Please click here for a copy of the comments.

These comments demonstrate that:

1. marketplace hyper-consolidation has increased provider concentration and decreased competition;
2. 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;
3. exclusivity agreements between large carriers and device manufacturers limits customer choice and degrade the mobile wireless experience; and
4. mobile wireless consumers in urban markets are afforded greater choice than their counterparts in rural markets.

The FCC should therefore:

1. cull accurate coverage and services data when determining the number of competitors in a given market;
2. stop hyperconsolidation among the largest carriers so that the number of service providers will not further decrease;
3. extend automatic roaming obligations to data services;
4. release more spectrum to the marketplace and re-impose a spectrum cap on holdings below 2.3 GHz;
5. prohibit exclusivity arrangements between mobile carriers and mobile device manufacturers; and
6. 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:

1. relies less on compromised or skewed mobile coverage data in all future competition assessments;
2. applies a heightened level of scrutiny to future transfer of licenses and other merger and acquisition activity to ensure heightened competition;
3. extends automatic roaming obligations to data services;
4. adopts pro-consumer policies such as a prohibition of exclusivity agreements between operators and device manufacturers;
5. 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
6. encourages the use of wireless backhaul technologies, especially in the TV White Spaces.