CTIA Tells FCC CMRS Competition Flourishing

“Competition among facilities-based CMRS carriers and against other providers is fierce,” CTIA said urging the FCC to base its report on “the FCC’s historical record, consisting of eleven consecutive dockets of the Commission’s repeated findings that the wireless industry is effectively competitive in both rural and urban markets.”

The FCC need not seek data on carrier conduct and consumer behavior below the county level, since such data are burdensome to produce and competitively sensitive, CTIA said. “The cost of collecting and compiling such information may be prohibitive, particularly for smaller wireless service providers who may need to divert limited resources to meet any such reporting requirements,” CTIA said.

The FCC should make sure wireless carriers have access to USF funds if it wants to stimulate wireless buildout in rural America, CTIA said. For example, on the Pine Ridge Indian Reservation in S.D., Alltel gets USF money; in 5 years, phone penetration rates there rose from 27% to 92%. “Universal service distributions remain primarily directed to incumbent wireline carriers, despite the steady rise of consumer demand for mobile wireless services over the last decade,” CTIA said.

The competition report gives the FCC a chance to revisit roaming, still a priority for smaller carriers, MetroPCS said. “Wireless subscribers increasingly expect their handset to work when they travel outside their local metropolitan area -- whether they travel once a year or more often,” MetroPCS said: “The barriers being raised by the national carriers do not serve the public interest and are allowing the national carriers to extend their dominance in their existing markets into new markets previously occupied by their roaming partners.”

Carrier consolidation has changed the market, with 4 national carriers now not needing regional and rural carriers to provide service, MetroPCS said. “The Commission no longer can ignore the competitive impact of the size disparity and no longer can rely solely on marketplace forces and voluntary arrangements to promote competition in the roaming market,” the company said.

NTCA urged the FCC to offer licenses in relatively small sizes in auctions. “It is likely that many more of NTCA’s member companies would like to be able to offer mobile data and broadband services to their customers,” NTCA said: “Without access to rural spectrum, however, rural carriers will be unable to do so.” NTCA said a recent member survey tallied 46% of respondents as citing spectrum access as a serious concern. “The Commission can take a giant step toward solving this problem by offering spectrum at auction according to relatively small geographic areas,” the group said: “This will provide small carriers a fair opportunity to obtain access to the spectrum that will allow them to offer state-of-the-art wireless service to their customers.”

Other commenters remarked more broadly. 3G Americas urged technology neutrality by policymakers, reminding the FCC that GSM is the most deployed wireless technology, with 2.4 billion-plus subscribers worldwide and 40% of the U.S. market. “When the government does not mandate the technology carriers must deploy or otherwise favor a particular technology, there is a greater chance that competition can develop between technologies and services, to the benefit of consumers.” TracFone, a major provider of prepaid service, said in assessing competition in the industry the Commission should be “mindful” of the growing role that it and other MVNOs play.

The satellite industry stressed its ability to deliver services when the terrestrial network is damaged. “Satellites are located thousands of miles above the Earth, rendering satellite networks substantially less susceptible to ground-based disasters than terrestrial networks,” said David Cavossa, exec. dir. of the Satellite Industry Assn., in SIA’s comments. MSS services are “embraced” by first responders, the military and federal, state and local personnel “as a necessary component” of communications day- to-day and in crisis, but buildings can block MSS signals, a shortcoming first responders can find frustrating, said Cavossa.

Deployment of ancillary terrestrial component service in the 2 GHz band by MSS operators will let customers use MSS phones every day, said a group of MSS operators in a joint filing: “Instead of waiting for satellite phones to arrive or for their local networks to be rebuilt, [first responders] will be able to continue using the same phones they carry every day.”

The FCC Wireless Bureau asked for specific numbers related to serving urban and rural areas. Globalstar said it analyzes its data by state but not by rural vs. urban. It did estimate that “less than one percent of its services currently are provided in urban areas.”

Mobile Satellite Ventures (MSV) said it provides packet data services to about 30,000 units -- including 11,000 mobile units, and there are about 170,000 MSV units in service through indirect channels. Implementation of MSV’s plan to launch 2 next-generation satellites in 2009 is “ahead of schedule,” said Jennifer Manner, MSV vp-regulatory affairs.