Support Increased Competition in Wireless Telecommunications

We, the undersigned citizens, strongly advocate that the Federal Government continue to promote competition among providers and choice for consumers in the wireless telecommunications industry, particularly by enabling the increased use of free (unlicensed) radio spectrum.

Clearly, consumers today are relying more and more on mobile voice and data services in their lives. This has caused an increased strain on the nation’s cellular networks, and a strong push to free up more radio spectrum to meet the rising demand. However, there is a real concern that merely freeing up new spectrum will not encourage competition in the cellular industry, nor lead to savings for consumers. In fact, the annual Wireless Competition Report that the FCC recently released showed a trend toward less competition in the industry, with concentration of the mobile industry increasing by 32% from 2003 to 2009.

The FCC, as well as the Departments of Justice and Commerce, have publicly recognized the need for approaches that encourage competition – and free spectrum solutions such as white spaces and unlicensed airwaves are receiving increasing interest. Among the recommendations included in the FCC’s National Broadband Plan that was unveiled earlier this year were the following:

- Recommendation 5.11: The FCC, within the next 10 years, should free up a new, contiguous nationwide band for unlicensed use. “The innovations spurred by unlicensed device usage have occurred because of benefits associated with such usage, including low barriers to entry and faster time to market, that have reduced costs of entry, spurred innovation and enabled very efficient spectrum usage.”

- Recommendation 5.13: The FCC should spur further development and deployment of opportunistic uses across more radio spectrum. “Public comment has suggested that "opportunistic" or "cognitive" technologies can significantly increase the efficiency of spectrum utilization by enabling radios to access and share available spectrum dynamically. The FCC should take actions to accelerate the development of opportunistic use technologies and expand access to additional spectrum.”

We propose that these recommendations be fully implemented, and that:
· The FCC should build on the success of WiFi, Bluetooth and other successful wireless technologies and make more unlicensed spectrum available. This will enable the spread of new technology innovations and provide a much needed resource for low-cost, high bandwidth wireless communications.
· The FCC and NTIA (National Telecommunications and Information Administration) should make underutilized commercial and government spectrum available either on an unlicensed or opportunistic use basis (i.e. via cognitive radio and spectrum sharing techniques.) This will help ensure that these valuable frequencies are put to use and not warehoused or shelved.

The reward for doing so will be to foster competition in the industry by opening the door to new market entrants, new products and services, new options for citizens in underserved areas and lower costs to all consumers for wireless services.

We urge your swift and immediate action.