• Part 1 – Free Press Net Neutrality proposals would devastate economy
• Part 2 – Free Press wants the FCC to mandate a dumb Internet
• Part 3 – We can’t pretend wireless and wired networks are the same

As part 3 of an ongoing series that analyzes Free Press’ recommendations to the FCC on the NPRM Net Neutrality proceedings, this segment will focus on wireless.

Free Press would like to see a number of new regulations pushed onto the wireless broadband industry and they want it to be as onerous as their proposed regulations on the wired broadband industry.  The problem is that the technical and economic differences in wireless broadband make Free Press’ proposals doubly bad.

Free Press advocates the following wireless regulations

• Wireless networks should be treated the same as wired networks
• No high bandwidth application blocking on wireless networks e.g., P2P prohibitions
• Carriers must allow attachment of any compatible device
• Carriers can’t be allowed to block tethering (attachment of PC to phone)

Free Press apparently believes that wireless networks should be sold, operated and regulated the same as wired networks even though this has never been done before because wireless networks are simply too different from wired networks in technical and economic terms.

Differences in capacity

• Wired networks use many wires and each wire is a separate transmission medium which multiplies capacity.  For example, a DSL network has a separate wire going to each home while a wireless mobile cell with hundreds to thousands of users has only one transmission medium.
• The propagation characteristics are vastly different between wired and wireless networks.  Signals in wires (especially shielded cable networks) are relatively shielded from interference and they don’t disperse so the signal stays concentrated and strong.  Mobile networks have wireless signals that disperse in many directions to achieve a wide coverage area, but the signal weakens very rapidly with the square of the distance.  Wires physically penetrate walls which results in no signal loss when entering buildings, but wireless signals are typically weakened 10-fold when going through the walls of a house or building.  The result is far less capacity (bits/second) per hertz (Hz) for wireless networks compared to wired networks.
• On cable broadband networks where even the last mile of wire is shared, the number of customers sharing the same wire (typically ~150) is significantly less than wireless networks that need to cover a few square miles or more.  Furthermore, the differences in the transmission medium means that on average, we can get a lot more bits per hertz over a shielded coax cable than any wireless medium.  The total amount of available spectrum on a coax cable is also a few times higher than all the deployed Commercial Mobile Radio Services (CMRS).
• A single strand of single mode fiber has many terahertz of spectrum capacity.  All the usable wireless spectrum for mobile or non line of sight fixed wireless applications in a given area amounts to 2 to 5 GHz of capacity .  Furthermore,  CMRS spectrum is extremely expensive and scarce and it is limited to a few hundred MHz of capacity.  Wireless networks have several thousand times lower spectrum capacity than fiber optic wired networks.
• Mobile customers can physically move to different places which makes it extremely difficult to support peak capacity requirements when many customers converge at a single location such as a major convention.  Wired customers stay in one place making it much easier to allocate capacity.

High bandwidth/duration applications severely degrade wireless networks

Free Press believes that wireless networks should be required to carry peer-to-peer (P2P) traffic, but striking down existing Terms of Service (ToS) restrictions on wireless networks against heavy bandwidth and heavy duty cycle applications is not practical on a technical level.  Even the requirement to permit seemingly low bandwidth Voice over IP (VoIP) applications on wireless networks is impractical for less obvious reasons.

• An HSPA 3G cell might have 7 Mbps of total capacity shared between hundreds of users. For low-duration bursty bandwidth applications like web surfing (which is what the vast majority of wireless customers want), it can multiplex (share) very well.  This is because each user is only using the bandwidth a small percentage of the time and for a few seconds at a time when they are actually loading the web page but remaining idle most other times.
• P2P or video streaming not only requires high bandwidth throughput, they sustains usage over several minutes or hours which does not multiplex (share) at all.  This means that very few P2P users can quickly take over large portions of the spectrum by opening up hundreds of simultaneous connections.
• P2P causes severe jitter problems (on the order of hundreds to thousands of milliseconds) on 802.11 networks which may have to be shared by hundred of users.  That means a single P2P user can ruin the gaming and VoIP experience of hundreds of Wi-Fi or White Space broadband users sharing the same base station.
• Wireless technology is typically not only constrained in megabits per second (Mbps), but there is also a packet per second (PPS) limit that can be overwhelmed with just a few P2P connections.  Many wireless operators ban P2P for these reasons because they may not have a technical means of limiting PPS per user.
• Less managed networks like Wi-Fi (802.11 technology) which will soon include White Space broadband networks which also use 802.11 technology don’t handle VoIP traffic well because of the random packet collision/loss problem.  An 802.11b network for example has 6 Mbps of usable bandwidth theoretically support 68 simultaneous uncompressed VoIP calls (G.711 codec) if we simply compute bandwidth requirements, but 802.11b only supports 4 of these VoIP calls in practice.  A 5th VoIP call will result in so many random packet collisions and packet drops that all of the VoIP calls will suffer.

Differences in economics

Free Press believes that wireless networks should be sold like wired networks with the same terms of service (ToS), but this too is divorced from reality.  It is about as realistic as demanding that mobile broadband cost the same, perform the same, and have the same usage caps as wired broadband.  No one expects to be able to use their wired broadband service on the road and it’s just as ridiculous to expect wireless networks to behave like wired broadband service.

• Spectrum is expensive and sold for specific purposes.
• Most existing spectrum was auctioned without “open” Net Neutrality requirements, and most of the recent 700 MHz auction was sold at three times the cost of spectrum without open access requirements.
• Wireless networks are far more competitive than wired networks, and more competitive than mobile networks in other nations.
• Smaller wireless ISPs have extremely heavy Internet transit costs and they would be put under enormous strain if they were required to carry P2P traffic at equal priority.

Figure 1 – Wide range of mobile Internet business models

Free Press wants to ban single-device service plans and that would force single-device users to subsidize multi-device users.  But unlike wired broadband services, wireless services are sold in single-device (non-sharable) or multi-device (sharable) plans.  Single-device plans typically cost $30/month while multi-device plans cost $60/month.  Multi-device plans allow customers to share their Internet access with nearby friends, family, co-workers, or anyone they like so they naturally cost more.  Free Press claims to be protecting the user but their proposal would raise the price of mobile broadband for the majority of people by requiring them to buy features they don’t need.

Free press wants consumers to be able attach any compatible device, but they can already do that today if they pay for general purpose connectivity.  Devices like the Novatel MiFi with Verizon’s mobile wireless network allows customers to connect any device they want using Wi-Fi including AT&T exclusive GSM iPhones that are currently incompatible with Verizon’s CDMA mobile network.  But Free Press’ proposal would shut down a wide range of successful special purpose business models that have restrictions not seen on wired networks.

• Mobile Internet is sometimes paid for by the content/application provider rather than by the user.  Amazon Kindle users for example don’t pay for connectivity on the Kindle but the access to the Internet is heavily restricted by Amazon.
• Mobile Internet is sometimes sold for application-specific devices such as the Peek Simply Email device.  Peek customers don’t specifically pay for mobile connectivity on the Peek, but the Peek only permits its users access to a limited number of email accounts and all other Internet applications and protocols are blocked on the device.

Consumers should have the right to buy general purpose mobile Internet access, but they should also have the right to buy less expensive services that are limited to the features they need.  The wireless business models we have are examples of market success and they are among the few bright spots of an ailing economy.  Consumers should continue to have a choice between general purpose and special purpose products.