The CCA Voice - Spring/Summer 2014 - (Page 21)

THEME: ON THE EDGE: MEETING CONSUMER DEMAND Competition - The Foundation for a Healthy Industry By: Kathleen Ham Vice President, Federal Regulatory Affairs, T-Mobile USA C ompetitive wireless providers must remain vigilant as policymakers in Washington take up issues such as spectrum distribution, facilities deployment, network interoperability, roaming, and the IP transition, to ensure the industry does not revert to a duopoly, robbing consumers of the benefits only competition can bring. For this very reason, the Competitive Carriers Association (CCA) has called for the creation of a Wireless Competition Task Force at the Federal Communications Commission (FCC), which would be charged with analyzing, developing, and implementing proposals for promoting wireless competition in the 21st century. Here are a few measures that we at T-Mobile would like to see become priorities for policymakers, and if they are already high on the list, we urge prompt action. First, as has been evident for several years, wireless carriers need more spectrum for commercial broadband services, and they need it now. The FCC already has made progress on several initiatives to accomplish this goal, including working with the National Telecommunications and Information Administration (NTIA) to repurpose the 1755-1780 MHz band, proceeding with plans to auction the 600 MHz band, and auctioning the H Block and the 1695-1710 MHz band. Rapid decisions on these issues will go a long way toward alleviating the spectrum crisis. Second, while allocation of additional spectrum is essential, all wireless providers need a fighting chance to purchase licenses at auction and in the secondary market to compete on equal footing with the largest two carriers. This is especially the case when valuable lower-band frequencies are at stake, such as those in the 600 MHz band. Accordingly, the FCC should revise its spectrum aggregation rules to ensure they reflect the difference in spectrum value and utility above and below 1 GHz. Third, it is time to stop pretending that each wireless carrier can and should build duplicate networks in every city, town, and rural area across the country. Despite T-Mobile's substantial investment in expanding its network, like all other wireless providers, it still requires access to roaming to remain competitive. The FCC's 2011 order, which directed most facilities-based carriers to offer data roaming arrangements on commercially reasonable terms and conditions, was a good first step, but obstacles remain. The FCC should help clarify exactly what the term "commercially reasonable" means in the context of roaming rates, and be prepared to act expeditiously on legitimate roaming complaints. Fourth, greater equipment interoperability is needed so that all licensees can take advantage of a global market for handsets. The FCC has taken important steps to address this problem in the 700 MHz band, and ensuring interoperability in the 600 MHz band will be critical as well. Eliminating the ability of carriers to create "boutique" band classes by unnecessarily restricting handset utility will increase the availability, affordability, and portability of end-user equipment, decrease consumer-switching costs, and promote the deployment of mobile broadband services. Fifth, the Commission should facilitate competitive IP interconnection arrangements among carriers as the transition to fully IP networks occurs. THE Key to this would be the establishment of a more efficient interconnection architecture with a small number of regional IP points of interconnection, instead of replication of the old phone network as some of the old phone companies demand. Sixth, the processes for tower siting and antenna collocation remain cumbersome today, as does the deployment of distributed antenna systems (DAS) and small cell technologies. Some helpful measures would be establishing a permanent exemption from the environmental notification procedures in certain situations, allowing collocation on many older structures without burdensome documentation requirements, and removing ambiguities in the FCC's review and approval process that can cause needless delays in DAS deployment. And finally, the Commission should continue to reform its universal service regime in a manner that takes into account the increasing popularity of wireless over wireline services. Today, wireless carriers receive less support from the universal service fund (USF) to expand service to rural and highcost areas, but at the same time, they are required to bear an increasingly disproportionate share of the USF contribution burden. New policies should ensure that wireless carriers do not have to subsidize their wireline competitors. Consumers today are adopting new wireless technologies as fast as the industry can develop them, and the possibilities appear limitless. Therefore, to some, it may not appear immediately necessary to focus on policy matters such as spectrum allocation, roaming, and tower siting. But, all great endeavors require strong foundations, and the best foundation for the wireless industry is competition. VOICE * * Spring/Summer 2014 21

Table of Contents for the Digital Edition of The CCA Voice - Spring/Summer 2014

Chairman’s Letter by Jonathan Foxman
A Message from the President and CEO by Steven K. Berry
CCA’s 2013 Annual Achievement Award Winners
Staying Ahead of “The Next Big Thing”
Near Tragedy in Nevada Demonstrates Need for Rural Investment
Competition – The Foundation for a Healthy Industry
Putting the “Incentive” in Incentive Auction
Beat ’Em or Join ’Em: Data Roaming in a 4G LTE World
2014: The Year of Small Cell Deployment
Band Class 12 – Beyond Broadband
Chat Mobility Utilizes Multi-Faceted Plan to Attract & Retain Customers
Blurred Lines: Reinventing in the Rural Market
Regional Carrier Bridges Digital Divide with Massive Network Upgrade
Wireless Challenges and Solutions for Competitive Carriers
Expanding America’s Wireless Networks: It Takes a Village
Lead with Location
Giving Your Customer Their Preferred Choices in Billing: Paper, Electronic, and Mobile
Monetizing Data Demand with Personalized Services
Making Sure Long-Distance Calls Reach Rural Subscribers
Mobility Growth with Emerging Devices
Mobile Broadband and the Rise of Mobile Security Challenges
On the Verge: Fulfilling 4G-LTE Consumer Demand in America
Transform Your Business by Making It Simpler
Lessons Learned on the Road to LTE
Let’s Get Personal
Even If the Voice Packets Make It, Does the Lack of Quality Ruin It?
Our Connected World: The Necessity of NFV for Telcos
Ten Hot Consumer Trends in 2014 and Beyond
Gain Your Edge: Effective Edge Out Strategies with 4G LTE
Reaching Consumer Demand Through Marketing in the Rural Driven Markets
Tips for Improving the Customer Experience
Creating a Super High-Capacity Network in Rural America
Your Competitors Are Coming for Your Customers
Index of Advertisers
Congressional Spotlight: Representative Robert “Bob” Latta

The CCA Voice - Spring/Summer 2014