Internet Society-
Philippines Chapter
Sunset View towers
2230 Roxas Blvd. Pasay City
Manila, Philippines
June 28, 2016
Attention: Mr. Winthrop Yu
Chairman
Mr. Aris Ignacio
President
Dear Messrs. Yu and Ignacio,
This is in response to your letter
intended for the PCC which was used as reference for press stories published by
the PDInquirer on June 21st and Malaya on June 24th. For purposes of thoughtful discussion,
especially given recent forums, we are sending you additional information that
may be helpful in forming your postion regarding issues currently facing the
industry.
ISOP: 700 MHz is not necessary for good Internet
service:
The narrative regarding the 700 MHz
frequency band has been changing since news of a possible joint venture between
SMC and Telstra emerged last year. Starting with “spectrum is a scarce
resource”, descriptions of 700 MHz have more recently evolved from “faster” or
“stronger” to “better coverage”. First, because its capacity to carry
information is less than that of higher frequencies, the 700 MHz is actually
“slower”, in this sense, than higher frequencies. Secondly, while 700 MHz may
be said to have better “coverage” than higher frequencies, it does so at the
expense of other desirable properties such as capacity, mentioned above.
What is clear is that though the properties
of various frequency bands may differ, 700 MHz has no special or magical
properties as against other frequency bands, particularly adjoining frequencies
(e.g. 850 and 900 MHz) which would have properties similar to 700 MHz.
GLOBE:
Speed being provided to a user is a function of several
variables: how far the user is from a cellsite, how many other users are being
served by the same cellsite, the aggregate bandwidth from the cellsite to a
mobile service provider (MSP) core network and internet backbone, and as
important, the size of the frequency spectrum and its position that dictates
how much information can be carried. Assuming all other factors being equal, a
user can enjoy higher speeds if there is a larger slice of frequency spectrum,
the slice being more at low frequency bands and smaller at higher frequency
bands (without forgetting the distance to the cellsite).
When delivering ever faster mobile internet, MSPs normally
favor higher bands (such as 2300 or 2600) because they can carry more
information for the same MHz slice versus low frequency bands (such as
700/900). Technology developments and later generations of air interfaces have
led to faster speeds using the same slices, but the principle remains the same.
As more high speed internet users use the same cellsite,
MSPs use a variety of methods to support more users. One method is the split up
the cellsites, effectively increasing site density and lowering the number of
users using the same cellsite. Other techniques include re-using spectrum at
various sectors, or even layering and aggregating frequency bands to support
more users. Unfortunately, most people do not recognize that increasing site
density simply means adding more cellsites, which is a huge barrier to telecom
infrastructure construction in the Philippines. We have pointed to Vietnam’s 55,000 sites for
example, more than double Philippines 17-21,000. In the most extreme bandwidth
use such as the US, the same site density would mean 94,000 sites in the
Philippines (US has 300K towers for 318.9M population).
It is because of the inability to add sites that more
frequency slices are necessary in order to support more high speed users per
cellsite. Aside of course from its ability to carry information, the use of the
700 MHz band provides better coverage versus higher frequency bands (suc as
2300 or 2600), and therefore MSPs can support more high speed users using the
same tower or cellsite footprint that currently exists today.
It would be unsolvable puzzle if MSPs like Globe were
asked to support more high speed internet users, or to support ever higher
speeds, yet hamstrung by an inability to increase site density or hamstrung by
lack of frequency resources.
ISOP: Empirically, while many
countries have (differing) spectrum plans for the 700 MHz band, most countries
do not even use 700 MHz, yet all if not most of these countries provide much
faster average Internet speeds than the Philippines. Clearly, the 700 MHz band
is neither necessary nor sufficient for providing good Internet connectivity.
GLOBE:
There are three ways to increase capacity:
1.
Build New Sites
Globe has been aggressive in the past few years in implementing new sites
but the current bureaucracy in securing permits hamper us in building new sites
as fast as we want. It takes about 8 months before one cell site can be
constructed because of the number of permits to be secured from barangay level
up to national level.
2.
Add more spectrum
Regardless of frequency band, additional spectrum is still an additional
layer for capacity. Having an additional spectrum in the low frequency band is
just a bonus because it can propagate farther and deeper. This solution is the
most difficult because one cannot use additional spectrum other than those assigned
by the regulatory body.
3.
Increase Spectrum Efficiency through 2G to 3G
to 4G migration
This is essentially how much bits per Hertz can you get from a given
spectrum. Obvious solution is to shift the available spectrum into higher
wireless generations like 3G and 4G/LTE. This is what Globe has been doing over
the years, by reallocating our spectrum previously used for 2G to 3G and 4G/LTE.
But we cannot completely devote all of our traditional spectrum assets to next
generation wireless technologies since smartphone penetration is only about
40-50% and there are still lots of 2G users. One example is Mindanao where
smartphone penetration is less compared to the rest of the country and where 2G
service revenues continue to have healthy takeup. But Globe through its
offerings of affordable postpaid plans bundled with smartphones is pushing as
hard as it can for subscribers to adopt 3G/4G. It is worth noting that the
Philippines is unique in that mobile operators
support all existing technologies today: 2G, 3G, 4G/LTE, because majority
of consumers in provincial areas have yet to adopt fully to smartphones. Unlike other countries that make them use
spectrum more efficiently, once they migrate customers to 3G, all 2G spectrum
can be reallocated to a newer technology like 4G. In the
same vein, many developing countries have yet to adopt to 4G/LTE because their spectrum
resources are only limited to 2G and 3G. Historically, in most of the world,
the 700 band was used for analog broadcast. As broadcast migrates to digital
technologies, the 700 bands are freed up for mobile internet. To date, GSMA counts about 64 countries that
have deployed or started to use the 700 MHz band.
ISOP: Spectrum is not “scarce” in the Philippines:
When asked a direct question as to
whether the telco conglomerate he was representing suffered from spectrum
scarcity or was otherwise spectrum-constrained, a telco lawyer declined to
answer. Obviously, highly dense concentrations (such as countries and operators
in Central Europe) would be much more constrained in this respect, compared to
the Philippines - spread-out over 7000 islands, sitting-out in the West
Philippine Sea. Yet these countries do very well and provide better service
with what they have.
Instead of scarcity, our two dominant telcos
(but particularly PLDT group) actually have mor than sufficient spectrum. Most
telecom operators around the world deliver much faster and better quality
Internet by making efficient use of spectrum allocations that are less than
those held by PLDT and Globe, even before their take-over of the SMC
frequencies.
GLOBE: The reasons why these countries do
well are:
1.
They have high smartphone penetration that allow
them to support mobile internegt customers using 3G/4G, and some countries are
beginning or planning to turn off 2G.
2.
They have different user behavior. First world
countries tend to use only wireless communication as data connection when they
are outdoor or truly mobile or in transit. Citizens of these countries have had
the benefit of many decades of wired (DSL or fiber or cable) internet
infrastructure, which are the main internet access technologies when at home,
at work, or at meeting places such as coffee shops or hotels. By contrast,
citizens of the Philippines have not had meaningful wired infrastructure and
now use mobile as the primary method of accessing internet.
4.
They have no issues on the number of cell sites
(e.g. US at 300,000 towers). These countries are fully supported by their
governments in building the infrastructure needed for their cell sites. Their
government recognized the importance of reliable and fast communication in
their economic development. The existing red tape right now in the country in
securing permits needed in building a cell site hamper our eagerness to build
as much and as fast as we want. Without enough cell sites telcos will need more
spectrum in order to deliver the high speeds to cope with the rapidly growing
usage of wireless mobile services. It’s as simple as that. Problem is all the
red tape is hampering the fast deployment of cell sites needed to provide
enough capacity layers needed to deliver faster broadband services.
ISOP: Spectrum Efficiency:
Spectrum should not be allocated
based on the current number of subscribers. Following the incumbents’ logic
that those with more subscribers should be allocated more spectrum would only
exacerbate and perpetuate incumbent’s dominance of the market, lock-out new
players, and reward the incumbents’ inefficient spectrum usage or other
shortcomings.
Instead, global best practice is to
reserve (and keep unused) spectrum for potential market entrants. A good
example of which is Singapore (already with one of the fastest Internet speeds
in the world), which still reserves spectrum for new players, even providing
spectrum to new players at a discount vis-a-vis incumbent.
GLOBE: We generally
agree that spectrum should be assigned based on the high speed users and total
mobile internet traffic of an MSP, not just in terms of absolute subscriber
numbers. For example, as of the first quarter 2016, Globe had about 70% of
mobile internet traffic, supported by a set of frequency resources that is
smaller than the other MSP and even smaller than SMC’s. This is the reason why
Globe has been requesting the NTC for the past decade to re-allocate the 700
MHz band, especially when it was reclassified from analog broadcast to mobile,
and be given its share. Clearly, citizens should have been enjoying the benefits
of 700MHz band much earlier.
ISOP: Spectrum Lock-out:
It is possible to deliver excellent
wireline (i.e. wired, e.g. DSL, FTTH ) Internet connectivity without any
spectrum assets at all. Given their already solid foothold in the mobile
market, expanding and improving wireline service is what incumbents PLDT and
Globe should have been doing, instead both failed the NTC fixed broadband tests
last year.
For new entrants, the story is
different. New entrants will need sufficient and properly allocated mobile
spectrum for fast roll-out and launch of their services. As the two dominant
incumbents already had much more spectrum than many other operators worldwide
even before taking-over the SMC frequencies, the 700 MHz spectrum grab not only
restrains competition but effectively forecloses it (reduces contestability to
zero). Notice should also be taken of the highly anomalous practice of
incumbents deciding which fractured bits of spectrum to “return”, purportedly
for use by a new entrant.
GLOBE: For fixed broadband solution, wireline (via DSL, fiber, even cable) is
still the most reliable so Globe has recently committed to a major fiber
build program nationally. This is the result of an admitted priority serving
mobile, which is now the main method of accessing internet. But we agree that
overall, internet will be healthier with a more balanced mix of technologies.
While there are also challenges in permits and rights of way, these are fewer
and easier to overcome than cellsite permit issues.
We have worked with the NTC to surrender useful slices of
frequency. Anyone who will implement a network compliant with global 3GPP
standards, across 2G/3G/4G and even 5G, can easily use the frequencies that
have been returned to the NTC and is now in their possession for disposition.
It is worth noting that the average amount of spectrum
bandwidth assigned to wireless operators in the Asia Pacific Region is 401 MHZ. In Europe, spectrum holdings
average 460 MHz, while in Latin America only 295 MHz. For the record Globe
prior to the SMC deal only had 210 MHz
of spectrum, after the deal it now has 340
MHz of spectrum, still way below the average in the Asia Pacific Region. So to
state the Philippine telcos have the most assigned spectrum relative to many
other operators is definitely erroneous and incorrect.
We hope the additional information will allow for more
positive exchange of views regarding the industry with the joint objective of serving
the Filipino consumers.
Sincerely,
Gil B. Genio
Chief Technology and Information Officer
Chief Strategy Officer
Globe Telecom
cc: Arsenio Balisacan
Chairman, Philippine Competition
Commission
