US wireless lobbyist The CTIA is drawing on UK regulator Ofcom's research to convince the FCC that an unregulated market is a competitive market.
In a letter addressed to FCC secretary Marlene Dortch, and seen by El Reg, the lobbyists draw from Ofcom's "Mostly Mobile" consultation to conclude that the USA is even more competitive than the UK, though such a conclusion requires a one leap of faith or two to reach.
The letter is clearly intended to be a pre-emptive strike against the FCC's investigation into the competitive state of the US wireless market. The CTIA represents the incumbents' operators, so the conclusions that less regulation and more spectrum are the order of the day comes as no surprise, - though some of the arguments in support of it might.
Ofcom's July consultation (pdf) does attribute the sucess of the industry to healthy competition, as the CTIA explains: "In the UK, which Ofcom found to be the most competitive market in Europe, the top four wireless carriers serve 93.5% of the market, and the top five network operators serve 100% of the market."
That should come as no surprise given that there are only five operators in the UK, but the CTIA goes on to explain that "the top four U.S. carriers serve 85% of the market, and the top five serve less than 90% of the market", and that this proves "the US wireless market is even more competitive and has even less concentration" than the UK.
The reason the UK market is so competitive is, of course, because of the parity in the size of our network operators (3 aside), and we're not sure our US readers would recognise their industry as described.
But it would be remiss to describe the CTIA as ill-informed about the UK's mobile industry, as the latter explains: "We also note the recent announcement that the third and fourth largest wireless carriers in the UK, O2 and T-Mobile, have announced their intention to merge." For anyone panicking now, we believe they mean Orange and T-Mobile, or perhaps the CTIA knows something we don't.
The letter then compares the total spectrum allocations for mobile communications on each side of the pond: 352.8MHz here compared to 409.5MHz in the USA, and concludes that the ability to serve 279 million customers with only slightly more spectrum than needed by a paltry 80 million Brits is testament to world-beating ingenuity and efficiency on the part of the incumbents.
Anyone with any knowledge of radio should be wincing at such a conclusion: the USA might have four times our population, but it also has 20 times the space in which to deploy radio waves. In fact the challenges facing US operators are not comparable to what's happening in the UK, but that's not going to stop the CTIA having one last stab at grabbing some more radio spectrum.
The letter points out that while the USA has largely allocated its available spectrum, the UK still has to auction off its Digital Dividend space, leading to the alarming conclusion: "The UK – a country serving less than one-third the number of subscribers, who use less than one-fourth the minutes of use per month – has seven times the amount of spectrum in the pipeline."
So now it's up to the FCC to give the US operators lots more spectrum while stripping away restrictive regulations, after all - it's what Ofcom recommends, at least if you choose to read it that way. ®