AWS 3, Tailors and Poorly Fitting Policy

Just because we’re in San Francisco this week doesn’t mean the work in Washington stops.  Today CTIA filed an FCC ex parte on behalf of hundreds of  companies expressing united opposition to the adoption of any "free" broadband mandates in the AWS 3 proceeding.

Our position: while any company should be free to voluntarily provide a "free" advertising-based service to consumers, a regulatory mandate for such a service will harm consumers and potentially delay access to next generation broadband services, especially in rural areas. 

A free service will harm consumers?  How?

Think about it:  At best, given a “free” service’s limited revenue opportunity in any market – a case exacerbated in rural areas – the licensee would have little incentive to invest and build-out the service, thereby defeating its original purpose.  At worst, having to compete with a “free” service could potentially drive most competitors out of any market, which means a reduction in broadband choice and availability.  The FCC will have essentially provided a disincentive for other companies to deploy broadband networks at a time when it should be promoting broadband build-out. 

We know that tailoring auction rules to a specific company's business plan won’t increase broadband adoption in the United States – recall the recent D Block debacle.  The US broadband market is already intensely competitive and is characterized by intra and intermodal competition, multiple business plans and innovative service packages.  

If the Commission wants to see further US broadband adoption, it should seriously consider the multiple currently pending proceedings aimed at doing just that.