CTIA has filed a letter with the FCC promoting the competitiveness of the US mobile marketplace and refuting the “circulating myths” about the European mobile marketplace being more advanced. The intent is to help its more powerful members in their fight against any possible open access provisions which may be included in the upcoming spectrum auctions. To some extent the CTIA is right—the US isn’t as far behind the rest of the world as is generally believed. In other respects they miss the point…Perhaps the biggest issue with the letter is the idea that if the US is doing well on all the indicators below it doesn’t need improving. “Based on the information contained in this ex parte, consumers would be harmed considerably if the United States wireless market moved in any way toward the European wireless market model” writes CTIA, with absolutely no evidence to back it up. It could be that the open access provisions will improve the market even further.

—“The price per minute of service in the United States is lower than every European country, without exception – it is one-half of the price in Finland and one-third (or less) of every other European country.” CTIA also notes that the US has almost twice as much minutes of use than any other country (834 minutes per month, with the next highest being India at 487): I think this is largely cultural—the Americans I’ve spoken to talk a lot more than people I’ve met from other countries. How cheap a good is is one indicator of the competitiveness of the market, and while people may argue about mobile data and content voice is still the primary use of a mobile phone. In respect to mobile data, a recent survey by M:Metrics showed that the US had about the same penetration of mobile web surfing as Europe, and although a lot of mobile content activities were excluded from the results it does indicate a relatively strong market.

—“According to Ofcom, the United States has the lowest Herfindahl-Hirschman Index (“HHI”) of the nine European countries they recently measured, and when measuring the market share of 53 countries’ top two providers, the United States has the third lowest concentration.” The HHI is a common accepted measure of market concentration (details here) where the lower the concentration of a particular market is, the lower the score. This is true as far as it goes, but the carriers aren’t available in all US markets—while there are a lot of operators in the US within a particular location there is far less choice than the national figures would suggest. Of course, this isn’t confined to the US—even in countries with national licenses some operators may not be able to cover the whole country.

—“Contrary to recent reports that the United States is lagging behind in the deployment of Wi-Fi-capable devices, the United States has a thriving, and growing Wi-Fi offering, including ten handsets in the market now and many more on the way.” That’s good news for everybody—although some of those handsets have restrictions such as only working on the carriers’ WiFi hotspots, or within the customers home and so on.

—”American consumers have access to over 700 different devices – according to our research, more than any other country on the planet.” Quite possibly, but I’d want to see the figures. Specifically, how many of those handsets were the same physical gadget with different branding for different carriers, how many were the same handsets with different colors, and more importantly: How many handsets actually offer different functionality.

—”...” CTIA had nothing to say about mobile content or mobile data services. This is unsurprising since the US still lags in terms of uptake of many content services (half of American mobile users only use the phone for voice). Of course, there’s nothing that says Americans have or should buy mobile content, it’s a free market after all.

All in all a very spirited defence of the status quo in the US marketplace, which does a good job of showing that the US is not really so far behind Europe in terms of mobile services, but completely fails to address the point that there are many players in the US mobile content and services market who are unhappy with the way the industry is currently run. Comparisons with other parts of the world aside, that needs to be addressed.

PDF of Letter