CCA Advocacy Agenda
CCA 2012 Issue Advocacy: Promoting Competitive Connectivity
In 2012, CCA will promote policies that support competitive connectivity while continuing to inform and educate federal policy-makers on increased industry consolidation involving Verizon Wireless and AT&T Mobility (the Big Two) and the resulting effect on competition in the mobile wireless industry. CCA promote policies that foster and support competition for the benefit of competitive carriers and consumers.
As a result of consolidation, the mobile wireless industry has reached a near duopoly, with the industry dominated by the Big Two. This environment limits consumer choice, slows deployment of high speed mobile broadband, stifles mobile innovation, and stalls economic and job growth. CCA represents every competitive wireless carrier and will continue to pursue policies that eliminate the Big Two’s control over the market and foster competition throughout the industry.
In order to support competitive connectivity, CCA will prioritize the following issues in 2012:
Interoperability/Handsets – Maximum utilization of finite, tax-payer spectrum resources cannot be achieved without interoperability. Reversing spectrum band fragmentation and restoring interoperability are critical to allowing all carriers and consumers to connect. Additionally, interoperability will provide consumers and public safety choice among devices they desire at home or roaming. As additional spectrum becomes available for mobile broadband use, interoperability is essential to ensuring viable buildout opportunities for all operators, as well as maximum spectrum revenues. CCA will continue to pursue competitive device policies that allow every carrier, large and small, to access the latest, cutting edge devices.
Data Roaming – The recently adopted Data Roaming Order must be defended against Verizon’s appeal, and the requirements of that Order should be expanded to provide consumers with ubiquitous access to services in a 4G world. The bright line between voice and data services has significantly eroded and will likely disappear in the near term. Roaming is thus required regardless of what services are being used.
Universal Service Fund Reform – The recently adopted USF-ICC Reform Order provides insufficient support to wireless service and inexplicably rewards wireline carriers with preferential treatment. CCA will work to provide support for consumers’ wireless choices and competition among providers. CCA will also support our members’ appeals of the Order. CCA will also support long term reform, including contribution reform.
Consolidation – The Big Two continue their consolidation through acquisitions of spectrum or competitors. CCA will oppose anticompetitive takeovers that further increase market power for the largest two carriers at the expense of consumers and competition, urging for necessary conditions that help to ensure a healthy, innovative, and vibrant industry. Absent such conditions, CCA will recommend denying approval of anticompetitive transactions.
Spectrum Availability, Allocation and Auctions – To provide maximum broadband coverage, competitive carriers need low-band spectrum that is interoperable and free from interference. CCA will support federal efforts to make more spectrum available for competitive carriers. As the FCC moves forward with incentive auctions, the FCC must exercise its authority in a manner that recognizes its flexibility to set appropriate eligibility and license conditions that support competition in the public interest, convenience and necessity. Spectrum should be licensed in an appropriate mix of all size geographic blocks to increase the potential number of carriers and new entrants that may compete in a spectrum auction. As new spectrum is brought to auction, CCA will push for rules that prevent excessive spectrum aggregation and support competition. CCA will also promote policies that support competition in the secondary market.
Nondiscriminatory Interconnection – As the telecommunications industry continues to migrate from the traditional Public Switched Telephone Network and move all traffic to packet based technology, CCA will continue to encourage a strong national interconnection policy embodied in Section 251 for IP-based interconnection and transit services. Such a framework will be essential to ensuring just and reasonable prices and nondiscriminatory treatment for all carriers.
NG911 – Federal policymakers must ensure that competitive carriers are not required to deploy Next Generation 9-1-1 (NG911) emergency services in a way that is debilitating or cost-prohibitive to providing communications services in general, especially in rural areas. Deployments of new technologies, including public safety deployments of 911 services, are typically made in urban areas first. Rural Public Safety Answering Points (PSAPs) tend acquire and implement technology more slowly and at a later date relative to their urban counterparts. NG911 requirements for the wireless industry should account for these slower rural deployments, and, thus, rural and regional carrier compliance requirements should not precede PSAP deployments. Federal policymakers must recognize the increased impact of fixed-cost upgrades to carriers serving smaller customer bases. Similar to other 911 requirements, policy-makers must also recognize that rural and regional carriers will need additional time for deployment.
Special Access – The large national carriers have an overwhelming and anticompetitive share of special access markets across the nation, and particularly in rural and regional portions of the U.S. As a result, special access providers like AT&T and Verizon are preventing competitive entry by failing to offer special access services at just and reasonable rates, terms and conditions. The FCC is currently evaluating the proper regulatory framework to adopt for special access service pricing, which is necessary to protect consumers, spur market entry and foster competition. CCA will continue to track the FCC’s special access proceeding to ensure competition in the special access market.
FCC Authority – CCA encourages and supports a return to policies that foster competition in the wireless industry. In the absence of vigorous competition, it is critical that the FCC retain the authority to establish a level playing field that allows all the carriers to compete through appropriate and narrowly tailored exercise of its regulatory authority.
Cybersecurity – With wireless networks playing an important role in the communications infrastructure throughout the country, CCA will work to ensure appropriate safeguards are enacted to protect the industry’s infrastructure from cyber attacks. New Cybersecurity regulations that do not impose excessive burdens on carriers or impede expansion of mobile broadband access should be established with the support and input of all wireless carriers.
