to surge ahead. Low-, mid-, and high-band spectrum each have different
capacity and network coverage properties.247 They also provide unique benefits and challenges
for mobile wireless service. Whereas low-band spectrum has long wavelengths and can travel long distances, high-band spectrum has greater capacity and can support more users. The
Commission’s efforts to date in transitioning the 600 MHz band and auctioning nearly five gigahertz of millimeter wave spectrum enabled the U.S. to roll out 5G first as compared to its global counterparts. A critical, and much needed, additional input is mid-band spectrum, which is particularly valuable for 5G because it combines data-carrying capacity with high-throughput, providing coverage across widespread areas and within buildings. Mid-band spectrum’s
246 Press Release, Wireless Providers Increased Spectrum Efficiency by 42 Times Since 2010, New Paper Shows, CTIA (July 9, 2019), https://www.ctia.org/news/wireless-providers-increased-spectrum- efficiency-by-42-times-since-2010-new-paper-shows. 247 Although definitions vary, we consider spectrum under 3 GHz to be low-band spectrum, spectrum between 3 GHz to 24 GHz to be mid-band spectrum, and spectrum above 24 GHz to be high-band spectrum.
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coverage and capacity together are so effective that the industry sometimes refers to it as the
“Goldilocks” spectrum for 5G.248 As such, a robust spectrum pipeline that includes sufficient
mid-band spectrum for licensed operations will be crucial to ensuring wireless providers can usher in the 5G economy with its resulting jobs creation and economic growth.
According to a 2020 Analysys Mason report, on average, benchmark countries, including
China, Japan, and the United Kingdom,249 are expected to make 382 megahertz of licensed mid-
band spectrum available by the end of 2020, while the United States will only have 70
megahertz.250 As a result, on average, these benchmark countries will have “over five times
more” mid-band spectrum than the United States at the end of the year.251 The average amount
of licensed mid-band spectrum expected to be available by the end of 2020 for leading nations
Canada, China, Japan, South Korea, and the U.K. has grown 32 percent from Analysys Mason’s
2018 mid-band report.252 From the end of 2020 to 2022, the average amount of mid-band being made available for 5G use in these five leading nations is projected to grow by a further 22 percent to more than 660 megahertz.253 The United States needs to effectively double its
licensed mid-band spectrum to keep up with leading nations.
248 See Mike Dano, Absence of Mid-Band Spectrum Clouds Trump’s 5G Proclamations, LIGHT READING (Apr. 12, 2019), https://www.lightreading.com/mobile/5g/absence-of-mid-band-spectrum-clouds-trumps- 5g-proclamations-/d/d-id/750811 (“[CTIA CEO Meredith Attwell Baker] called mid-band the ‘Goldilocks’ of spectrum bands because it toes the line between providing adequate coverage due to its propagation characteristics while also being capable of transmitting large amounts of data.”). 249 The list of benchmark countries in which Analysys Mason contrasts availability of spectrum is as follows: Australia, Canada, China, France, Germany, Hong Kong, Italy, Japan, Qatar, South Korea, Spain, Sweden, the United Kingdom, and the United States. 250 Janette Stewart et al., 5G Mid-Band Spectrum Global Update, ANALYSYS MASON, at 1 (Mar. 2020), https://api.ctia.org/wp-content/uploads/2020/03/5G-mid-band-spectrum-global-update-march-2020.pdf. 251 Id. 252 Id. 253 Id.
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Against this backdrop, the Commission’s upcoming spectrum auctions are an
indispensable part of the path forward for providing critical mid-band airwaves. CTIA supports
the Commission’s plans to auction 280 megahertz of spectrum in the 3.7-3.98 GHz C-band in
December, and its commitment to auction another 70 megahertz in the 3.5 GHz CBRS band this
summer.254 Moving forward with an auction of 350 megahertz of mid-band spectrum this year is
a key component of ensuring the U.S. remains competitive in the development and deployment
of next-generation wireless services. For the C-band in particular, once the winning bidders are
identified, avoiding delays in post-auction relocations and the issuance of licenses to winning
bidders will be critical.255 Delays are costly for all operators, and particularly for new and
smaller entities that may have less financial flexibility. Moreover, although the CBRS spectrum
that the Commission plans to auction will bring its own unique challenges (e.g., a novel, untested
254 See Letter from Meredith Attwell Baker, President and CEO, CTIA, to the Honorable Roger Wicker, the Honorable Maria Cantwell, the Honorable Frank Pallone, and the Honorable Greg Walden, at 1 (Feb. 25, 2020), https://api.ctia.org/wp-content/uploads/2020/02/MidBand-Letter-2-25-20.pdf. 255 Id.
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sharing framework and power levels that are broadly recognized to be too low), this auction
nevertheless presents an opportunity in the near future for stakeholders to innovate.256 While, as
Commissioner Michael O’Rielly stated, it is an action “the Commission needs to take to make
these critical mid-band licenses available for 5G and other next-generation wireless services,”257
we must nevertheless heed the Commissioner’s statement that we be “mindful that the power
limit restrictions on PALs and General Authorized Access (GAA) are woefully inadequate,
especially in rural America” and that “we need a definitive timeframe for [ ] review, along with a
clear process to evaluate whether the dynamic protection areas can be reduced in size.”258
Beyond the auctions that are already scheduled for 2020, CTIA urges the Commission to
ensure that wireless service providers have access to the pipeline of mid-band spectrum they
need to expand next-generation network deployments and support innovation. In particular, the
Commission must ensure it takes advantage of the a key mid-band spectrum opportunity in the
Lower 3 GHz band, and do so with an eye toward making as much of the band available for licensed, exclusive use as possible. CTIA thus supports the Commission’s proposal to prepare the Lower 3 GHz band for expanded commercial wireless use by removing the existing non- federal secondary Radiolocation and Amateur allocations in the 3.3-3.55 GHz segment and relocating incumbent non-federal operations.259 The Commission should also work
256 See, e.g., Letter from Scott K. Bergmann, Senior Vice President, Regulatory Affairs, CTIA, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 18-122 et al., at 2 (filed Feb. 7, 2020). 257 Michael O’Rielly, Commissioner, FCC, The 3.5 GHz Auction Is Finally a Go! (Feb. 7, 2020), https://www.fcc.gov/news-events/blog/2020/02/07/35-ghz-auction-finally-go; see also Monica Alleven, Verizon Views CBRS, C-band in ‘very different ways,’ FIERCEWIRELESS (Mar. 3, 2020), https://www.fiercewireless.com/operators/verizon-views-cbrs-c-band-very-different-ways. 258 Auction of Priority Access Licenses for the 3550-3650 MHz Band, Statement of Commissioner Michael O’Rielly, FCC 20-18, AU Docket No. 19-244 (rel. Mar. 2, 2020). 259 See Comments of CTIA, WT Docket No. 19-348, at 1-2 (filed Feb. 21, 2020).
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collaboratively with NTIA to explore fulsome use of the Lower 3 GHz band for licensed,
exclusive use under a 5G-friendly framework.260 By creating exclusive licensed mid-band channels in the Lower 3 GHz band, the United States can better take advantage of the economic and technological opportunities offered by 5G, just like other nations around the world are doing.
Promoting Spectrum Licensing and Secondary Market Transactions. In order to ensure
that wireless service providers can put spectrum resources to their best use as soon as possible,
CTIA also urges the Commission to facilitate secondary market transactions, which are an
important way in which mobile network operators, including small and rural carriers, access
spectrum today.261 Quick action by the Commission could serve as a template for future actions
to allow greater spectrum utilization and efficiency. In particular, the Commission should
consider whether any licensing procedures unnecessarily delay access to spectrum, and move to
streamline spectrum licensing, transfer, and assignment processes so that consumers across the
country can benefit from the deployment of competitive next-generation networks as soon as
possible. Simplifying the regulatory processes for secondary market participants, including
licensees, would allow for more efficient and faster transactions and would more promptly
promote the public interest by permitting users to gain ready access to spectrum and creating
additional capacity to support network services. CTIA also previously suggested steps the
Commission could take to improve its partitioning, disaggregation, and spectrum leasing
processes.262 For example, the Commission could incentivize providers to sell or lease their
260 See id. at 2. 261 See, e.g., Comments of CTIA, WT Docket No. 19-38 (filed June 3, 2019); Reply Comments of CTIA, WT Docket No. 19-38 (filed July 1, 2019). 262 See id.
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spectrum rights in the secondary market by extending for one year final buildout requirements
where a party engages in certain secondary market transactions, and permitting licensees to re-
aggregate their previously partitioned or disaggregated spectrum licenses.263 There also are steps
the Commission could take to make its information technology structure and databases more
efficient and transparent, so that interested parties have ready access to the information they need
to enter into secondary market transactions,264 and to facilitate certain transfers and assignments
that the Commission’s electronic systems do not currently support.265
Eliminating barriers to investment is essential to the expansion of next-generation
wireless services in the United States. The Commission has taken a number of steps to
modernize its siting rules and adopt deregulatory policies that promote wireless competition and
deployment across the country.
Infrastructure. CTIA applauds the actions the Commission has already taken to
facilitate the deployment of 5G and wireless broadband infrastructure.266 As Commissioner
Brendan Carr has explained, “smart infrastructure policies . . . can flip the business case for
263 See id. 264 See Comments of CTIA, WT Docket No. 19-38, at 17-22 (filed June 3, 2019). 265 For example, the Commission could update Form 608 to allow spectrum manager lessees to assign their leases, and update the Universal Licensing System to permit the assignment and transfer of control of STAs. 266 Scott K. Bergmann, A Year of Accelerated Wireless Infrastructure Investment, CTIA BLOG (March 22, 2019), https://www.ctia.org/news/a-year-of-accelerated-wireless-infrastructure-investment.
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thousands of communities.”267 For example, in March 2018, the Commission encouraged investment in 5G wireless networks by modernizing outdated federal regulations and streamlining and clarifying federal historic and environmental reviews for all wireless siting deployments.268 In August 2018, the Commission clarified that cities cannot establish moratoria on siting requests and reformed the federal framework for pole attachment requests.269 The following month, the Commission reaffirmed local control over wireless infrastructure decisions while also establishing national guardrails that balanced the need to ensure that wireless broadband can be efficiently deployed to serve consumers and businesses across the country.270
The Commission’s efforts to reduce barriers to wireless infrastructure deployment have had measureable results.271 Consequently, more U.S. consumers have access to advanced wireless services today. Indeed, 4G LTE service covers more than 77 percent of the total U.S. land area and reaches more than 99 percent of Americans.272 Consumers also benefit from
267 Commissioner Brendan Carr, FCC, Keynote Address at the International Institute of Communications 2019 Telecommunications and Media Forum, “Building a 5G World” (Dec. 10, 2019), https://docs.fcc.gov/public/attachments/DOC-361292A1.pdf (“Commissioner Carr IIC 5G Remarks”). 268 See Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, Second Report and Order, 33 FCC Rcd 3102 (2018). The U.S. Court of Appeals for the D.C. Circuit vacated a portion of the March Order that would have exempted small cell deployments from federal historic-preservation and environmental reviews. United Keetoowah v. FCC, 933 F.3d 728 (D.C. Cir. 2019). 269 See Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, Third Report and Order and Declaratory Ruling, 33 FCC Rcd 7705 (2018). 270 See Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, Declaratory Ruling and Third Report and Order, 33 FCC Rcd 9088 (2018); see also Commissioner Brendan Carr, FCC, Keynote Remarks at the CCA Annual Convention, “Building America’s Next Generation of Wireless Infrastructure” (Oct. 2, 2018), https://docs.fcc.gov/public/attachments/DOC- 354660A1.pdf. 271 See, e.g., Commissioner Carr IIC 5G Remarks. 272 Comments of CTIA, GN Docket No. 19-285, at 6 (Nov. 22, 2019).
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download speeds that are 90 percent faster than five years ago.273 The expansion in coverage
extends beyond cities, with more than 90 percent of rural consumers having access to at least
three LTE service providers.274
And the Commission’s work continues at pace. The Commission is currently evaluating
additional reforms for siting macro and small facilities and coordinating with other federal
policymakers to further streamline siting on federal properties and lands; both of which may
offer further opportunities to expedite the rollout of 5G. The Commission can also continue to
promote the deployment of infrastructure needed for 5G by resolving practical questions related
to the implementation of the Commission’s rules for siting on existing infrastructure.275 Despite
clear direction from Congress in the Spectrum Act of 2012,276 there continues to be confusion regarding the meaning and application of the Commission’s implementing regulations, delaying deployment and undermining Congressional and Commission intent.277 For these reasons, CTIA continues to urge the Commission to take several actions to clarify its rules implementing
Section 6409,278 which can alleviate uncertainty and inconsistent application of the
Commission’s rules and unleash the continued investment and deployment necessary to realize
the potential of 5G in the United States.
273 Id. at 7. 274 Id. 275 CTIA Petition for Declaratory Ruling, WT Docket No.17-79, WC Docket No. 17-84 (filed Sept. 6, 2019) (“CTIA Petition”); WIA – The Wireless Association, Petition for Declaratory Ruling, WT Docket No. 17-79 (filed Aug. 27, 2019). WIA also filed a Petition for Rulemaking seeking discrete rule changes. See WIA – The Wireless Association, Petition for Rulemaking, RM-11849 (filed Aug. 27, 2019). 276 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, Title VI, § 6409(a), codified at 47 U.S.C. § 1455. 277 See, e.g., CTIA Petition at 8-19. 278 See, e.g., id.
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Supply Chain. In November 2019, the Commission finalized a new rule that takes steps
to help protect the United States against national security threats to the communications supply
chain by prohibiting the use of Universal Service Fund dollars to purchase equipment and
services from companies that pose a national security threat.279 As the Commission begins to
implement programs under this rule to ensure our critical communications infrastructure is
secure and resilient, the Commission should adopt straightforward procedures that avoid undue
burdens and minimize network disruptions for wireless providers, especially small and regional
providers.280 Close collaboration with the Departments of Commerce and Homeland Security is
critical to ensure that our nation’s supply chain initiatives are coordinated at the federal level.281
VI. CONCLUSION.
Metrics such as investment, usage, connections, and deployment of advanced networks all lead to the conclusion that competition is robust in the wireless industry, and that consumers, businesses, and the U.S. economy are reaping the benefits. Competition in the mobile wireless industry is also sparking immense opportunity as a result of the transition to 5G, which will bring myriad innovations across numerous sectors of the economy, including transportation, manufacturing, agriculture, education, retail, healthcare, energy, and more. Smart policymaking will only support further growth, investment, and innovation. CTIA looks forward to working with the Commission to foster the continued availability of spectrum resources—particularly mid-band frequencies—and deregulatory policies to ensure that the communications marketplace remains highly competitive for years to come.
279 See Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs, et al., Report and Order, Further Notice of Proposed Rulemaking, and Order, 34 FCC Rcd 11423 (2019). 280 Comments of CTIA, WC Docket No. 18-89, at 24-25 (filed Feb. 3. 2020). 281 Id. at 2.
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Respectfully submitted,
/s/ Kara Graves
Kara Graves Assistant Vice President, Regulatory Affairs
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
Sarah K. Leggin Director, Regulatory Affairs
CTIA 1400 Sixteenth Street, NW Suite 600 Washington, DC 20036 April 27, 2020 (202) 736-3200
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