RTG filed comments on the Petition for Rulemaking filed by CTIA-The Wireless Association (CTIA) requesting that the FCC initiate a rulemaking to transition cellular licensing from a system based on site licenses to geographic market-area licensing. RTG opposes CTIA’s proposal that the FCC eliminate Phase II unserved area licensing entirely, but agrees with CTIA that the cellular licensing scheme needs to be modified to account for evolving digital technologies. RTG is open to considering converting cellular licensing to a hybrid geographic-based approach under which markets that are “covered” may be converted to geographic licenses, but markets with 50 square miles or more of unserved area are still subject to unserved area licensing.

Although cellular is a mature service widely deployed across the country, there are still areas that are unserved or underserved. The Commission should continue its policy of providing competitors with an opportunity to apply for, and provide service to otherwise unserved areas. Accordingly, the FCC should not freeze or eliminate the cellular unserved area licensing process. RTG is, however, amenable to converting fully covered cellular markets (e.g., those with unserved areas of less than 50 square miles) to geographic market-area licenses.

Click here for a copy of RTG Comments.