STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
RE: Applications of AT&T Inc. and Dobson Communications Corporation For Consent to 
Transfer Control of Licenses and Authorizations, File Nos. 0003092368, et al., WT 
Docket No. 07-153, Memorandum Opinion and Order, FCC 07-196
I am pleased to support approval of this transaction given the numerous public interest 
and consumer benefits, especially for rural and suburban Alaskan consumers.  The merger will 
provide Dobson’s customers with access to the full range of services available on AT&T’s 
national GSM-EDGE network and will allow Dobson’s customers to make and receive voice 
calls in more than 190 countries, and access data services in 120 countries, through AT&T’s 
roaming partners.  As discussed below, however, I question the necessity of introducing a new 
economic analytical framework as part of this Order.  
In today’s order, the Commission adds 700 MHz band spectrum to its market screen for 
spectrum suitable for provision of mobile telephony services.  While it is certainly important that 
we update our analytical tools from time to time, this action is decidedly premature and 
introduces an unnecessary level of complexity into the Commission’s market analyses. I also 
wonder how the new framework will affect participation in the forthcoming auction of 700 MHz 
spectrum.
The Order concludes that 700 MHz band spectrum “not only is technically capable of 
supporting mobile services, but also is in many respects ideally suited for the provision of these 
services.” This may be true; however, at this preliminary stage, we have little, if any, idea how 
auction winners will elect to use this spectrum. Nor should we -- the Part 27 licensing rules 
expressly welcome flexible uses within this band.  And, at least one current operator is deploying 
mobile broadcast services. The Order also concludes that 700 MHz band spectrum “is available 
on a nationwide basis.”  Actually, Congress has determined that the spectrum will not be fully 
available until February 17, 2009, which is over one year away.  
The fact is that the capabilities of the 700 MHz band spectrum are irrelevant until the 
band is licensed, cleared of incumbent users, built out, and used to provide services to America’s 
consumers.  Moreover, I wonder whether the distinctions for the purposes of this market screen 
between the cellular, PCS, SMR, 700 MHz, AWS-1 and BRS spectrum bands are still necessary 
or appropriate.  Perhaps our overdue 12th Annual Wireless Competition Report will more 
thoroughly analyze this issue.     
Once again, the Commission raises more questions than it answers, and appears to bind 
future Commission action, and dictate or bind government policy.  I am concerned that we are 
regulating unnecessarily without thinking through possible unintended consequences.  This is 
especially unfortunate given the critical need for market certainty as we approach the 700 MHz 
auction.