Federal Communications Commission FCC 11-103
STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
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 Mobile 
Wireless, including Commercial Mobile Services, WT Docket No. 10-133.
 I am pleased that this year’s mobile competition report builds on the leaps and bounds of 
progress over previous reports that began with last year’s Fourteenth Report. This year’s report 
again recognizes the on-the-ground reality that mobile is about much more than voice. The 
analysis of voice, data and text services provides Congress with an updated picture of the state of 
competition in commercial mobile service markets. The report brings further improvements, 
showing us, for example, how the number of competitors in an area varies by consumer income.
Although we deliver the product to Congress, we would be remiss if we at the Commission did 
not use this report to consider the effects of our policy decisions on the mobile market.  
But we should not allow this progress to stop us from continuing to improve the report 
going forward.  I note, for example, that we continue to rely on third parties to furnish us most of 
the data on pricing and investment. I would prefer to have the Commission gather and verify this 
data ourselves. Good regulatory decisions depend on good data. Similarly, while I am pleased to 
see that mobile service covers vast swaths of our land, the report’s coverage maps and network 
performance data are based on what carriers advertise and how each carrier defines coverage.
The report acknowledges that this likely overstates actual coverage, and we have asked about 
actual performance for data services in our Form 477 notice. With the technology increasingly 
available to validate coverage and performance claims, shouldn’t we, the expert agency, be 
moving toward a model of what consumers are actually experiencing?
Finally, I cannot ignore some of the darkening clouds over the state 
of mobile competition. The headline for this Report will be that the FCC neither finds nor does 
not find effective competition. Dig deeper and, sure enough, we find ongoing trends of industry 
consolidation. The well-accepted metric for market concentration, the Herfindahl-Hirschman 
Index, remains above the threshold for a “highly concentrated” market. It also appears that 
consumers are no longer enjoying falling prices, according to the CPI for cellular services. We 
know there is a looming spectrum crunch and a growing need for backhaul. There is no doubt 
that the mobile market is an American success story, and there are many ways to measure 
industry health. But it would be foolish and decidedly not in the public interest to ignore the facts 
this Report reveals. If we want Americans to continue to enjoy innovation, affordability and 
improved mobile coverage, we must heed these facts and continue to examine areas where the 
Commission can act to encourage mobile competition. 
Thank you to the Chairman and the Wireless Telecommunications Bureau for bringing us this 
data-rich, well presented report.