*Pages 1--1 from  Microsoft Word - 50358.doc*
 STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 
 Re:  Applications  of  Western  Wireless  Corporation  and  ALLTEL  Corporation  For  Consent  to  Transfer  of  Control  of  Licenses  and  Authorizations;  WT  Docket  No.  05-  50 
 Western  Wireless  and  ALLTEL  have  demonstrated  a  sincere  commitment  to  providing  the  latest  wireless  technologies  and  services  to  traditionally  underserved  customers,  particularly  those  in  rural 
 America.  Coming  from  South  Dakota,  I  am  well  aware  of  the  challenges  associated  with  providing  mobile  wireless  services  in  the  Great  Plains  and  other  less  populated  areas  of  the  country.  I  fully  approve 
 this  merger  because  I  believe  it  will  allow  ALLTEL  to  be  a  stronger,  more  vibrant  carrier  capable  of  providing  more  comprehensive  and  advanced  mobile  wireless  services  to  its  customers,  no  matter  where 
 they  live. 
 Of  course,  a  merger  like  this  requires  a  thorough  public  interest  review  to  ensure  that  we  do  not  inadvertently  disadvantage  the  very  communities  we  are  trying  to  protect.  An  unchecked  merger  could 
 harm  the  competitive  environment  in  some  communities  in  ways  that  the  market  is  unlikely  to  overcome.  I  applaud  the  Commission  staff  for  conducting  a  thorough  analysis  of  the  markets  potentially  affected  by 
 the  merger,  and  I  fully  support  our  decision  to  require  divestiture  in  the  markets  identified  in  our  Memorandum  Opinion  and  Order. 


 I  do  have  one  area  of  concern  that  is  associated  more  with  the  overall  trend  of  consolidation  in  the  mobile  wireless  industry  rather  than  the  specific  merger  before  us.  During  the  past  year,  we  have 
 regularly  heard  from  smaller  mobile  wireless  companies  that  are  concerned  about  their  ability  to  negotiate  automatic  roaming  contracts  with  the  larger  regional  and  nationwide  carriers.  These  concerns  also  came 
 up  both  in  the  record  of  this  merger  as  well  as  in  the  Cingular-  AT&  T  Wireless  acquisition  completed  last  year. 


 I  think  the  time  is  right  for  the  Commission  to  accumulate  a  full  record  on  the  roaming  issue  to  determine  what,  if  any,  action  may  be  needed.  So,  I  am  very  pleased  that  the  Chairman  has  agreed  to 
 initiate  shortly  a  proceeding  that  will  explore  the  issue  of  roaming  and  the  effects  of  consolidation  on  the  ability  of  smaller  carriers  to  negotiate  access  to  larger  networks.  This  is  a  positive  development,  and  I  am 
 pleased  that  we  can  begin  a  formal  review  of  this  matter  in  the  very  near  term. 
 Finally,  there  has  been  some  good  discussion  during  the  last  few  days  of  our  deliberation  regarding  the  merger  and  its  possible  impact  on  ALLTEL’s  compliance  with  the  upcoming  E911  handset 
 penetration  deadline.  I  appreciate  the  efforts  of  Commissioner  Copps  in  raising  this  important  issue.  As  the  mobile  wireless  industry  is  well  aware,  the  entire  Commission  takes  E911  compliance  very  seriously 
 particularly  given  the  increasingly  important  role  of  E911  in  our  nation’s  homeland  security  efforts. 
 While  I  am  troubled  by  ALLTEL’s  apparent  difficulty  in  reaching  the  95%  penetration  level  by  December  31,  2005,  I  acknowledge  the  recent  commitment  to  timely  address  these  challenges  and  to 
 ensure  that  the  merged  company  remains  on  a  “path  to  full  compliance.”  Also,  the  record  contains  a  number  of  support  letters  on  ALLTEL’s  behalf  from  public  safety  and  governmental  organizations 
 including  filings  from  officials  leading  the  state  government  wireless  E911  deployment  efforts  in  North  Carolina,  South  Carolina,  and  Virginia.  Ultimately,  I  believe  that  issues  regarding  ALLTEL’s  handset 
 compliance  problem  can  be  addressed  through  our  existing  rules  and  regulations,  an  area  in  which  we  have  not  hesitated  to  take  specific  enforcement  action  when  appropriate  during  the  past  several  years. 
1