Please click here for a copy of the comments.
These comments demonstrate that:
- marketplace hyper-consolidation has increased provider concentration and decreased competition;
- spectrum scarcity and the absence of a spectrum cap have stifled new market entry and next-generation network upgrades, which in turn has reduced competition;
- exclusivity agreements between large carriers and device manufacturers limits customer choice and degrade the mobile wireless experience; and
- mobile wireless consumers in urban markets are afforded greater choice than their counterparts in rural markets.
The FCC should therefore:
- cull accurate coverage and services data when determining the number of competitors in a given market;
- stop hyperconsolidation among the largest carriers so that the number of service providers will not further decrease;
- extend automatic roaming obligations to data services;
- release more spectrum to the marketplace and re-impose a spectrum cap on holdings below 2.3 GHz;
- prohibit exclusivity arrangements between mobile carriers and mobile device manufacturers; and
- authorize the use of TV White Spaces spectrum for much needed mobile backhaul links.
To introduce true competition in the mobile industry, RTG requests that the FCC:
- relies less on compromised or skewed mobile coverage data in all future competition assessments;
- applies a heightened level of scrutiny to future transfer of licenses and other merger and acquisition activity to ensure heightened competition;
- extends automatic roaming obligations to data services;
- adopts pro-consumer policies such as a prohibition of exclusivity agreements between operators and device manufacturers;
- continues to release additional spectrum to new market entrants and reinstitutes a spectrum cap to prevent the largest wireless carriers from hoarding this prized asset; and
- encourages the use of wireless backhaul technologies, especially in the TV White Spaces.