DISSENTING STATEMENT OF 
COMMISSIONER MICHAEL J. COPPS
Re:  AT&T Mobility II LLC and Aloha Spectrum Holdings Company LLC Seek FCC Consent 
for Assignment of Licenses and Authorizations
 Today’s decision authorizes the transfer of licenses for 12 MHz of extremely valuable 
spectrum in the 700 MHz band, covering 196 million Americans, to the nation’s largest wireless 
carrier. It affects 72 of the top 100 markets in the United States—and every single one of the top 
10 markets. By any measure, it represents an important development in the wireless 
marketplace—a marketplace that has seen round after round of consolidation in recent years.
 Most unfortunately, today’s order contains only an extremely abbreviated analysis of the 
competitive effects of this change in ownership. Instead, we have a rush to judgment that seems 
hard to square with the FCC’s statutory duty to promote competition in the wireless marketplace 
and diverse ownership of spectrum licenses. 
 To begin with, the Order applies the Commission’s faulty new 95 MHz spectrum screen—
a figure that (as I argued in greater detail in my dissent to another spectrum acquisition this fall) is 
based on sloppy math and inaccurate assumptions. And even though today’s Order concedes that 
this transaction will cause the applicant to exceed the far-too-generous 95 MHz figure in 11 
different locations across the country, it requires no divestiture or remedy of any sort to temper 
the effects of this acquisition on wireless competition. Our license transfer orders also 
traditionally analyze the public interest benefits of a transaction—but not this one, which is 
largely silent on the issue.
 Because today’s hasty decision seems destined to reduce competition and diversity in the 
wireless marketplace, and because I see little demonstration of countervailing benefits and 
precious little serious analysis of any sort, I must respectfully dissent.