Re: WT Docket Nos. 06-150, 06-169 and 96-86; PS Docket No. 06-229 (Press Release)

The Honorable Kevin J. Martin, Chairman
The Honorable Michael J. Copps
The Honorable Jonathan S. Adelstein
The Honorable Deborah Taylor Tate
The Honorable Robert M. McDowell
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554

Re: WT Docket Nos. 06-150, 06-169 and 96-86; PS Docket No. 06-229

Dear Mr. Chairman and Commissioners:

We have learned through recent media accounts that the Commission’s
proposed service rules seek to impose an “open access” requirement on 22 MHz of
the Upper 700 MHz band spectrum. On behalf of the approximately 139 undersigned
small and regional operators and organizations, we write to urge you to reject an
“open access” mandate in this spectrum. The FCC should refrain from imposing
novel and untested open access conditions, which favor a single entity, on the 700
MHz spectrum critically needed by small and regional carriers to increase coverage
and services.

The proposed open access mandate in the 700 MHz band would significantly
hinder small carrier participation in the 700 MHz auction and in many cases foreclose their ability to deploy this spectrum in small and rural markets. The open access and public safety requirements on the licenses in the Upper 700 MHz band will force large carriers, deterred by open access requirements, to pursue licenses in the Lower 700 MHz band. As a result, both large and small carriers will be bidding on the same 24 MHz of spectrum in the lower 700 MHz band. This is particularly troubling because the spectrum in the Lower 700 MHz band uses smaller license areas intended to benefit small and regional carriers. Although many smaller licenses may initially cost more, large carriers will likely choose to bid on the many smaller licenses rather than accept larger, encumbered licenses. The end result would be fewer small and regional license winners in the 700 MHz auction.

Ultimately, we believe that the undersigned small carriers and the millions of
consumers we serve will be the net losers from an open access requirement in the
Upper 700 MHz band. The proposed open access requirements trade the benefits of
rural deployment by small and regional licensees, and their proven track record of
providing service to their customers, for – at best – speculative gains of an open
access network.

In sum, we fear that encumbering the Upper 700 MHz licenses with onerous
conditions will result in small and regional carriers having little chance of securing licenses to deliver innovative 700 MHz wireless services to their subscribers.

Pursuant to Section 1.1206 of the Commission’s Rules, this letter is being
electronically filed with your office. If you have any questions concerning this
submission, please contact the undersigned.

Sincerely,

Companies and Corporate Headquarters:

Alaska Communications Systems, Inc. - Anchorage, AK
Blooston Rural Carriers
-All West Communications, Inc. - Kamas, UT
-BEK Communications Cooperative - Steele, ND
-Big Bend Telephone Company - Alpine, TX
-Cannon Valley Communications, Inc. - Bricelyn, MT
-CC Communications - Fallon, NV
-Chibardun Telephone Cooperative, Inc. - Dallas, WI
-Clear Lake Independent Telephone Company Clear - Lake, IA
-Command Connect, LLC - Sulphur, LA
-Communications 1 Network - Kanawha, IA
-Eastern Colorado Wireless, LLC - Wiggins, CO
-FMTC Wireless, Inc. - Nora Springs, IA
-Hancock Rural Telephone Corp. d/b/a Hancock Telecom - Maxwell, IN
-Harrisonville Telephone Company - Waterloo, IA
-Haviland Telephone Company, Inc. - Haviland, IN
-Heart of Iowa Communications - Union, IA
-Interstate Telecommunications Cooperative - Clear Lake, SD
-Kennebec Telephone Company, Inc. - Kennebec, SD
-Ligtel Communications, Inc. - Ligonier, IN
-Manti Telephone Company - Manti, UT
-Mid-Rivers Telephone Cooperative, Inc. - Glendive, MT
-Midstate Communications, Inc. - Kimball, SD
-Nucla-Naturita Telephone Company - Nucla, CO
-Ponderosa Telephone Company - O’Neals, CA
-Red River Rural Telephone Association, Inc. - Abercrombie, ND
-Santel Communications Cooperative - Woonsocket, SD
-Smithville Telephone Company - Ellettsville, IN
-South Slope Cooperative Communications Co. - North Liberty, IA
-Venture Communications Cooperative - Highmore, SD
-Webster Calhoun Cooperative Telephone Association - Gowrie, IA
-Yadkin Valley Telephone Membership Corp. - Yadkinville, NC
Cincinnati Bell Wireless - Cincinnati, OH
CTIA – The Wireless Association - Washington, DC
East Kentucky Network, LLC d/b/a Appalachian Wireless - Prestonburg, KY
General Communication, Inc. - Anchorage, AK
Mohave Wireless - Kingman, AZ
NTELOS, Inc. - Waynesboro, VA
Rural Cellular Association, on behalf of its approximately 100
small and regional wireless carrier members, available at
http://americanroamer.com/rca/rca_members.html
U.S. Cellular Corporation - Chicago, IL
Westlink Communications, Inc. - Ulysses, KS