FCC Record, Volume 28, No. 5, Pages 3700 to 4038, Supplement (March 2013) Page: 3,769
iii, 3700-4038 p. ; 28 cm.View a full description of this book.
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promote brand recognition. Marketing expenditures are a significant factor of non-price competition in
the mobile wireless industry.u3 The size of a provider's sales and distribution networks is one measure of
the provider's penetration of the market. An entrant that has an existing customer base for other
telecommunication services may expect to have lower expenditures on marketing, sales, and distribution
than an entrant that does not have a customer base in potentially complementary telecommunications
services that can be marketed in bundles. Marketing and advertising expenditures by mobile wireless
service providers are discussed below.
F. Spectrum for Mobile Wireless Services
85. As discussed above, spectrum is a key input for the provision of mobile wireless services,
and spectrum policy affects if and when existing providers and potential entrants will be able to build out
networks or expand capacity. Because spectrum plays such a significant role in the mobile wireless
industry, and because the Commission has primary responsibility for overseeing spectrum availability,
allocation, and holdings, this section will highlight the role of spectrum as an entry condition. Other
inputs in the mobile wireless industry, including infrastructure and backhaul, are discussed in Section VII
below. First, we briefly describe the Commission's allocation and licensing of commercial wireless
spectrum that is used for the provision of mobile voice and data services. We then provide an overview
of the overall spectrum holdings among different providers. We also discuss the relative advantages of
spectriu 'in different frequency bands for providing broadband service.
1. .Availability of Mobile Wireless Services Spectrum
86. Ensuring that sufficient spectrum is available for incumbent licensees, as well as for
potential entrants, is critical to promoting competition, investment, and innovation. Incumbent licensees
may need additional spectrum to increase their coverage or capacity as they grow their subscriber bases
and meet increasing demand, while new entrants need access to spectrum to enter the market and compete
with established licensees. A number of commenters discuss their concerns with a lack of spectrum for
mobile use, and comment that competition and innovation in the mobile market requires spectrum."
Through the years, the Commission has increased the amount of spectrum available for the provision of
mobile wireless services. This spectrum has been made available in different frequency bands, in
different bandwidths and licensing areas.
87. As noted in the National Broadband Plan, making sufficient spectrum available to meet
growing spectrum needs is integral to enabling network expansion and technology upgrades by
providers.' In the absence of sufficient spectrum, network providers must turn to costly alternatives,
such as cell splitting, often with diminishing returns"' Accordingly, the National Broadband Plan
recommended that the Commission make 500 megahertz of spectrum newly available for broadband use
within ten years, of which 300 megahertz between 225 MHz and 3.7 GHz should be made newly
25 See Barriers to Understanding, at 467 (Advertising, like investments that raise product quality, is as common a
competitive behavior in high-technology industries as price competition is in industries that are characterized by less
product innovation). See also Modern Industrial Organization, at 80 (If an incumbent has never had any rivals [i.e.
it is a monopolist] then asymmetries in advertising costs between the incumbent and entrant can constitute a barrier
to entry, because the monopolist has never had to bear these costs). However, the wireless telephony/broadband
market is not a monopoly, and incumbent providers incur significant advertising costs as a component of their
rivalry.
2 See Section IV.B.4, Advertising Marketing, Sales Expenditures, and Retailing, infra.
'S See Counsel Tree Comments at 1; CTIA Comments at 66, TechAmerica Comments at 3, WCAI Reply at 4.
256 National Broadband Plan, at 77.
257 National Broadband Plan, at 77.3769
Federal Communications Commission
FCC 13-34
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United States. Federal Communications Commission. FCC Record, Volume 28, No. 5, Pages 3700 to 4038, Supplement (March 2013), book, March 2013; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc177415/m1/80/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.