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17th Mobile Wireless Competition Report Comment PN

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Released: May 17, 2013
445 12th Street, S.W.

DA 13-1139

News media information 202/418-0500 Fax-On Demand 202/418-2830 Internet:

Released: May 17, 2013



WT Docket No. 13-135

Comments Due: June 17, 2013
Reply Comments Due: July 1, 2013

This Public Notice (Notice) solicits input and data on mobile wireless competition for the Federal
Communications Commission’s (Commission) Seventeenth Annual Report on the State of Competition in
Mobile Wireless, including Commercial Mobile Radio Services (Seventeenth Report). The Commission
is required to submit annual reports to Congress analyzing competitive conditions with respect to
commercial mobile services.1 On March 21, 2013, the Commission released its Sixteenth Mobile
Wireless Competition Report (Sixteenth Report).2 With this Notice, the Wireless Telecommunications
Bureau (Bureau) seeks to update the information and metrics used in the Sixteenth Report, as well as to
enhance the Commission’s analysis of mobile wireless competition for the Seventeenth Report.
This Notice seeks data and information on industry structure, firm conduct, market performance, and
consumer behavior with respect to mobile wireless services, as well as on input and downstream
segments, intermodal competition, urban-rural comparisons, and international comparisons. We request
that commenters provide, to the extent possible, information and insights on competition across the
mobile wireless ecosystem using this framework. We also ask parties to comment on whether the
framework used in the Sixteenth Report was adequate for analyzing mobile wireless competition in a
useful and timely manner, or whether changes should be made for the Seventeenth Report.
The Commission actively endeavors to improve and refine the way it collects, analyzes, and reports
industry data. In particular, we are interested in obtaining data and metrics that quantify the importance
of mobile data and mobile broadband services. These would include detailed, comprehensive, historical
measurements of mobile data traffic, usage, subscribers, and devices. This Public Notice contains a series
of questions asking for data and analytic recommendations related to that effort. We seek comment on
these and any other approaches to improve the quality of the Seventeenth Report as well as subsequent

1 See 47 U.S.C. § 332(c)(1)(C).
2 Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and
Analysis of Competitive Market Conditions with Respect to Mobile Wireless, including Commercial Mobile
Services, WT Docket No. 11-186, Sixteenth Report, FCC 13-34 (rel. March 21, 2013) (Sixteenth Report).

The information used in the competitive analysis in the Sixteenth Report was derived from various
sources, including comments in the public record, Mosaik Solutions (Mosaik),3 industry associations,
financial industry analysts, company filings and news releases, Security and Exchange Commission
filings, trade publications, industry trade and press releases, research firms’ publicly-available data,
university researchers and scholarly publications, vendor market product releases, white papers, service
provider web sites, and data submitted to the Commission through other data collection efforts such as
Form 477 and the Numbering Resource Utilization / Forecast (NRUF). We seek input on whether there
are other sources of data, especially quantitative data, which the Commission can use to perform a
comprehensive analysis of mobile wireless competition.
For the Seventeenth Report, we request that commenters submit data and statistics available for calendar
year 2012 and for early 2013, as well as information on any trends and developments that have occurred
during 2012 or 2013. In particular, we seek information on events or developments that have arisen after
release of the Sixteenth Report.
Members of the industry, the public, and other interested parties are encouraged to submit information,
comments, and analyses regarding mobile wireless competition. In order to facilitate its analysis of
competitive trends over time, the Bureau requests that parties submit current data, as well as historic data,
that are comparable over time. Commenters seeking confidential treatment of their submissions should
request that their submission, or a specific part thereof, be withheld from public inspection.4



The Bureau’s analysis of market structure in the Sixteenth Report focused on the deployment of mobile
wireless networks, the current level of concentration, the ease or difficulty with which new providers can
enter the marketplace, and the conditions under which providers exit the sector. 5 We invite commenters
to address the sources of data and the analysis of metrics and information relating to the various aspects of
industry structure outlined below.


Mobile Wireless Service Providers and Service Provision

Since the Twelfth Report, the Commission has used data from Mosaik to analyze the extent of mobile
wireless network deployment and competition. This data source provides the Commission with a set of
maps of the boundaries of the network coverage areas of every operational, facilities-based, terrestrial
mobile wireless provider in the United States and its territories. Using these maps and population data
from the Census Bureau, the Commission is able to estimate the percentage of the U.S. population
covered by (1) a certain number of providers,6 (2) different types of network technologies, and (3) the
mobile voice and mobile broadband networks of individual service providers. The Sixteenth Report also
provided, for the first time, estimates of U.S. road miles covered. While these analyses provide a

3 Mosaik Solutions (formerly American Roamer) is an independent consulting firm that produces coverage maps
based on public sources as well as confidential information supplied directly by service providers. See Twelfth
23 FCC Rcd at 2261, ¶ 35, n. 61.
4 47 C.F.R. § 0.459.
5 See Sixteenth Report at ¶ 8.
6 The coverage data may not represent the number of choices actually available to consumers living in particular
areas, as service providers provide network coverage in certain areas to serve customers resident elsewhere.

quantitative baseline that can be compared across network types, technologies, and providers over time, it
has drawbacks. As noted in the Sixteenth Report, the Mosaik analysis likely overstates the coverage
actually experienced by consumers, because Mosaik reports advertised coverage as reported to it by many
mobile wireless service providers, each of which uses a different definition of coverage.7 The data are not
consistent across geographic areas and service providers. We ask commenters to address the extent to
which the limitations of the Mosaik data affect the Commission’s analysis of the data.
Are there additional sources of data that can be used to examine mobile wireless service availability and
network deployment? Are there additional analyses of competition that the Commission should perform
using the Mosaik data or other data sources? How can the Commission further develop and refine its
understanding of mobile voice and broadband availability and deployment?


Other Mobile Wireless Providers


Resale/MVNO Providers

We seek information to update the information on the major resellers/Mobile Virtual Network Operators
(MVNOs) in the United States in the Sixteenth Report.8 We also ask for comment on the extent to which
MVNOs and resellers create competitive pressure on facilities-based providers, including the facilities-
based providers from which the MVNO or reseller purchases its wholesale services. How many
subscribers do these companies have, and with which facilities-based providers? How has this changed in
2012 and 2013? Are there any new MVNO or reseller business models? From the consumer’s
perspective, what are the benefits of buying from a reseller/MVNO versus a facilities-based provider? In
what other ways has the MVNO sector evolved during the past year?

Mobile Satellite Service Providers

The Bureau seeks information about the role of mobile satellite service (MSS) providers in the mobile
wireless services industry.9 Traditionally, MSS has involved voice and narrowband data services. MSS
services are generally targeted at users requiring service in remote areas, in disaster response situations, or
other places where terrestrial mobile wireless network access may be limited.10 Examples of MSS
customers include the oil industry, maritime users, public safety agencies, and other government/military
operations. How has this changed during 2012 and 2013? To what extent are mobile wireless services
provided by MSS a substitute for or a complement to terrestrial mobile wireless services? The Sixteenth
noted that progress toward deployment of ancillary terrestrial component (ATC) services has been
a slow process, with no such services offered at the time of its release, and further noted that there was
little commercial use of the 2 GHz band spectrum for MSS.11 In December of 2012, the Commission
eliminated the ATC rules for the 2 GHz band, granted terrestrial authority to the existing MSS licensee,

7 See Sixteenth Report at Executive Summary, Network Deployment.,.
8 See Sixteenth Report at ¶ 29.
9 To the extent that satellite providers offer mobile voice and data services that compete with terrestrial commercial
mobile wireless services, such satellite-based services will be included in the Commission’s analysis of competitive
market conditions with respect to mobile wireless. All other competitive issues related to satellite communications
will be examined in the Commission’s annual reports on the status of competition in the satellite services market.
See “IB Invites Comment for Third Annual Report to Congress on Status of Competition in the Satellite Services
Market,” IB Docket No. 09-16, Public Notice, 24 FCC Rcd 5424 (IB 2009).
10 See Thirteenth Report, 24 FCC Rcd at 6301 ¶ 247.
11 Service Rules for Advanced Wireless Services in the 2000-2020 MHz and 2180-2200 MHz Bands, Notice of
Proposed Rule Making and Notice of Inquiry
, 27 FCC Rcd 3564 ¶ 8 (2012)(AWS-4 NPRM and NOI).

and established rules for terrestrial service.12 What mobile wireless services are currently being offered
using MSS companies? To what extent are MSS operators providing broadband services, and how is this
affecting mobile wireless competition? How do MSS providers plan to deploy services taking advantage
of the rule changes?


Market Concentration

In the Sixteenth Report, as in previous Competition Reports, the Commission analyzed horizontal
concentration in the mobile wireless industry by calculating the Herfindahl-Hirschman Index (HHI) for
each Economic Area (EA) in the United States and determining an average HHI, weighted by EA
population, for the entire country.13 The data source used for this calculation is the Numbering Resource
Utilization / Forecast (NRUF) data that are submitted to the Commission on a rate center basis.14 NRUF
tracks the number of phone numbers that have been assigned to mobile wireless devices and therefore
serves as a proxy for mobile wireless subscribers.15 We seek comment on the usefulness of the HHI index
derived from NRUF data in measuring industry concentration and competition, the relationship between
concentration and competition, and whether there are other ways or current best practice metrics by which
the Commission should analyze concentration in the mobile wireless industry. We seek comment on
whether it would be helpful to estimate market shares or concentration for specific mobile wireless
services and how we might estimate such market shares. The Bureau also asks whether EAs continue to
be an appropriate geographic area for the calculation of HHI measures based on NRUF data in the
Seventeenth Report or whether we should use other geographic boundaries.
In addition, we seek comment on the relationship between concentration and competition. How has
concentration in the mobile wireless services industry changed during 2012 and 2013? To what extent are
such changes the result of consolidation? Have changes in concentration levels affected pricing, the

12 See Service Rules for Advanced Wireless Services in the 2000-2020 MHz and 2180-2200 MHz Bands, WT
Docket No. 12-70, Fixed and Mobile Services in the Mobile Satellite Service Bands at 1525-1559 MHz and 1626.5-
1660.5 MHz, 1610-1626.5 MHz and 2483.5-2500 MHz, and 2000-2020 MHz and 2180-2200 MHz, ET Docket No.
10-142, Service Rules for Advanced Wireless Services in the 1915-1920 MHz, 1995-2000 MHz, 2020-2025 MHz
and 2175-2180 MHz Bands, WT Docket No. 04-356, Report and Order and Order of Proposed Modification, FCC
12-151 (rel. Dec. 17, 2012) (AWS-4 Report and Order).
13 See Sixteenth Report, at ¶ 24. EAs are defined by the U.S. Department of Commerce’s Bureau of Economic
Analysis. See Twelfth Report, 23 FCC Rcd at 2331, n. 564.
14 Rate center boundaries are much smaller than, and not coextensive with, mobile telecommunications license
boundaries such as Cellular Market Areas (CMAs), Metropolitan Trading Areas (MTAs), or Basic Trading Areas
(BTAs). Due to their relatively small size, rate centers are not necessarily indicative of where a mobile
telecommunications subscriber lives, works, or uses a mobile telecommunications device. In addition, to protect the
confidentiality of the companies submitting NRUF data, the Commission does not report the number of subscribers
for geographic areas in which there are three or fewer providers.
15 The Commission estimates the number of mobile wireless subscribers by counting the number of telephone
numbers that have been assigned to end users by mobile wireless providers using NRUF submissions. See
Thirteenth Report
, 24 FCC Rcd at 6278-79, ¶ 196 & n. 551. In NRUF, carriers do not report numbers that have
been ported to them. Therefore, to develop an estimate of mobile wireless subscribership, it is necessary to adjust
the raw NRUF data to account for mobile wireless subscribers who have transferred their wireline numbers to
wireless accounts. Porting adjustments are developed from the telephone number porting databases managed by
Neustar, acting as the administrator of the regional Number Portability Administration Centers (NPACs). The
databases contain all ported numbers currently in service. They also contain information about when the number
was most recently ported (to a carrier other than the carrier to which the number originally was assigned) or, in some
cases, when the database was updated to reflect a new area code. Trends in Telephone Service, FCC, Apr. 2005, at
8-2 – 8-3.

rollout of new services, and equipment offerings? Have they affected mobile data services differently
than mobile voice services? And have they affected rural areas differently than urban areas?


Entry and Exit Conditions

Actual entry and exit in a market occur in the context of underlying regulatory, market, and technological
conditions that directly influence the total number of firms that can compete successfully.16 Barriers to
entry in the mobile wireless services industry include various regulatory and non-regulatory factors, such
as access to spectrum, tower siting policies, large sunk costs for network deployment, and the magnitude
of marketing and advertising expenditures on brands and services.17 The Bureau seeks comment on the
effects of these and other types of barriers to entry on concentration in the mobile wireless industry. Do
entry and concentration vary across different market product segments or niches or across different types
of geographic areas?


Recent Entry and Exit

The Bureau requests information on market entry by mobile wireless service providers, as well as
consolidation and other forms of market exit, which occurred over the past year. To what extent have
new providers launched service in 2012 and 2013? Are other providers in the process of securing
financing and building networks, with plans to begin offering service soon? To what extent have certain
providers that offered service in some areas of the country entered new markets, including new cities as
well as smaller towns or suburban areas surrounding larger urban areas?
Which mobile wireless service providers exited the market by being absorbed in an acquisition by another
company during the past year? How has the pace of consolidation changed in 2012 and 2013? What are
the reasons for consolidation by mobile wireless service providers and the reasons for any changes in the
pace of consolidation? Are there any relevant studies of concentration and market performance in the
mobile wireless service industry?



We ask for input and feedback on our latest analysis of the spectrum used for mobile wireless services,
the spectrum holdings of mobile wireless service providers, and the competitive effects of spectrum
holdings, as well as up-to-date information on this topic. How should the Commission assess the ways in
which spectrum holdings affect the structure, conduct, and performance of the mobile wireless services
industry? How do mobile wireless service providers and spectrum licensees currently use their licensed
spectrum? Are certain frequencies used heavily while others lie fallow? How does this vary across
different types of geographic areas?
How much spectrum is unused or underutilized? To what extent do spectrum licensees lease, partition, or
disaggregate their spectrum? How much of the spectrum available for the provision of mobile wireless
services is actually used to provide service? What are the tradeoffs involved? Of the spectrum that is
currently unused, to what extent do licensees plan to use that spectrum to provide service in the future?
Are there geographic areas within spectrum license boundaries that licensees do not plan to serve? Are
there any data or estimates available on spectrum utilization or non-utilization/warehousing?
How much additional spectrum will be required to support next generation technologies and mobile
broadband applications, and in what locations? How much spectrum is being used to provide services

16 See Sixteenth Report at ¶ 62.
17 Id.

over 3G and 4G network technologies versus 2G digital voice technologies? How much spectrum is
required to roll out services over technologies such as WiMax and LTE? Which technologies, services,
and applications require large amounts of spectrum? How should the Commission account for differences
in spectrum holdings and bandwidth in evaluating mobile wireless competition?
The different propagation characteristics of different spectrum bands can influence how spectrum is used
to deliver mobile wireless services to consumers.18 What are the benefits of transmitting in different
frequency bands? Do these benefits vary across geographic areas? How do such benefits translate into
capital and operating cost differences? How are service providers’ network deployment plans affected by
their spectrum holdings in the frequencies above and below 1 GHz? How does the use of different
frequency bands affect competition in the industry?
The Bureau seeks comment on whether there is access to sufficient spectrum, either through Commission
auctions or through secondary market transactions, to prevent spectrum from becoming a significant
barrier to entry in the mobile wireless industry. Are existing service providers spectrum constrained? If
so, in which geographic markets are providers most likely to be constrained? Do potential entrants have
sufficient opportunities to access spectrum, and has this changed in the past year?
How have advanced network technologies affected spectrum access? As these technologies become more
prevalent, will potential entrants have more or fewer opportunities to access spectrum? Have mobile
wireless service providers become more or less spectrum-constrained after rolling out new networks and
services? Do providers anticipate needing additional spectrum to deploy faster and more advanced
mobile broadband networks?




Price Rivalry

The Bureau seeks information on innovations or developments that have occurred with mobile wireless
pricing plans during 2012 and 2013. Have such pricing innovations occurred throughout the mobile
wireless industry, or have they been limited to certain types of services or a subset of providers? Are
providers targeting different pricing plans to different types of consumers? If so, how? To what extent
do new types of pricing plans reflect price rivalry among mobile wireless service providers?
In particular, the Bureau seeks comment and information on trends related to the pricing of mobile data
and Internet access services offered by mobile wireless service providers. We request data on the pricing
of these services on a national or sub-national level. Have the ways in which providers’ price mobile data
and Internet access services changed in 2012 and 2013? The Sixteenth Report noted the shift to tiered,
usage based pricing models for smartphones and other data devices. It also noted the introduction of
shared plans directed at subscribers with multiple devices.19 Have these trends continued, and to what
extent, and how has this affected competition in the industry? How are providers pricing mobile Internet
access services for non-voice devices such as tablets, e-readers, laptops, and modem cards, and how has
this changed in the past year? Are there any reports or analyses that discuss pricing trends for mobile data
services? How have such trends affected mobile data subscribership and use?
What pricing methods are providers using specifically to retain customers and reduce churn? What
benefits or promotions are providers offering to repeat customers and those with long-term contracts?
What developments have occurred with regard to customer retention pricing methods during 2012 and

18 See Sixteenth Report at ¶ 119.
19 See Sixteenth Report at ¶ 144

2013? What has been the effect of pro-rated early termination fees on churn? What role does handset
and device pricing play in mobile wireless competition? Do providers engage in rivalry via handset and
device pricing? How has this changed in the last year?20 We also seek comment on the extent to which
the secondary market for handsets and devices affects device pricing as a factor in competition.
We seek to update the information on the measures wireless service providers are taking to alert
customers when they have exceeded or are about to exceed a monthly voice, text, or data limit, so that
they can avoid “bill shock.” As noted in the Sixteenth Report, in October 2011, the Commission, CTIA,
and Consumers Union announced voluntary industry guidelines under which mobile service providers
will provide free alerts to subscribers, on an opt-out basis, both before and after they have reached
monthly voice, text, and data limits.21 We also note that on April 18, 2013, the Commission announced
that providers covering 97 percent of wireless consumers were participating in the bill shock prevention
program.22 We seek comment on whether service providers have implemented other measures to enable
their customers to avoid unwanted overage charges and bill shock.


Non-Price Rivalry


Network Coverage and Technology Upgrades

The Bureau requests information on the extent to which mobile wireless providers have upgraded, or plan
to upgrade, their networks with 3G and 4G technologies such as Wideband Code Division Multiple
Access (WCDMA), High-Speed Packet Access (HSPA), HSPA+, Evolution Data-Optimized (EV-DO),
EV-DO Rev A, WiMAX 802.16e-2005 (mobile WiMAX), and Long Term Evolution (LTE). Has there
been further deployment of these technologies since the release of the Sixteenth Report? How extensively
have providers deployed advanced technologies in rural areas?
We seek information on how providers plan to deploy services in the WCS and AWS-4 bands including
the technologies and speeds they plan to offer. We also seek information on the network and end-user
equipment that will be available for these bands. Are the services to be offered and networks to be
deployed using this spectrum similar to or different from the services offered using other frequencies,
such as Cellular, Broadband PCS, and the 700 MHz Band? We seek information on the relative
advantages and disadvantages of the various mobile network technologies and the impact their differences
have on competitive conditions in the mobile wireless industry. To what extent do 3G and 4G network
technologies improve providers’ coverage, capacity, and/or service offerings? In addition, to what extent
have providers integrated their mobile wireless network technologies with high-speed wireless local area
network (WLAN) technologies such as Wi-Fi, with the aim of offering seamless mobile voice or data

20 We note that in March, 2013, T-Mobile announced that it was eliminating both term-contracts and device
subsidies. See (visited April 23, 2013).
21 CTIA – The Wireless Association, Federal Communications Commission, and Consumers Union Announce Free
Alerts to Help Consumers Avoid Unexpected Overage Charges,
Press Release, CTIA, Oct. 17, 2011, available at The guidelines also include measures to inform customers
about international roaming charges when traveling abroad.
22 FCC Marks Milestone in Effort to Eliminate ‘Bill Shock’, Press Release, FCC, April 18, 2013. On April 17th the
Commission held a consumer workshop, and updated its Web Portal to help further educate consumers on issues
related to unexpected charges on their bills.


Advertising, Marketing, Sales Expenditures, and Retailing

The Bureau requests comment and updated information on the extent to which provider advertising,
marketing, and retailing practices reflect competition in the mobile wireless marketplace. How much did
individual providers, and the industry as a whole, spend on advertising and marketing in 2012 and 2013?
Have providers increased the amount of money spent on customer acquisition? How have advertising and
marketing campaigns and practices changed during 2012 and 2013? In addition, what are the most
popular retail channels used by mobile wireless providers, and how has this changed over the past year?
Are different types of customers obtained through different retail channels, and how does this affect the
various performance metrics used to analyze competition in the industry?

Differentiation in Mobile Wireless Handsets/Devices

We seek comment on the role of handsets and devices in competition among mobile wireless service
providers. Providers compete by introducing new handsets and devices, distinguishing their handset and
device offerings from those of their competitors, responding to competitors’ device innovations with rival
offerings, offering certain device models on an exclusive basis, and allowing devices that they do not sell
directly to be used on their networks. Have these trends continued since the Sixteenth Report? How are
providers using device innovations as a way to compete? Does the variety of available handsets differ
significantly depending on where a subscriber lives?
We also seek comment on the importance of device platforms and operating systems, and their
accompanying application stores, to mobile wireless consumers. How has the role of device operating
systems changed since the Sixteenth Report? Have certain platforms increased or decreased in popularity
and market share? To what extent are mobile wireless customers exhibiting loyalty to certain platforms,
as opposed to particular devices or providers, and how is this affecting competition among mobile
wireless service providers?
The Sixteenth Report discussed the growing popularity of non-voice devices, such as tablets and e-
readers, which, at least in part, rely on a mobile wireless network connection. How many of these devices
were in use at the end of 2012 and in 2013, and to which networks did they connect? What is the nature
of a consumer’s relationship with the mobile wireless network provider when using such devices, and
how does it differ from the relationship when using a traditional mobile handset or smartphone? How has
this changed in the past year? How does the increasing use of these devices affect competition among
mobile wireless service providers? What effect has the advent of shared data plans had on adoption and
usage of such devices?

Differentiation in Mobile Data Applications

As with handsets and devices, mobile wireless service providers also compete by differentiating from
their rivals the applications that they make available through the devices attached to their networks. The
Bureau is interested in collecting updated information and analyses of the mobile data applications
available on mobile wireless networks and how consumers are able to access those applications. How are
providers differentiating themselves from their rivals by the applications and Internet content that are
available through their networks? To what extent do mobile wireless service providers offer consumers a
level of choice in content and applications that is similar to or greater than the level of choice available
through other broadband connections? What changes have occurred in this regard during 2012 and 2013?
We invite comments on the impact of the use of mobile web browsers and application stores. How has
the increasing popularity of mobile applications and Internet access affected the ability of mobile wireless
service providers to differentiate themselves? To what extent has control over the types of applications
that customers can access on their devices shifted from service providers to device makers and/or
operating system developers during 2012 and 2013?



The Seventeenth Report will analyze a range of mobile wireless performance metrics, including
subscribership levels, penetration rates, net subscriber additions, usage levels, pricing levels and trends,
revenue, investment, profitability, and network and service quality. The analysis of subscribership levels
will include data on the total number of mobile wireless connections, subscribers, smartphones, Internet
access subscribers, and data-capable handsets, as well as the number of prepaid and postpaid subscribers,
number of subscribers in different age cohorts, and the number of connections in different Economic
Areas (EAs). Are there additional metrics that would enhance the Commission’s analysis of the mobile
wireless marketplace? Are there additional ways that existing data can be analyzed to provide further
insight into the nature of mobile wireless competition? To the extent that commenters believe we should
include additional metrics or perform additional analyses, we ask that they provide these data and explain
these analyses. Are the additional metrics available on a national as well as a sub-national level?



As mentioned above, the Seventeenth Report will analyze several different measures of mobile wireless
subscribership levels and penetration rates, from a variety of data sources. The metrics include: total
mobile wireless subscribers in the United States and by provider; mobile wireless Internet access
subscribers and devices in use; data-capable, SMS-capable, and web-capable devices; tablets; wireless
aircards and laptop cards in use; mobile wireless subscribers by pricing plan; mobile wireless subscribers
by age; and mobile wireless connections by EA.
The main source of data used by the Commission to calculate total mobile wireless connections
nationwide and by EA is NRUF. NRUF tracks the number of phone numbers that have been assigned to
mobile wireless devices. As noted in the Sixteenth Report, one important limitation to NRUF is that it is
no longer an accurate reflection of the number of individual subscribers.23 More consumers are using
more than one mobile device – particularly non-voice devices, such as Internet access devices (e.g.,
wireless modem cards and mobile Wi-Fi hotspots), e-readers, tablets, and telematics systems – and many
data-only mobile devices have assigned telephone numbers. Thus, NRUF provides an estimate of the
number of mobile wireless connections or connected devices. In addition, while many mobile wireless
devices that are not used for mobile voice services still have a phone number assigned to them, certain
providers’ devices, such as Clearwire’s WiMAX mobile and fixed Internet access devices, do not have
phone numbers assigned to them and are not captured in the NRUF data. NRUF data also do not include
demographic information about the subscribers with phone numbers assigned to them. We seek comment
on the effects of NRUF’s limitations in analyzing mobile wireless performance and competition. For
example, the number of people who use multiple devices limits the ability of the Commission to
determine how many people in the United States do not own a mobile wireless handset or device.
In the Sixteenth Report, as in previous Competition Reports, the Commission calculated sub-national
penetration rates by EA.24 The Bureau requests comment on the appropriateness of using EAs for such
calculations. Given the limitations of NRUF data, insofar as they are reported on the basis of the location
of rate centers, would other geographic areas be appropriate to use in place of or in addition to EAs, such

23 See Sixteenth Report, Executive Summary, Subscribers, Connections, and Net Adds. .
24 The use of any particular geographic area to calculate mobile wireless subscribership and penetration rates for
purposes of this report does not imply that the same geographic area will be used in any other Commission
proceedings to define the relevant geographic markets. Such other proceedings could include an application for a
license transfer and may present facts pointing to a narrower or broader geographic market definition than any used,
suggested, or implied in the Competition Reports.

as states, MTAs, BTAs, CMAs, or counties? In addition, are there other ways to interpret existing
national and sub-national subscribership data for purposes of the Seventeenth Report?
Beginning with the Fourteenth Report, the Commission has supplemented its existing data on mobile
wireless subscribership and connections with data from the Commission’s Form 477 on mobile wireless
Internet access subscribers and connected devices.25 Under the Form 477 Local Telephone Competition
and Broadband Reporting requirements, mobile wireless broadband providers report their number of
mobile Internet access subscribers at speeds exceeding 200 kbps in at least direction on a state-by-state
basis by speed tier.26 We note that the Form 477 data do not separately capture those mobile data users
who do not have a subscription to a mobile Internet access service.27 We seek comment on the ways we
can use the Form 477 data to analyze mobile wireless competition in the Seventeenth Report.
Are there additional sources that the Commission should use to analyze mobile wireless subscribership?
For instance, are there sources that can provide data on either a national or sub-national basis on the
number of individuals who use mobile wireless services, rather than the number of mobile wireless
connected devices? Are there sources that can provide data on the number of devices that are used for
mobile broadband or data services exclusively or in conjunction with mobile voice services? In addition,
are data available on the number of connections broken down by mobile network technologies, such as
We also seek comment on whether we should analyze the adoption rates of mobile wireless services
among different segments of the population, including by age group, income level, and geographic area.
For example, we provided analysis of how the number of facilities-based mobile wireless providers varies
by median income in the Sixteenth Report. Should we extend this type of analysis to other areas in the
Seventeenth Report? If so, which sources could provide such data? We also noted variance of
smartphone penetration by race/ethnicity, household income, education level, and urban/rural location.
We seek comment on how we might expand the use of detailed demographic information throughout the
Seventeenth Report.


Net Subscriber Additions

We seek comment on our analysis of net subscriber additions, or “net adds,” for the industry as a whole,
by pricing plan, and by service provider and ask whether we should make any changes or add any new
measures to the Seventeenth Report. We also seek comment on the extent to which net adds metrics
provide valuable insight into the level of competition in the mobile wireless services industry.

25 See Sixteenth Report, Executive Summary, Subscribers, Connections, and Net Adds .
26 Development of Nationwide Broadband Data to Evaluate Reasonable and Timely Deployment of Advanced
Services to All Americans, Improvement of Wireless Broadband Subscribership Data, and Development of Data on
Interconnected Voice over Internet Protocol (VoIP) Subscribership, WC Docket No. 07-38, Report and Order and
Further Notice of Proposed Rulemaking
, 23 FCC Rcd 9691, 9700, ¶ 20 (2008). Mobile high-speed “subscribers”
are defined for Form 477 purposes as customers whose device and subscription permit them to access the lawful
Internet content of their choice at data rates exceeding 200 kbps in at least one direction. Id. at 9703 ¶ 23. In
addition, mobile wireless broadband providers are required to report the percentage of the total subscribers in each
state that are residential (not billed to a corporate, business, government, or institutional account). Id. at 9703 ¶ 24.
However, they are not required to submit their number of subscribers broken down on a Census Tract basis, as other
broadband providers are required to do. Id. at 9698, ¶ 16.
27 Mobile data services include not only data services and applications that are offered over mobile broadband
networks (which transfer data at speeds of at least 200 kbps in at least one direction), but also those that are provided
over network technologies with slower data rates.


Output and Usage Levels

To analyze mobile wireless output and usage, the Commission tracks data on mobile voice, messaging,
and data traffic. For the Seventeenth Report, we seek data, both for the industry as a whole and by
provider, on mobile voice, messaging, and data traffic volumes. How have these changed during 2012
and 2013? What are the reasons for such changes?
While industry-wide data on total and average voice minutes of use (MOUs), as well as text messaging
and multimedia messaging service (MMS) traffic volumes, have been available from CTIA, data on the
number of megabytes of mobile data traffic have been limited.28 Because of the increasing importance of
mobile data and broadband services in the mobile wireless industry, we ask that commenters, particularly
mobile wireless service providers, submit data on mobile data traffic volumes. For instance, we ask them
to provide the total megabytes of mobile data traffic on their networks on a quarterly or annual basis. We
ask also for any data on mobile data traffic by type of device, by type of subscription, by age group, and
on a sub-national basis.
In addition, the Bureau asks whether there are additional sources of voice or messaging traffic data that
should be included in the Seventeenth Report. For example, we request data on voice, messaging, and
data on a sub-national basis and/or broken down by various demographic groups. Should the
Commission perform other analyses or draw additional conclusions about usage and traffic from new or
existing data?


Pricing Levels and Trends

The Bureau seeks comment on the use of certain pricing measures – namely the Cellular Consumer Price
Index (CPI) and Revenue Per Minute (RPM) – as tools in its analysis of the performance of the mobile
wireless industry.29 In particular, to what extent do changes in these pricing measures provide insight into
the nature of competition in the mobile wireless services sector?
The Bureau seeks updated information and additional data on the pricing of mobile voice, messaging, and
broadband services. In particular, the Commission is able to use industry data from CTIA to calculate
voice RPM, which is used as a proxy for the per-unit price of mobile voice service,30 but has not been
able to use the same source to generate an analogous metric for the per-unit price of mobile broadband
service. Therefore, we request data that can be used to derive a unit price measure for this increasingly
important mobile wireless service. In general, how has the pricing of mobile voice, messaging, and
broadband services changed during 2012 and 2013? Are there additional analyses that can be performed
or conclusions that can be drawn from new or existing pricing data?
Recent and future developments in mobile pricing plans and service offerings have the potential to blur
the distinction between voice and data revenue and between voice and data usage. These developments
include the use of bundled voice and data service offerings and the transition to mobile VoIP services.
We invite comment on, and analysis of, the impact of such developments on the usefulness of voice
RPM, or other per-unit pricing metrics, as a means of tracking pricing trends in mobile wireless services.

28 See Sixteenth Report at ¶ 261.
29 See Sixteenth Report at ¶ 266-267.
30 See Sixteenth Report at ¶ 267.



The Bureau seeks comment on the use of key revenue metrics, including total industry revenues and
average revenue per user (ARPU), in its analysis of mobile wireless performance and competition. Are
additional ARPU data available that we should consider, in particular data depicting whether and how
ARPU varies by region and/or demographic group? We also request provider-specific ARPU data for the
Seventeenth Report, including information on how service providers allocate ARPU to different types of
mobile wireless services or devices. Are there additional analyses that can be performed or conclusions
that can be drawn from new or existing data? The Bureau requests from commenters additional input on
the possible causes for any recent trends in ARPU, as well as additional data that may support various



We ask for updated information and additional analyses of investment levels in the mobile wireless
industry, including total investment levels over time, as well as investment per subscriber, investment as a
percentage of revenue, and capital expenditures by individual mobile wireless service providers. Did
investment – both for the industry as a whole and by individual providers – increase or decrease during
2012 and 2013? For what purposes are providers using capital expenditures, and how has this changed in
the past year? Are there any studies or analyst reports on the investments of nationwide providers versus
regional/local providers? Do data exist on investment by geographic region? Which categories of
investment are most relevant for competition?



The Sixteenth Report included an analysis of mobile wireless provider profitability measures using three
different metrics: Earnings Before Interest, Taxes, Debt, and Amortization (EBITDA) per subscriber,
EBITDA minus CAPEX per subscriber, and reported EBITDA margins.31 We request input on the use of
these profitability estimates in our analysis of the performance of the mobile wireless industry, including
to what extent profitability metrics are indicators of competition. Are there different estimates of
profitability that should be included in the Seventeenth Report, and how should they by analyzed? What
are the most appropriate ways to measure change in profitability over time for the industry as a whole, as
well as for individual firms?


Service Quality

Indicators of service quality performance in the Sixteenth Report included the results of consumer
surveys, such as those conducted by J.D. Power & Associates, Consumer Reports, and the Commission,
as well as the results of network speed and reliability tests performed by PCWorld magazine, and The Bureau seeks comment on the usefulness of these sources in measuring service and
network quality, and asks whether it should consider data from additional sources.
We invite comment on whether there are additional sources of information that we should include in the
Commission’s analysis of service quality, such as those that include quantifiable measures of network
quality.33 What factors do such sources take into account when evaluating service quality? For instance,

31 See Sixteenth Report at ¶ 284-289.
32 See Sixteenth Report at ¶ 316-317.
33 We note that last year Commission staff initiated a program to develop consistent information on industry wide
mobile broadband service performance in the United States. See Sixteenth Report at ¶ 292, citing “FCC Announces
‘Measuring Mobile America’ Program to Test Mobile Broadband Performance” News Release, Sept. 5, 2012, (visited April 25, 2013).

are there surveys that focus primarily or exclusively on network performance and reliability (incidence of
dropped calls, interference, and so forth), as well as surveys that also take into account other influences on
the customer experience, such as cost of service, customer service, and billing? In cases where surveys
measure overall customer satisfaction with the performance of wireless service providers rather than
network performance per se, what specific dimensions of service quality are survey respondents asked
about, and how are responses to different questions weighted to derive the overall score? What
methodologies do any recommended surveys use to select survey respondents, and do these
methodologies result in any sample bias?
Are data available from service providers or third parties that indicate that service and network quality
have improved or deteriorated during 2012 and 2013? If so, which elements of service quality have
changed, and in what ways? Finally, do commenters believe that the service quality experienced by rural
customers is adversely affected by their location?




Consumer Switching Costs

The costs that consumers may incur when switching providers include the time and expense required to
access information on available services, early termination fees (ETFs), and handset- and device-related
costs. We request updated information on these switching costs and ask whether additional costs should
be included in our analysis. Specifically, what information sources are available to consumers about the
availability, quality, and features of mobile wireless services? How have these information sources
evolved in 2012 and 2013? Are there new avenues for consumers to gain information through retailers or
third parties, such as online or in-store comparisons of pricing plans, services, and handsets and devices?
In addition, we seek information on consumer behavior in response to ETFs and other service pricing
plans and policies. To what extent are consumers able to avoid an ETF by paying the full, non-subsidized
price for a device, and how many consumers choose such an option? Which providers prorate ETFs over
the life of a contract, and by how much do prorated ETFs reduce the initial ETF? What do ETF trends
reveal about mobile wireless consumer behavior and competition? To what extend does a secondary
market for handsets and devices allow consumers to bypass ETFs? We also seek comment on services
that enable consumers to transfer the remainder of their contract term to others.
Finally, the Bureau seeks comment, in analyzing consumer switching costs, on the role of handsets and
devices. To what extent do consumers choose a service provider based on the handsets and devices
available for use on that provider’s network or on the applications available on these devices? Does this
vary among different types of consumers? How has this changed over time? Has expiration of the
Digital Millennium Copyright Act exemption permitting handset unlocking affected consumer choice?34
When handsets or devices are “locked,” or designed to work on a single network, to what extent can
consumers “unlock” or reprogram their devices so they will work on the network of another service
provider? How does device locking affect the willingness of consumers to switch providers? What
restrictions do providers place on the ability of consumers to unlock their devices? How clear and
accessible are these policies?
Switching costs may include the stranding of information stored on or mobile applications purchased for a
particular handset or device that cannot be transferred. To what extent are consumers able to transfer
stored information or downloaded applications from one handset or device to another? How does this

34 Exemption to Prohibition on Circumvention of Copyright Protection Systems for Access Control Technologies,
77 Fed. Reg. 65,264-66 (Oct. 26, 2012) (to be codified at 37 C.F.R. pt. 201).

change when both the old and new devices use the same platform or operating system? How significant
are the costs of reacquiring applications for most consumers, and how do they affect whether a consumer
is willing to switch to a new handset or device and/or a new provider?



The Bureau requests up-to-date churn information and asks whether we should include other churn data in
addition to blended churn, comparative churn, and the average lifetime of subscribers for several
providers. How did the overall churn rate, as well as the churn rates of particular service providers,
change during 2012 and 2013? In addition, in order to provide a detailed explanation of our analysis of
churn, we ask providers to submit descriptions of how they calculate churn. Do the differences in how
churn is calculated prohibit a meaningful comparison of churn figures across the mobile wireless
industry? Further, the Bureau seeks sub-national or regional churn data and churn data by demographic
groups. What are the reasons for consumer churn? Have the reasons for churn changed or remained the
same in 2012 and 2013? In particular, how has ongoing evolution in handset design and functionality
affected consumer churn decisions?




Input Segments


Infrastructure and Backhaul

In addition to spectrum access, mobile wireless services depend critically on access to productive inputs
such as network infrastructure (cell sites and towers),35 as well as backhaul facilities. Are there other key
input markets that affect overall competition? What data are available to measure these effects?
With respect to infrastructure, the Bureau seeks comment on how the structure of the infrastructure sector
affects competition in the mobile wireless services industry. How many new cell sites were deployed in
2012 and 2013, and by which service providers? To what extent do service providers own their own
towers or antenna facilities, and to what extent do they lease space from independent tower companies?
Does this vary across different types of geographic areas? How do these different approaches affect
service providers’ costs and competition in the mobile wireless services sector? In addition, what are the
major barriers or constraints faced by service providers needing to add or modify cell sites in their
networks? To what extent do regulatory and zoning approvals from state and local government
authorities act as barriers to tower and cell site deployment?
We seek information on the extent to which mobile wireless service providers will likely need to purchase
additional backhaul transmission facilities – such as T1 lines, cable, wireless microwave, and fiber optics
– in order to accommodate increasing mobile broadband traffic. Which types of technologies are service
providers using for backhaul, and what are the costs of the different technologies? We also seek comment
on how the structure of the market for backhaul services affects overall competition in the mobile wireless

35 The Middle Class Tax Relief and Job Creation Act of 2012 included a provision that would facilitate the
placement of wireless facilities on existing towers. See, Middle Class Tax Relief and Job Creation Act of 2012, Pub.
L. 112-96, H.R. 3630, 126 Stat. 156 at § 6409(a) (enacted Feb. 22, 2012). In January 2013, the Wireless
Telecommunications Bureau issued a Public Notice providing guidance on the interpretation of that section. See
“Wireless Telecommunications Bureau Offers Guidance On Interpretation Of Section 6409(A) Of The Middle Class
Tax Relief And Job Creation Act Of 2012,” DA 12-2047, rel. January 25, 2013.

service sector. How do the differences in technology, availability, and price for backhaul services impact


Downstream Segments


Handsets/Devices and Operating Systems

The Bureau invites commenters to submit data and information on the mobile wireless device and
operating system sectors of the mobile wireless ecosystem. What types of data sources, such as consumer
surveys, provide information on consumer preferences with regard to mobile devices? What are the main
factors consumers take into account when choosing a device? What types of handset models, features,
and innovations are most popular with different groups of consumers, and how has this changed in the
past year?
What is the nature of competition among handset providers and among operating system providers, and
how does this affect competition among mobile wireless service providers? What are the competitive
effects of vertical integration by device and operating system firms? What are the competitive effects of
“open” operating systems used in devices manufactured by competing handset providers? What are the
advantages and disadvantages of vertical integration of devices and operating systems versus the open
operating system model?
During 2012 and 2013, have service providers, operating system developers, and equipment
manufacturers changed the way consumers can access applications and use features on their devices?
How do devices and operating systems affect the types of applications that a subscriber can access,
download, or use? Do devices with greater functionality and more advanced features – such as
smartphones with web browsing capabilities and large, touch screens – allow users to access a wider
range of applications and content than devices with more basic capabilities? To what extent does the
ability to use a wide array of applications and services influence a consumer’s device purchase?
Is there a market for multi-standard handsets that work within U.S. frequency allocations? If yes, what
are the benefits of such devices for consumers? Are multi-standard handsets currently available to
American consumers? How does the availability of such multi-standard handsets affect competition?
How are mobile wireless handsets or devices restricted for consumer use?
What types of mobile wireless devices, other than handsets with voice capabilities, are currently being
used by consumers? How do these devices complement mobile wireless handsets? How are these
devices integrated with other segments of the mobile wireless ecosystem?


The Bureau invites commenters to submit data and information on the applications sector of the mobile
wireless ecosystem. What are the most common ways that consumers access applications on their mobile
wireless handsets and devices, and how has this changed in the past year? What is the role of application
stores offered by operating system developers and service providers? Which application stores are most
popular with consumers, and how many applications are available on and downloaded from such stores?
What types of applications are most popular with consumers? What data sources, such as analyst reports
and consumer surveys, provide information about consumer preferences with regard to mobile
applications and application stores?
To what extent can consumers access and use the content and applications of their choice? How does this
vary by device, operating system, service plan, and service provider? Which of these elements has the
greatest impact on consumer choice? What other factors besides the level of choice – such as price, ease

of use, security, and reliability – play a role in a consumer’s preference with respect to accessing mobile




Competition in Voice Services

The Bureau asks for comment and sources of information on the extent to which mobile voice service
competes with wireline voice service. What type of data provides evidence on the extent of wireless-
wireline voice substitution? How many and what types of households or individuals have “cut the cord”
and use a mobile phone as their sole phone? Do mobile-only households have higher voice usage levels
than those with wireline phones? Are there any new developments in intermodal voice competition that
have occurred in 2012 and 2013? What are the major reasons for these developments?


Competition in Broadband Services

Mobile wireless technologies appear to play an increasingly significant role in providing broadband
services. To what extent do mobile broadband services complement or compete with broadband services
offered over wireline technologies such as DSL, cable, or fiber to the home? To what extent are
consumers substituting fixed with mobile data usage for certain functions and applications, such as web
browsing, e-mail, and accessing social networking sites? What factors – such as price, coverage, uplink
and downlink speeds, equipment, and bundling – influence the extent to which mobile broadband services
compete with wireline broadband services?


Wireless Local Area Networks

The wireless local area network technology, Wi-Fi, enables consumers to connect to the Internet
wirelessly within the range of 100-300 feet at home, work, or public “hot spots” – such as restaurants,
coffee shops, hotels, airports, convention centers, and city parks – typically using a laptop computer with
an internal or external Wi-Fi modem.36 Wi-Fi can serve as both a competitor and a complement to the
wide area networks deployed by facilities-based mobile wireless service providers.37
Some mobile wireless service providers use Wi-Fi hot spots to supplement or complement their mobile
voice and data offerings provided through the licensed use of spectrum. To what extent are mobile
wireless providers using Wi-Fi to offload data traffic or for other purposes? Is data available on the
percentage of smartphone or tablet data traffic that travels over Wi-Fi? Have new services or applications
that integrate both mobile wireless and Wi-Fi networks been launched in the past year? To what extent is
Wi-Fi being used to provide location-based services?
In addition, we ask for information on the extent to which Wi-Fi networks are being used for voice as
well as data services and on whether such voice services are being provided using Voice over Internet
Protocol (VoIP) technology or other technologies. Are there estimates available on the amount of voice
traffic on Wi-Fi networks? What applications and equipment are available for voice over Wi-Fi? To
what extent are Wi-Fi-based voice and data services considered to be complements to, or substitutes for,
the mobile voice and data services offered over mobile wireless networks?

36 Wi-Fi networks generally must rely on another type of broadband connection, such as wireline, cable, or wireless,
for access to the Internet.
37 WLAN technologies operate on an unlicensed basis under Part 15 of the Commission’s rules. See 47 C.F.R. Part

Finally, we seek information on the total number of public hot spots, as well as the number of free hot
spots and fee-based hot spots. We also request information on the pricing of fee-based hot spots. Has the
proportion of free versus fee-based hot spots changed over the past year? Is there a difference in
connectivity speeds, reliability, and security at free versus fee-based hot spots? To what extent do hot
spots compete with mobile broadband offerings and wireline broadband services? Do the differences
between free and fee-based hot spots influence competition between Wi-Fi providers and mobile wireless
service providers?



To obtain a better understanding of the state of mobile wireless competition in rural areas and tribal lands,
the Bureau requests comment on the extent of mobile voice and broadband network deployment in these
areas. Are there noteworthy trends in the state of competition in rural areas and tribal lands?
Furthermore, regarding rural areas and tribal lands, to what extent do providers offer coverage only in
certain parts of these areas, such as near major roads, where they do not market service to residents of
those areas? If this is the case, could the Commission’s analysis of mobile wireless service deployment
and competition be further improved if mobile wireless providers indicated the parts of their coverage
areas in which they compete to offer service and the parts that are used only to provide coverage to
traveling subscribers based in other locations?
Are commenters aware of pricing studies that look at urban versus rural or other sub-national mobile
wireless pricing? We ask commenters to provide input on how the Commission can examine whether
pricing in rural areas conforms to national pricing plans or whether there are meaningful differences in
mobile wireless pricing plans and pricing promotions between urban and rural areas. To the extent that
such differences exist, what are the reasons for such differences?
Finally, the Bureau seeks comment on how mobile wireless service providers’ spectrum holdings vary in
urban versus rural areas. To what extent is spectrum unused or under-utilized by licensees to a greater
extent in rural versus urban areas? Do licensees plan to deploy networks and offer service using such
spectrum in the future? To what extent are service providers and licensees in rural areas spectrum
constrained? Is there a greater benefit for service providers to holding spectrum in the frequencies below
1 GHz in rural versus urban areas? If so, why?



The Bureau invites commenters to submit any studies or analyses that compare the mobile wireless
marketplace in the United States with that in other countries. Previous reports have relied on data
published by Merrill Lynch comparing mobile penetration rates, usage levels, and prices in the United
States with those in other countries. Are there additional sources the Commission should consider that
provide data on mobile wireless prices, usage, subscribership, and service quality around the world?
What is the interplay among the regulatory frameworks, provider practices, and market conditions in
other countries? In particular, are there ways to measure the benefits or harm to consumers as a result of
provider practices with regard to mobile applications and devices?



In addition to alternative sources of data and information to update indicators of competition used in the
Sixteenth Report and previous Competition Reports, the Bureau invites commenters to recommend
additional or alternative indicators of competition to enhance the analysis of competitive market
conditions with respect to mobile wireless in the Seventeenth Report. In each case, the commenter should
also submit, or identify sources for, the data and information needed to compile the proposed indicator.
As necessary and appropriate, the commenter should also explain how the recommended indicator fits

into the framework used in the Sixteenth Report. Are there additional measures the Commission can take
to improve the dissemination of the data for the Seventeenth Report, or to make its analysis more
transparent and robust?
Finally, the Bureau invites commenters to propose additional topics of interest that are related to the
assessment of the status of competition in the mobile wireless marketplace. For example, have any
noteworthy new trends or developments relevant to the assessment of competitive conditions in the
mobile wireless marketplace emerged during 2012 and 2013?



Pursuant to sections 1.415 and 1.419 of the Commission’s rules, 47 CFR §§ 1.415, 1.419, interested
parties may file comments on or before

June 17, 2013

and reply comments on or before

July 1, 2013

All filings should refer to WT Docket No. 13-135. Comments may be filed: (1) using the Commission’s
Electronic Comment Filing System (ECFS), or (2) by filing paper copies. See Electronic Filing of
Documents in Rulemaking Proceedings, 63 FR 24121 (1998).
Comments and reply comments filed in response to this Public Notice will be available for public
inspection and copying in the Commission’s Reference Center, Room CY-A257, 445 12th Street, S.W.,
Washington, D.C. 20554, and via the Commission’s Electronic Comment Filing System (ECFS) by
entering the docket number, WT 11-186. Copies of the request are also available from Best Copy and
Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-0169, e-mail
Comments may be filed using the ECFS or by filing paper copies. See Electronic Filing of Documents in
Rulemaking Proceedings, 63 Fed. Reg. 24121 (1998). Comments filed through the ECFS can be sent as
an electronic file via the Internet to Generally, only one copy of an
electronic submission must be filed. If multiple docket or rulemaking numbers appear in the caption of
this proceeding, however, commenters must transmit one electronic copy of the comments to each docket
or rulemaking number referenced in the caption. In completing the transmittal screen, commenters should
include their full name, U.S. Postal Service mailing address, and the applicable docket or rulemaking
number. Parties may also submit an electronic comment by Internet e-mail. To get filing instructions for
e-mail comments, commenters should send an e-mail to , and should include the following
words in the body of the message, “get form.” A sample form and directions will be sent in reply.
Parties who choose to file by paper must file an original and one copy of each filing. If more than one
docket or rulemaking number appears in the caption of this proceeding, commenters must submit two
additional copies for each additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or
overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S. Postal
Service mail). All filings must be addressed to the Commission’s Secretary, Office of the Secretary,
Federal Communications Commission, as follows:
-All hand-delivered paper filings for the Commission’s Secretary must be delivered to FCC
Headquarters at 445 12th St., S.W., Room TW-A325, Washington, DC 20554. All hand deliveries
must be held together with rubber bands or fasteners. Envelopes must be disposed of before
entering the building. The filing hours at this location are 8:00 a.m. to 7:00 p.m.



This is the


location where hand-delivered or messenger-delivered paper filings
for the Commission’s Secretary will be accepted. The Commission’s former filing location at
236 Massachusetts Ave., N.E., is permanently closed.
-Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must

be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
-U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be addressed to 445
12th Street, S.W., Washington, DC 20554.
-All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal
Communications Commission.
Parties are requested to send one copy of their comments and reply comments to Best Copy and Printing,
Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (800) 378-3160, e-mail
Alternate formats of this Public Notice (computer diskette, large print, audio recording, and Braille) are
available to persons with disabilities by contacting the Consumer & Governmental Affairs Bureau at
(202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to
For further information, contact Paroma Sanyal, Spectrum & Competition Policy Division, Wireless
Telecommunications Bureau, (202) 418-2425, or Heidi Kroll, Spectrum & Competition Policy Division,
Wireless Telecommunications Bureau, (202) 418-2361.

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