1
PUBLIC NOTICE
FEDERAL COMMUNICATIONS COMMISSION
445 12th Street, S.W.
WASHINGTON, DC  20554                                                                                         DA 08-453
News media information 202/418-0500 Fax-On Demand 202/418-2830 Internet: http://www.fcc.gov   ftp.fcc.gov 
Released:  February 25, 2008
WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON COMMERCIAL 
MOBILE RADIO SERVICES MARKET COMPETITION
WT Docket No.  08-27
Comments Due:  March 26, 2008
Reply Comments Due:  April 10, 2008
In 1993, Congress created the statutory classification of Commercial Mobile Services1 to promote the 
consistent regulation of similar mobile radio services.2 At the same time, Congress established the 
promotion of competition as a fundamental goal for Commercial Mobile Radio Service (CMRS) policy 
formation and regulation.  To measure progress toward this goal, Congress required the Commission to 
submit annual reports (CMRS Reports) that analyze competitive conditions in the industry.3
This Public Notice solicits data and information in order to evaluate the state of competition among 
providers of CMRS for its Thirteenth Annual Report and Analysis of Competitive Market Conditions 
with Respect to Commercial Mobile Services (Thirteenth Report).  The statute requiring the 
Commission to submit annual reports providing an analysis of competitive market conditions with respect 
to CMRS stipulates that this analysis shall include, among other things, an analysis of whether or not 
there is effective competition.4 In this proceeding, the Wireless Telecommunications Bureau (Bureau) 
seeks to update and improve the indicators of competition for the Commissions next report to Congress 
and to determine whether or not there is effective competition in the CMRS market.  The Bureau seeks 
public input to facilitate this determination.
  
1 The term commercial mobile service is defined by the Communications Act of 1934, as amended (the Act), as 
any mobile service  that is provided for profit and makes interconnected service available (A) to the public or (B) 
to such classes of eligible users as to be effectively available to a substantial portion of the public, as specified by 
the Commission.  Communications Act  332(d)(1), 47 U.S.C.  332(d)(1).  Mobile service is defined at Section 
3 of the Act.  Communications Act  3(27), 47 U.S.C.  153(27).  The term commercial mobile service came to be 
known as the commercial mobile radio service.  47 C.F.R.  20.3.
2 The Omnibus Budget Reconciliation Act of 1993, Pub. L. No. 103-66, Title VI,  6002(b), amending the 
Communications Act of 1934 and codified at 47 U.S.C.  332(c).
3 47 U.S.C.  332(c)(1)(C).
4 Id.
2
The Commission is constantly striving to improve and refine the way it collects, analyzes, and reports 
industry data.  Importantly, the Twelfth Report5 introduced a new data source that allowed for a 
significantly more granular and accurate analysis of mobile telephone service deployment and 
competition.  This new data source provided the FCC with a set of maps that set out the detailed 
boundaries of the network coverage areas of every operational mobile telephone provider in the United 
States.  Using these maps, the FCC was able to estimate a number of metrics based on the 8 million 
census blocks that comprise the U.S., rather than the 3,200 counties on which the FCC had previously 
relied.  Among the metrics significantly enhanced by this new data source were:  (1) the percentage of the 
U.S. population covered by a certain number of providers, and (2) the percentage of the population 
covered by different types of network technologies.  
For the Thirteenth Report, the Bureau is seeking to increase its understanding of conditions in the CMRS 
marketplace, particularly with regard to new technological developments.  Therefore, this Public Notice
contains a new series of questions asking for data and analytic recommendations related to that effort.
In the four most recent CMRS Reports, the Commission has reviewed competitive market conditions 
using a framework that groups indicators into four categories: (1) market structure; (2) provider conduct; 
(3) consumer behavior; and (4) market performance.6 Accordingly, when submitting responses to this 
Public Notice, commenters should, to the extent possible, present materials addressing these four 
categories of indicators.   In addition to these issues and the specific matters discussed below, the Bureau 
seeks comment generally on which indicators are useful for analyzing competitive market conditions with 
respect to CMRS.  We also request comment on what specific criteria should be used to determine 
whether there is effective competition among CMRS providers. 7
Industry members, members of the public, and other interested parties are encouraged to submit 
information, comments, and analyses regarding competition in the provision of CMRS.  Commenters 
desiring confidential treatment of their submissions should request that their submission, or a specific part 
thereof, be withheld from public inspection.8 In order to facilitate its analysis of competitive trends over 
time, the Commission requests that parties submit current data as well as historic data that are comparable 
over time.
  
5 In the Matter of Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual 
Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Radio Services, WT 
Docket No. 07-71, Twelfth Report, FCC 08-28 (rel. Feb. 4, 2008) (Twelfth Report).
6 Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and 
Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, Ninth Report, 19 FCC
Rcd 20597 (2004); Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual 
Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, Tenth Report, 
20 FCC Rcd 15908 (2005); Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, 
Annual Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, 
Eleventh Report, 21 FCC Rcd 10947 (2006) (Eleventh Report);  Twelfth Report, FCC 08-28.  The reports can also 
be found on the FCCs web site at <http://wireless.fcc.gov/cmrsreports.html>.
7 In view of a separate ongoing proceeding on roaming obligations of CMRS providers, this Public Notice omits 
questions about roaming.  See Reexamination of Roaming Obligations of Commercial Mobile Radio Service 
Providers, WT Docket No. 05-265, Memorandum Opinion & Order and Notice of Proposed Rulemaking, 20 FCC 
Rcd 15047 (2005).  
8 47 C.F.R.  0.459.
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I. MOBILE TELECOMMUNICATIONS MARKET STRUCTURE
The Bureaus analysis of market structure will focus on the current level of concentration and the ease or 
difficulty with which new providers can enter the market.  The Bureau invites commenters to address the 
sources of data and the analysis of metrics relating to both aspects of market structure in the sections 
below.
A. Service Availability and Deployment 
1. Service Deployment, Granularity of Data, and Coverage Maps
As discussed above, in the Twelfth Report, we improved our examination of competition in the mobile 
telephone sector by compiling a list of census blocks where operators offer digital and next generation 
technologies, using data supplied under a contract with American Roamer, an independent consulting 
firm that produces coverage maps based on public sources as well as confidential information supplied 
directly by service providers.9 We seek comment on our analysis. Is this new methodology for tracking 
facilities-based competitors appropriate? Are census blocks an appropriate size to analyze the number of 
CMRS competitors and the deployment of various services?
2. Mobile Data and Broadband Deployment
The Bureau seeks comment on deployment of newer network technologies such as EDGE Enhanced Data 
Rates for Global System for Mobile Communications Evolution (EDGE), Wideband Code Division 
Multiple Access (WCDMA), High-Speed Downlink Packet Access (HSDPA),  Evolution Data 
Optimized (EV-DO) or EV-DO Rev A, and WiMax IEEE 802.16e-2005 (WiMax).  The Bureau also 
is seeking comment on ways it could deepen and refine its understanding of broadband availability and 
deployment.   
The Bureau is particularly interested in changes that have occurred in mobile data and broadband network 
deployment since the Twelfth Report.  For example, what advanced wireless applications are being 
offered using these technologies?   
3. Service Deployment in Rural Areas and Tribal Lands
To obtain a better understanding of the state of competition in rural areas and tribal lands, the Bureau 
requests comment on the extent of mobile voice and data service in these areas.  To what extent are 
advanced wireless services being offered in rural areas and tribal lands?  Are there noteworthy trends in 
the state of competition in rural areas and tribal lands?
Furthermore, regarding rural areas and tribal lands, do providers provide 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 true, could the Bureaus analysis be further improved if 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? 
B. Other Competitors to Terrestrial CMRS Providers
1. Mobile Satellite Service Providers  
The Bureau seeks information about the current provision of CMRS by mobile satellite service (MSS) 
  
9 Twelfth Report, at  35 & note 61.
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companies, including the frequency bands they are employing.10 The Bureau requests data on prices (of 
both service and handsets) and coverage.  In order to obtain a greater understanding of the MSS market, 
we also request data on:  (1) the number of subscribers; (2) minutes of use; and (3) differences in phone 
usage between rural and urban areas.  In addition, we ask for comment on the extent to which CMRS 
provided by MSS functions as a substitute for terrestrial CMRS services.11 The Bureau also requests 
information on the current status and deployment of Ancillary Terrestrial Component systems by MSS 
companies.
2. Resale/MVNO Providers 
To what extent are resellers/Mobile Virtual Network Operators (MVNOs) creating competitive 
pressures in the mobile telecommunications sector?  Who are the major resellers/MVNOs in the United 
States?  How many subscribers do they have?  From the consumers perspective, what are the benefits of 
buying from a reseller/MVNO versus a facilities-based provider?  Are resellers/MVNOs selling to 
specific demographic segments? 
C. Horizontal Concentration
1. NRUF Data and Output Market Concentration 
The main source of data the Bureau uses to calculate output market concentration statistics for the 
purpose of this report is the Numbering Resource Utilization / Forecast (NRUF) data that are submitted 
to the Commission on a rate center basis.12 The Commission has found that NRUF data are a reasonable 
proxy for mobile telephone subscribers, and in previous CMRS Reports, utilized the NRUF data to 
calculate market concentration measures for Economic Areas (EAs). 13 We seek comment on whether 
any market or technological developments indicate that NRUF data may not reasonably reflect the 
number of mobile telephone subscribers.  The Bureau also seeks comment whether EAs, given any 
market or technological developments, continues to be an appropriate geographic area for the calculation 
of mobile telecommunications concentration measures based on NRUF data.  
  
10 In addition to terrestrial mobile services, CMRS includes MSS that provide CMRS directly to end users.  See 47 
C.F.R.  20.9(10).
11 While terrestrial and satellite CMRS operators provide wireless mobile voice and data connectivity, the Satellite 
Flexibility Order noted in 2003 that, since terrestrial CMRS and MSS are expected to have different prices, 
coverage, product acceptance and distribution, the two services appear, at best, to be imperfect substitutes for one 
another that would be operating in predominately different market segments. Twelfth Report, FCC 08-28 at 15  
16; see also Flexibility for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz Band, 
the L-Band, and the 1.6/2.4 GHz bands; Review of the Spectrum Sharing Plan Among Non-Geostationary Satellite 
Orbit Mobile Satellite Service Systems in the 1.6/2.4 GHz Bands, Report and Order and Notice of Proposed 
Rulemaking, 18 FCC Rcd 1962, 1964 (2003) (Satellite Flexibility Order), modified sua sponte, Order on 
Reconsideration, 18 FCC Rcd 13590 (2003), on reconsideration, Memorandum Opinion and Order and Second 
Order on Reconsideration, 20 FCC Rcd 4616 (2005), further recon pending.   
12  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, in order 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.
13 EAs are defined by the U. S. Department of Commerces Bureau of Economic Analysis.  See Twelfth Report, FCC 
08-28 at 98 n. 564.
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2. Mobile Data Subscriber Shares 
One limitation of NRUF data for the purpose of measuring concentration levels in the mobile data market 
is that they do not reveal whether mobile telephone subscribers use their handsets for mobile data services 
as well as to make and receive calls.  We request sources of information on the number of mobile data 
subscribers that individual providers serve, or the percentage of their customer base that uses mobile data 
services as well as mobile voice.  Do individual providers mobile data market shares differ significantly 
from their mobile telephony market shares, and if so, to what extent?
D. Consolidation and Exit 
The Bureau seeks comment on the effects of consolidation in the mobile telecommunications market.  
Has consolidation affected mobile data services differently than mobile telephone services?  Has 
consolidation affected pricing, roll-out of new services, or equipment offerings?  Has consolidation 
affected rural areas differently than urban areas? Are the effects of consolidation or exit different for 
mergers and acquisitions, swaps, joint ventures, and bankruptcies?  
E. Barriers to Entry 
Barriers to entry in the mobile telecommunications market may include first-mover advantages, large 
sunk costs, and access to spectrum. 14 The Bureau seeks comment on these and other types of barriers to 
entry in the mobile telecommunications market.  What are the most significant barriers to entry in the 
mobile telecommunications market?  Are barriers to entry different in rural and urban areas?
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 CMRS industry.  Are existing service providers spectrum constrained? If so, in 
which geographic markets are providers most likely to be constrained?  Have these providers become 
more spectrum constrained after rolling out advanced wireless services?  Do potential entrants have 
sufficient opportunities to access spectrum?  As advanced wireless technologies become more prevalent, 
will potential entrants have more or fewer opportunities to access spectrum?  In addition, the Bureau 
seeks comment on whether its policy to facilitate spectrum leasing will provide sufficient opportunities 
both for existing providers to expand their operations and for new mobile telecommunications providers 
to enter the market.  Finally, we ask about the likely impact of the recent auction of 700 MHz spectrum on 
competition in the CMRS market as well as the impact of any anticipated auctions.15  
  
14 See Horizontal Merger Guidelines issued by the U.S. Department of Justice and the Federal Trade Commission at 
 3.0 (Apr. 2, 1992, revised Apr. 8, 1997) (discussion of barriers to entry); Dennis W. Carlton and Jeffrey M. 
Perloff, Modern Industrial Organization, 76-82 (3rd ed., Addison, Wellsley, Longman, Inc., 1999) (same).  See also 
2000 Biennial Review Spectrum Aggregation Limits for Commercial Mobile Radio Services, WT Docket No. 01-
14, Report and Order, 16 FCC Rcd 22668, 22688-91 (2001).
15 Auction of 700 MHz Band Licenses Scheduled for January 24, 2008, Notice and Filing Requirements, Minimum 
Opening Bids, Reserve Prices, Upfront Payments, and Other Procedures for Auctions 73 and 76, Public Notice, 22 
FCC Rcd 18141 (2007).  With respect to the 700 MHz Band, the Digital Television and Public Safety Act of 2005 
(DTV Act), amended Section 309(j)(14) of the Communications Act, 47 U.S.C.  309(j)(14), to establish February 
17, 2009 as a firm deadline for the end of the digital television (DTV) transition period, and to require that the 
Commission commence the auction of certain recovered analog broadcast spectrum no later than January 28, 2008.  
Until the transition is complete, the 700 MHz Band will remain occupied by television broadcasters.   Nevertheless, 
substantial portions of the band are not so encumbered and are available for immediate use by new licensees.
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II. PROVIDER CONDUCT IN THE MOBILE TELECOMMUNICATIONS MARKET 
A. Price Rivalry 
1. Pricing Plan Innovations
What innovations have occurred with pricing plans since the Twelfth Report?  Have these pricing 
innovations spread throughout the mobile telecommunications market or have they been limited to a 
subset of providers?  To what extent do new types of pricing plans reflect price rivalry among CMRS 
providers?   Have pricing innovations been more widely adopted in the last year? The Bureau seeks 
information on which providers offer nationwide pricing plans, particularly those that are not typically 
described as being nationwide operators, and request descriptions of the terms of such plans.  Do 
providers engage in rivalry via handset pricing?  Has this changed in the last year?
2. Pricing Plans for Mobile Data and Broadband Services
The Bureau also seeks comment and information on pricing trends for mobile data services offered by 
mobile telephone providers.  Are there data on the pricing of these services available on a national or sub-
national level?  How are new or enhanced mobile data services such as location-based services, games, 
digital photos, video services, and downloadable music priced?  Are there any reports or analyses that 
discuss pricing trends for mobile data services?
3. Pricing Plans in Rural Areas
The Bureau asks for comment and information on whether there are meaningful pricing differences 
between urban and rural areas.  Did differences exist in the past that no longer exist today?  To the extent 
that such differences exist, what are the reasons for such differences?
B. Capital Expenditures 
Have capital expenditures by mobile telecommunications providers increased or decreased since the 
Twelfth Report?  For what purposes are providers using capital expenditures?  Are there any studies or 
analyst reports on the capital expenditures of nationwide providers versus regional/local providers?  Does 
data exist on capital expenditures by geographic region?
C. Technology Deployment and Upgrades 
For the Thirteenth Report, the Bureau requests information on the extent to which mobile 
telecommunications providers have upgraded, or plan to upgrade, their networks to more advanced 
technologies such as WCDMA, HSDPA, High Speed Uplink Packet Access (HSUPA), EV-DO, EV-
DO Rev A, EV-DO Rev B, WiMAX,  Long Term Evolution (LTE), and Ultra Mobile Broadband 
(UMB).  How extensively have providers deployed more advanced technologies (e.g., have providers 
focused on urban areas only, or have they deployed these technologies in rural areas as well)?  What, if 
any, are the relative advantages and disadvantages of these various technologies, and what impact do such 
differences have on competitive market conditions in the mobile telephone sector?  Are there other new 
wireless technologies that have improved wireless providers coverage, capacity and/or service offerings 
for mobile services?  What types of advanced technologies and services do licensees plan to deploy the 
Advanced Wireless Services (AWS) spectrum band and the 700 MHz Band, as well as the BRS/EBS 
Band?  In addition, to what extent have providers integrated their mobile telephone network technologies 
with high-speed wireless local area network technologies such as Wi-Fi, with the aim of offering seamless 
mobile voice or data services?  Finally, to what extent are providers using innovations in handset features 
and design as a way to compete?
D. Applications and Devices
The Bureau invites commenters to submit information and evidence documenting provider practices with 
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regard to applications and devices, especially with regard to recent developments indicating that providers 
are facing growing pressures to move to an open platform model.16 To what extent, and in what specific 
ways, do providers restrict the types of devices that can be attached to, or the types of applications that 
can be accessed on, their networks?  To what extent are providers differentiating themselves from their 
rivals with regard to applications and devices?  What changes in provider practices, if any, have occurred 
in this regard in the past year?  What impact have recent technological and market developments, such as 
the introduction of the Apple iPhone, had on carrier conduct in this area?
III. CONSUMER BEHAVIOR IN THE MOBILE TELECOMMUNICATIONS MARKET
A. Access to Information 
The Bureau seeks comment on the development of consumer information sources for the mobile 
telecommunications market.  Are there new avenues for consumers to gain information, such as retailers 
providing on-line and in-store comparisons of pricing plans, services, and handsets? 
B. Switching and Churn 
The Bureau asks 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 wireless industry?  How 
reliable are prior churn estimates?  Are there other sources of churn data available that should be included 
in the Thirteenth Report?  Further, the Bureau seeks sub-national or regional churn data, and churn data 
by demographic groups.  Have the previous reasons consumer churn, namely service cost and network 
quality, remained the same?  If not, what are the reasons for consumer churn?   Since the Twelfth Report, 
has there been a change in the churn rate?  If there has been a change, what is the magnitude of this 
change?  Has local number portability (LNP) affected wireless customer churn rates?  If so, has the 
effect been significant?  How has ongoing evolution in handset design and functionality affected 
consumer churn decisions?
IV. MOBILE TELECOMMUNICATIONS MARKET PERFORMANCE
The Bureau intends to analyze various metrics including pricing levels and trends, subscriber growth and 
penetration, Minutes of Use (MOUs), innovation and diffusion of services, and quality of service.  Are 
there any other metrics that would add to its analysis of the mobile telecommunications market?  Are 
these metrics available on a national or sub-national level?
A. Pricing Levels and Trends 
1. Pricing Trends
The Bureau seeks comment on the use of available pricing estimates as a tool in its analysis of the 
performance of the mobile telephone market, including to what extent any observed pricing changes are 
evidence of effective competition.  The Bureau seeks information on which providers offer nationwide 
pricing plans, particularly those that are not typically described as being nationwide operators, and request 
descriptions of the terms of such plans.  We ask for information and comment on voice and data services.  
Are there additional analyses that can be performed or conclusions that can be drawn from new or 
existing pricing data?  We also seek information on trends in handset prices.
2. Pricing Trends in Rural Areas
Are commenters aware of pricing studies that look at urban versus rural or other sub-national mobile 
  
16 See, e.g., 700 MHz Second Report & Order, [cite  generally and to open platform section] (adopting open 
platform requirement for C Block if reserve price is met at auction).
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telecommunications pricing?  Given the scarcity of studies that provide direct information on pricing, the 
Bureau is interested in finding alternative ways of determining whether pricing in rural areas conform to
national pricing plans.  Are there other ways of studying this issue?  Are there existing studies or data sets 
that would give us the ability to explore this issue?
3. Voice Revenue Per Minute
In the Twelfth Report, we used average revenue per minute (RPM) as a proxy for mobile pricing.  RPM 
is calculated by dividing a providers estimate of ARPU by its estimate of MOUs, yielding the RPM that 
the provider is receiving.  Until the last two years, revenues from wireless data services were a relatively 
insignificant portion of the average wireless subscribers bill.  However, in the last two years, data 
services have become an ever increasing portion of that bill.  Because the denominator in our RPM 
calculation measures usage based on the number of billable minutes of voice calls, rather than voice and 
data services combined, RPM is becoming an increasingly inaccurate measure of the pricing of mobile 
voice service.  In the Twelfth Report, we addressed this issue by including a revised version of RPM, 
Voice RPM, which excludes that portion of ARPU generated by data services.  We seek comment on 
the use of Voice RPM as a proxy for mobile pricing, and whether the methodology we used to develop it 
is appropriate.  Should we consider other proxies for mobile pricing, and if so, which ones?
B. Average Revenue per Unit (ARPU) 
Average monthly revenue per subscriber is another key metric presented in past CMRS Reports.  The 
Bureau seeks comment on the use of ARPU as a metric in its analysis of the mobile telecommunications 
industry.  Are additional ARPU data available that should be considered, in particular data depicting 
whether and how ARPU varies by region and/or demographic group?  The Bureau requests information 
on ARPU allocated to voice versus data and/or broadband services.  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 hypotheses.  
C. Quantity of Services Purchased 
1. Subscriber Growth 
Since the Seventh Report,17 the Commission has estimated the number of subscribers in the United States 
by using NRUF data.  NRUF data, however, do not include demographic information.  Therefore, the 
Bureau requests information on subscribers that would assist in a greater understanding of the mobile 
telecommunications inventory, such as penetration rates by age groups and/or household penetration 
rates.
The Bureau asks for comment on how to determine which geographic area or areas should be used to 
calculate mobile telecommunications subscribership and penetration rates.18 The Bureau requests 
comment on the appropriateness of using Economic Areas (EAs) for such calculations.  Given the 
  
17 Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and 
Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services,  Seventh Report, 17 FCC 
Rcd 12985 (2002) (Seventh Report).
18 The use of any particular geographic area to calculate mobile telecommunications 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 CMRS Reports.  
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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 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 Thirteenth Report?  Also, are there data on either a 
national or sub-national basis on the number of mobile telecommunications customers that use mobile 
data services?  
2. Minutes of Use 
The Bureau seeks comment on the use of MOUs as an indicator of the demand for mobile 
telecommunications services.  For purposes of the Thirteenth Report, the Bureau asks for comment on the 
sources of the MOU data presented in the Twelfth Report and requests additional MOU data.  In addition, 
should the Bureau perform other analyses or draw additional conclusions from new or existing data?  The 
Bureau requests data on MOUs on a sub-national basis and/or broken down by various demographic 
groups.
D. Quality of Service 
The Bureau seeks comment on the use of consumer surveys to measure service quality in the mobile 
telecommunications market.  Do commenters recommend any particular consumer surveys on service 
quality in the mobile telecommunications market, and why?  What factors do these recommended surveys 
take into account to evaluate customer satisfaction with service quality?  In particular, do the surveys 
focus primarily or exclusively on network performance and reliability (incidence of dropped calls, 
interference, and so forth), or do they 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 the recommended 
surveys use to select survey respondents, and do these methodologies result in any sample bias?  What 
types of consumer surveys should we consider in our analysis?
E. Applications and Devices
The Commission invites commenters to submit consumer surveys, or other types of evidence, about 
consumer preferences with regard to mobile applications and devices.  To what extent are consumers 
satisfied with the types of mobile devices and applications available to them?  What are the most 
important factors consumers take into account when choosing a handset?  The Commission also invites 
commenters to submit any U.S. or international studies or analyses measuring the benefits or harm to 
consumers as a result of provider practices with regard to mobile applications and devices.
V. WIRELESS  WIRELINE COMPETITION
A. Competition in Voice Services 
The Bureau asks for comment and sources of information on the extent to which mobile telephone service 
competes with wireline service. We ask for information about the number and demographics of 
households that have cut the cord and use wireless phones as their sole phone.  Has the introduction of 
intermodal LNP affected consumer behavior or had any impact on wireless-wireline competition?  Are 
there any other new developments in wireless-wireline competition that have occurred since the Twelfth 
Report?  What are the major reasons for these developments?  
B. Competition in Broadband Services 
Wireless technologies appear to play an increasingly significant role in the market for broadband services.  
In addition to the mobile broadband services discussed above, we note that wireless operators using 
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Broadband Radio Service/Educational Broadband Service (BRS/EBS) spectrum in the 2.5 GHz band 
currently offer, or have announced plans to offer, portable high-speed Internet access services using 
technologies such as WiMax.  We seek detailed information from operators on their current and planned 
deployment of WiMax and similar wireless broadband technologies in BRS/EBS spectrum, in other 
licensed spectrum bands, and in spectrum bands used by unlicensed devices.  To what extent do mobile 
and portable wireless broadband services complement broadband services offered over wireline 
technologies such as DSL, cable, or fiber to the home?  To what extent do they compete with these 
wireline technologies?  What effect will the 2006 AWS-1 Auction and the 2008 700 MHz Band Auction 
have on the provision of wireless broadband services and broadband competition?
VI. WIRELESS LOCAL AREA NETWORK TECHNOLOGIES
Wireless Local Area Network technologies can serve as both a competitor and a complement to the 
services offered by the CMRS industry.19 The most prevalent WLAN technology is equipment 
manufactured in accordance with the IEEE 802.11 family of standards, commonly known as Wi-Fi.20  
Wi-Fi networks often must rely on another type of broadband connection, such as wireline, cable, 
wireless, or broadband over power lines (BPL), for access to the Internet.21 Wi-Fi enables consumers to 
connect to the Internet at 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.22  
Some mobile telephone providers use Wi-Fi hot spots to supplement or complement their CMRS 
offerings provided through the licensed use of spectrum.23 We ask for information on which service 
providers use WLANs in these ways, and we seek a description of those service offerings.  We also 
request information about the pricing and usage of such plans.  In addition, we ask for information on the 
extent to which WLANs are being used for voice as well as data services, and on whether such voice 
services are being provided using Voice over Internet Protocols (VoIP) technology or other 
technologies.  Are there estimates on the amount of voice on WLANs, as compared with data traffic?  
What voice equipment and services are available for use over public hot spots?  To what extent are 
WLAN-based data and VoIP services considered to be complements to, or substitutes for, the data and 
voice services offered over CMRS networks?  
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 and reliability for free versus fee-based hot spots?  To what extent do hot spots 
compete with mobile broadband network data offerings, and to what extent do the differences between 
free and fee-based hot spots influence competition between Wi-Fi providers and CMRS providers?
  
19 Twelfth Report, FCC 08-28 at 110  252.
20 WLAN technologies operate on an unlicensed basis under Part 15 of the Commissions rules.  See 47 C.F.R. 15 
et seq.
21 Appropriate Regulatory Treatment for Broadband Access to the Internet Over Wireless Networks, WT Docket 
No. 07-53, Declaratory Ruling, 22 FCC Rcd 5901, 5907-8  15 (2007).
22 These hot spots usually function as an extension of another broadband Internet access network end point (e.g., 
wireline broadband Internet access or cable modem Internet access end point).
23 Several mobile telephone providers have entered the hot spot operations business through acquisition, 
partnerships, or independent deployment.  Twelfth Report, FCC 08-28 at 111  254.  See, e.g., T-Mobile, T-Mobile 
Hotspot U.S. Location Map, <https://selfcare.hotspot.t-mobile.com/locations/viewLocationMap.do> (last visited 
Feb. 6, 2008) (T-Mobile claims it has 8,800 hotspots where its customers can get connectivity). 
11
VII. OTHER INDICATORS AND TOPICS 
In addition to alternative sources of data and information to update indicators of competition used in the 
Twelfth Report and previous CMRS Reports, the Bureau invites commenters to recommend additional or 
alternative indicators of competition to enhance the analysis of competitive market conditions with 
respect to CMRS in the Thirteenth 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 market 
structure-provider conduct-consumer behavior-market performance framework.
Finally, the Bureau also invites commenters to propose additional topics of interest that are related to the 
assessment of the status of competition in the CMRS marketplace.   For example, have any noteworthy 
new trends or developments relevant to the assessment of competitive conditions in the mobile telephone 
sector emerged since the publication of the Twelfth Report?
VIII. PROCEDURAL MATTERS
Pursuant to sections 1.415 and 1.419 of the Commissions rules, 47 CFR  1.415, 1.419, interested 
parties may file comments on or before XX XX, 2008 and reply comments on or before XX XX, 2008.  
All filings should refer to WT Docket No. 07-71.  Comments may be filed using: (1) the Commissions 
Electronic Comment Filing System (ECFS), or (2) by filing paper copies. See Electronic Filing of 
Documents in Rulemaking Proceedings, 63 FR 24121 (1998).  
 Electronic Filers:  Comments may be filed electronically using the Internet by accessing the 
ECFS:   http://www.fcc.gov/cgb/ecfs/.  Filers should follow the instructions provided on the 
website for submitting comments.  If multiple dockets or rulemaking numbers appear in the 
caption of this proceeding, filers must transmit one electronic copy of the comments for each 
docket or rulemaking number referenced in the caption.  In completing the transmittal screen, 
filers should include their full name, Postal Service mailing address, and the applicable docket 
number.  Parties may also submit an electronic comment by Internet e-mail.  To get filing 
instructions for email comments, filers should send an e-mail to ecfs@fcc.gov, and should 
include the following words in the body of the message, get form <your e-mail address>.  A 
sample form and directions will be sent in response.
 Paper Filers:  Parties who choose to file by paper must file an original and four copies of each 
filing.  If more than one docket or rulemaking number appears in the caption of this proceeding, 
filers 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 Commissions 
Secretary, Office of the Secretary, Federal Communications Commission.
The Commissions contractor will receive hand-delivered or messenger-delivered paper 
filings for the Commissions Secretary at 236 Massachusetts Avenue, N.E., Suite 110, 
Washington, D.C. 20002.  The filing hours at this location are 8:00 a.m. to 7:00 p.m.  
All hand deliveries must be held together with rubber bands or fasteners.  Any 
envelopes must be disposed of before entering the building.
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.
12
U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be 
addressed to 445 12th Street, SW, Washington, D.C. 20554.
One copy of each pleading must be delivered electronically, by e-mail or facsimile, or if delivered as 
paper copy, by hand or messenger delivery, by commercial overnight courier, or by first-class or 
overnight U.S. Postal Service mail (according to the procedures set forth above for paper filings), to:  
(1) the Commission's duplicating contractor, Best Copy and Printing, Inc., at FCC@BCPIWEB.COM or 
(202) 488-5563 (facsimile); (2) Ben Freeman Spectrum and Competition Policy Division, Wireless 
Telecommunications Bureau, at ben.freeman@fcc.gov (202) 418-7447 (facsimile); (3) Heidi Kroll 
Spectrum and Competition Policy Division, Wireless Telecommunications Bureau, at 
heidi.kroll@fcc.gov, or (202) 418-7447 (facsimile).
Copies of the public notice and any subsequently-filed documents in this matter may be obtained from 
Best Copy and Printing, Inc. in person at 445 12th Street, S.W., Room CY-B402, Washington, D.C. 
20554, via telephone at (202) 488-5300, via facsimile at (202) 488-5563, or via e-mail at 
FCC@BCPIWEB.COM.  The public notice and any associated documents are also available for public 
inspection and copying during normal reference room hours at the following Commission office:  FCC 
Reference Information Center, 445 12th Street, S.W., Room CY-A257, Washington, D.C. 20554.  The 
public notice is also available electronically through the Commissions ECFS, which may be accessed on 
the Commissions Internet website at http://www.fcc.gov.  Alternate formats of this public notice 
(computer diskette, large print, audio recording, and Braille) are available to persons with disabilities by 
contacting Brian Millin at (202) 418-7426 (voice), (202) 418-7365 (TTY), or by sending an e-mail to 
access@fcc.gov.
For further information, contact Ben Freeman, Spectrum & Competition Policy Division, Wireless 
Telecommunications Bureau, (202) 418-0628, or Heidi Kroll, Spectrum & Competition Policy Division, 
Wireless Telecommunications Bureau, (202) 418-1310.