CTIA – The Wireless Association Letter to FCC

ctia.jpgYesterday the CTIA – The Wireless Association, sent a letter to the FCC. This letter, which was signed by approximately 139 small and regional wireless operators, expresses the wireless operators’ opinions on the open access conditions that the FCC is considering in its 700MHz service rules.

CTIA Letter to the FCC:
July 16, 2007
The Honorable Kevin J. Martin, Chairman
The Honorable Michael J. Copps
The Honorable Jonathan S. Adelstein
The Honorable Deborah Taylor Tate
The Honorable Robert M. McDowell
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554

Re: WT Docket Nos. 06-150, 06-169 and 96-86; PS Docket No. 06-229

Dear Mr. Chairman and Commissioners:
We have learned through recent media accounts that the Commission’s proposed service rules seek to impose an “open access” requirement on 22 MHz of the Upper 700 MHz band spectrum. On behalf of the approximately 139 undersigned small and regional operators and organizations, we write to urge you to reject an “open access” mandate in this spectrum. The FCC should refrain from imposing novel and untested open access conditions, which favor a single entity, on the 700 MHz spectrum critically needed by small and regional carriers to increase coverage and services.

The proposed open access mandate in the 700 MHz band would significantly hinder small carrier participation in the 700 MHz auction and in many cases foreclose their ability to deploy this spectrum in small and rural markets. The open access and public safety requirements on the licenses in the Upper 700 MHz band will force large carriers, deterred by open access requirements, to pursue licenses in the Lower 700 MHz band. As a result, both large and small carriers will be bidding on the same 24 MHz of spectrum in the lower 700 MHz band. This is particularly troubling because the spectrum in the Lower 700 MHz band uses smaller license areas intended to benefit small and regional carriers. Although many smaller licenses may initially cost more, large carriers will likely choose to bid on the many smaller licenses rather than accept larger, encumbered licenses. The end result would be fewer small and regional license winners in the 700 MHz auction.

Ultimately, we believe that the undersigned small carriers and the millions of consumers we serve will be the net losers from an open access requirement in the Upper 700 MHz band. The proposed open access requirements trade the benefits of rural deployment by small and regional licensees, and their proven track record of providing service to their customers, for – at best – speculative gains of an open access network.

1400 16th Street, NW Suite 600 Washington, DC 20036 Main 202.785.0081 Fax 202.785.0721 www.ctia.org

In sum, we fear that encumbering the Upper 700 MHz licenses with onerous conditions will result in small and regional carriers having little chance of securing licenses to deliver innovative 700 MHz wireless services to their subscribers.
Pursuant to Section 1.1206 of the Commission’s Rules, this letter is being electronically filed with your office. If you have any questions concerning this submission, please contact the undersigned.

Companies: Corporate Headquarters:
Alaska Communications Systems, Inc. Anchorage, AK
Blooston Rural Carriers
All West Communications, Inc. Kamas, UT
BEK Communications Cooperative Steele, ND
Big Bend Telephone Company Alpine, TX
Cannon Valley Communications, Inc. Bricelyn, MT
CC Communications Fallon, NV
Chibardun Telephone Cooperative, Inc. Dallas, WI
Clear Lake Independent Telephone Company Clear Lake, IA
Command Connect, LLC Sulphur, LA
Communications 1 Network Kanawha, IA
Eastern Colorado Wireless, LLC Wiggins, CO
FMTC Wireless, Inc. Nora Springs, IA
Hancock Rural Telephone Corp. d/b/a Hancock Telecom Maxwell, IN
Harrisonville Telephone Company Waterloo, IA
Haviland Telephone Company, Inc. Haviland, IN
Heart of Iowa Communications Union, IA
Interstate Telecommunications Cooperative Clear Lake, SD
Kennebec Telephone Company, Inc. Kennebec, SD
Ligtel Communications, Inc. Ligonier, IN
Manti Telephone Company Manti, UT
Mid-Rivers Telephone Cooperative, Inc. Glendive, MT
Midstate Communications, Inc. Kimball, SD
Nucla-Naturita Telephone Company Nucla, CO
Ponderosa Telephone Company O’Neals, CA
Red River Rural Telephone Association, Inc. Abercrombie, ND
Santel Communications Cooperative Woonsocket, SD
Smithville Telephone Company Ellettsville, IN
South Slope Cooperative Communications Co. North Liberty, IA
Venture Communications Cooperative Highmore, SD
Webster Calhoun Cooperative Telephone Association Gowrie, IA
Yadkin Valley Telephone Membership Corp. Yadkinville, NC
Cincinnati Bell Wireless Cincinnati, OH
CTIA – The Wireless Association® Washington, DC