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 STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 December  11,  2002 
 RE:  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. 
 The  CMRS  Competition  Report  serves  as  the  factual  foundation  of  many  Commission  decisions.  It  is  therefore  extremely  important  that  Commission  staff  have 
 the  best  possible  data  available  to  them  when  composing  this  Report.  I  have  noted  in  the  past  that  our  Report  and  our  decisions  would  greatly  benefit  from  better  data. 


 For  example,  I  have  been  particularly  worried  that  past  Reports  have  defined  an  entire  county  as  being  served  by  a  carrier  if  any  part  of  the  county  is  served.  This  means 
 we  have  counted  an  entire  county  as  served  even  though  only  a  highway  that  runs  through  it  is  actually  served.  We  also  have  found  competition  in  a  county  even  where 
 two  apparent  competitors  do  not  venture  into  each  other’s  territory  to  actually  compete.  This  situation  occurs  because  Commission  staff  do  not  have  access  to  more  granular  data. 
 This  NOI  asks  the  questions  needed  to  solve  this  problem  and  I  urge  carriers  to  help  us  produce  more  granular,  aggregated,  non-  company-  specific  data  on  this  point  by 
 submitting  coverage  information  and  seeking  confidential  treatment. 
 In  addition,  better  understanding  the  state  of  competition  and  deployment  in  rural  America  must  be  a  top  priority  of  the  next  CMRS  Competition  Report.  This  NOI 
 dedicates  an  entire  section  to  rural  issues.  Combined  with  what  we  learn  from  the  Rural  Spectrum  NOI  that  we  also  are  issuing  today,  we  have  the  potential  to  be  in  a  better 
 position  to  analyze  rural  service  soon.  Again,  the  submission  of  detailed  comments  from  a  wide  range  of  sources  will  be  the  key  to  success  here. 


 I  am  also  hopeful  that  this  NOI  will  also  help  us  better  understand  if  and  how  churn,  service  quality,  pricing,  innovation,  and  ARPU  relate  to  our  analysis  of 
 competitive  market  conditions.  Making  conclusions  about  increasing  or  decreasing  competition  from  evidence  about  these  and  other  metrics  is  tricky  business.  The  NOI 
 seeks  input  on  how  we  should  make  these  conclusions. 
 To  conclude,  I  want  to  thank  the  staff  for  going  through  this  extra  step  in  the  Competition  Report  process.  I  know  that  you  work  hard  on  this  Report  already  and  I 
 believe  that  you  produce  admirable  results.  I  hope  that  these  NOIs  will  begin  to  give  you  the  data  you  need  each  year  to  further  advance  this  critical  resource. 
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