comments of sprint nextel corporationbefore the federal communications commission washington, d.c....

Before theFEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of

The State of Mobile Wireless Competition

))))

WT Docket No. 10-133

COMMENTS OF SPRINT NEXTEL CORPORATION

Charles W. McKeeVice President, Government AffairsFederal and State RegulatorySprint Nextel Corporation900 Seventh Street N.W.Washington, D.C. 20001703-433-3786

Scott R. FreiermuthCounsel, Government AffairsFederal RegulatOlYSprint Nextel Corporation6450 Sprint ParkwayOverland Park, KS 6625 I913-315-8521

July 30, 2010

Table of ContentsSummary of Comments.............................................. 11

1. Imp0I1ant Trends and Developments in the Wireless Space During 2009and 2010 . 1

A. The Launch of 4G Mobile Broadband Service Has Been the MostSignificant Recent Development in the Wireless Ecosystem 1

B. Sprint Has Been an Industry Leader in Environmentally Responsible(or "Green") Initiatives.................................................................. 5

C. Sprint Has Recently Introduced a Wide Variety of Different Plansfor Consumers Not Interested in Contract Plans.............................. 10

D. Sprint Has Developed a New Service Plan Designed Specifically to HelpThose Americans Most Negatively Impacted by the Recession 13

E. Wireless Providers Have Made Impressive Gains in Providing ConsumersWith a Positive Customer Experience, as Recent Surveys Confirm......... ... ... 14

11. The Retail Mobile Wireless Market Is Effectively Competitive........................ 21

A. There Exists Today Effective Competition in the Retail Market for MobileWireless Services.......................................... 21

B. High Penetration Rates Should Ensure That the Retail Market for MobileWireless Services Will Remain Effectively Competitive in the Near Term...... 26

111. The Commission Must Address Promptly the Critical Inputs That AT&T andVerizon Control Over the Mobile Wireless Ecosystem...... 28

A. The Commission Should Promptly Resolve Its Long-Standing SpecialAccess Backhaul Investigation...... 29

B. The Availability of Data Roaming at Reasonable Rates and Terms Isa Critical Input to the Provision of Mobile Broadband Service......... 30

C. The Harmful Impact of Today's Antiquated and Discriminatory IntercarrierCompensation Regime on the Wireless Ecosystem.................................... 32

IV. The Commission Should Assure the Availability of Additional Spectrumfor Competitive Mobile Broadband Services... 34

V. Conclusion...................................................................................... 36

Summary of Comments

Sprint addresses three general subjects in response to the Commission's request for input and data on mobile wireless competition.

A. Important Developments in the Wireless Space During 2009 and 20 IO. Sprint addresses five developments in these comments:

1. The launch of this nation's first 4G mobile broadband network. Sprintdescribes this network, including the introduction last month of the nation's first 4G smartphone. Sprint submits that 4G networks will notonly enrich the Internet experience of mobile broadband users, but alsoprovide more effective competition to fixed broadband service providers.

2. A review of Sprint's environmentally responsible (or "green") initiatives. Sprint briefly describes some of the steps it has taken in the past18 months, including the introduction of three eco-friendly phones andnumerous "green" accessories, and the success it has achieved with itsdcvice recycling programs. Since 2001, Sprint's take back programshave diverted more than 20 million phones from landfills for reuse andrecycling.

3. In response to the FCC's ongoing examination of service plans withterm contracts and early termination fees ("ETFs"), Sprint describes itsset of six different plans that it offers to consumers who do not want tosign a term service contract that includes an ETF.

4. Sprint describes its new Lifeline service that it developed specificallyfor those Americans most negatively impacted by the recession.

5. Sprint finally discusses the impressive gains that the wireless industryhas made in providing consumers with a positive customer experience.Sprint also summarizes the numerous steps it takes to ensure that consumers select the right plan and device, that they truly understand theplan and phone they choose, and that they remain satisfied and mayfreely modify plans as circumstances change.

B. The Retail Mobile Wireless Market Is Effectively Competitive. Among otherthings, Sprint notes that the wireless Consumer Price Index ("CPI") continued to fall duringthe first half of this year. And Sprint compares several of its plans with those available toconsumers in the United Kingdom ("U.K."), which demonstrates that American consumersreceive a better value than their counterparts in the U.K. Sprint observes the Ofcom, the U.K.regulator, has determined that its mobile wireless market is effectively competitive.

Sprint further documents the high-level of penetration that exists in the wireless space.Because the wireless market is effectively saturated, the only way a provider can increase itscustomer base is by (l) retaining as many of its current customers as possible, and then (2)attracting current customers away from its competitors by convincing them they would receive lower prices and/or better value by switching providers. In this environment, competition in the retail market is likely to continue to be strong in the near term to the benefit of con-

- 11 -

sumers. Maintenance of this competition, however, depends upon carrier access to the criticalinputs for their service.

C. Critical Inputs to the Provision of Mobile Wireless Services. The FCC should becommended for examining for the first time in its recent 14th annual competition repoli, thecritical inputs carriers need to provide their services. Sprint discusses four such inputs in thissection:

I. The need for the FCC to promptly resolve its long standing specialaccess backhaul investigation;

2. The critical role of data roaming to the provision of mobile broadbandservices;

3. The harmful impact oftoday's antiquated and discriminatory intercarrier compensation regime on the wireless ecosystem; and

4. The importance of additional spectrum for competitive mobile broadband services.

- 111 -

Before theFEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of

The State of Mobile Wireless Competition

))))

WT Docket No. 10-133

COMMENTS OF SPRINT NEXTEL CORPORATION

Sprint Nextel Corporation ("Sprint") submits these comments in response to the

Commission's request for "input and data on mobile wireless competition" as part of its prep-

aration of its Fifteenth Annual Report on the State of Mobile Wireless Competition. I

I. IMPORTANT TRENDS AND DEVELOPMENTS IN THE WIRELESS SPACEDURING 2009 AND 2010

The Commission seeks comment on "any trends or developments that have occurred

during 2009 or 2010," the period that will be covered in the next wireless competition report?

Sprint below discusses the trends and developments it believes are the most significant over

the past 18 months.

A. THE LAUNCH OF 4G MOBILE BROADBAND SERVICE HAS BEEN THE MOSTSIGNIFICANT RECENT DEVELOPMENT IN THE WIRELESS ECOSYSTEM

Mobile broadband service, until recently, was available only via third-generation

("30") technologies. As discussed below, mobile broadband services using fourth-generation

(40") technologies have now become available to an increasing number of American con-

sumers and businesses. Sprint submits this development will revolutionize the broadband

See Public Notice, Wireless Telecommunications Bureau Seeks Comment on the State ofMobile Wireless Competition, WT Docket No.1 0-133 (June 30, 20 IO)("Public Notice").

See Public Notice at 2.

Sprint Nextel CommentsMobile Wireless Competition, WT Docket No. 10-133

July 30, 2010Page 2

3

"

market as 4G networks support faster speeds and provide users with an all-Internet Protocol

("IP") connection. 4G networks will not only enrich the Internet experience of mobile broad-

band users, but also provide more effective competition to fixed broadband service providers.

Sprint became the first national carrier to introduce 4G mobile broadband service with

its launch in September 2008 of a mobile WiMAX network in Baltimore.3 Two months later,

in November 2008, following Commission approval,4 Sprint and the "old" Clearwire merged

their WiMAX spectrum and other WiMAX assets into "new" Clearwire (hereafter, "Clear-

wire"), with Sprint contributing $3.3 billion of net assets to the venture. 5 Google, Intel, Com-

cast, Time Warner Cable, and Bright House Networks contributed $3.2 billion in Clearwire,

and became important investors in the new company6

The new Clearwire launched its first mobile WiMAX market in January 2009 (in Port-

land).? This network uses open industry standards (specifically, IEEE 802.l6e), which enable

See Sprint News Release, XOHM WiMAX Broadband Service Debuts in Baltimore, New 4GWireless Era Dawns (Sept. 29, 2008). This news release, as other Sprint news releases referenced inthese comments, are available at: hUp;/b1e\\isreIeases,sprintcom/t>I1oenI".zJHmL7c=l2ZI49.!kp=Iroj,ne\\iLne\\isl:QoIJl.!kllyo",Q·

It appears that DigitaIBridge Communications was the first company to introduce a mobileWiMAX service, launching its 4G service in Jackson Hole, Wyoming - three months before Sprintlaunched service in Baltimore. See DigitaIBridge News Release, DigitalBridge Communications Deploys the first Mobile WiMAX Network, BridgeMAXX Mobile Services 1~ Now Commercially Availablein Jackson, Wyoming (June 30, 2008), available athttp://\\i\\i\\i ..cli.gitalbrigge.e.omm.tln.i.e.alions,colll/PortalsIQIAbo\lt''.lo20l)[3<::!l)!3Cjacksoll''.1020Networl<.Q63QQ8pgf.

See Sprint/Clearwire WiMAX Merger Order, 23 FCC Rcd 17570 (Nov. 7, 2008).

See Sprint 2008 SEC Form 10-K, at 3 (Feb. 27, 2009).

See Clearwire News Release, Clearwire Completes Transaction With Sprint Nextel and $3.2Billion Investment to Launch 4G Mobile Internet Company (Dec. I, 2008), available athup//iD Veslors.clear\\iire .C()lll/phoen i".zlJtmI,?c=I 987228<p=i ro I.,11e\\isArticl.e.8<ID~.123 IQ158<highlight=.

See Clealwire News Release, Clearwire Introduces Clear 4G Mobile Internet Service to Portland (Jan. 6, 2009), available at http://nc\\isroom.clcarwirc.com/phocnix.zhtmJ?c-2I 4419&p=irol·ncwsArticlc&ID·1240894&highlight=.


July 30, 2010Page 3

any manufacturer to design devices to work on the 40 network. Clearwire provides its own

set of services under the CLEAR™ brand,8 and it has executed mobile virtual network opera-

tor ("MYNO") agreements with Sprint and some of its other investors so they can resell Wi-

MAX services under their own brands.9 Likewise, Sprint has executed MYNO agreements

with Clearwire and other Clearwire investors so they can access and resell Sprint's nationwide

30 services. 10

At the end of2009, Clearwire's mobile WiMAX network was operational in 27 mar-

kets covering 34.5 million people. I I Clearwire's most recent information shows that its Wi-

MAX network serves 44 markets covering approximately 51 million people. 12 And Clear-

wire expects to reach approximately 120 million people by the end of 2010 with the launch of

many new markets including cities such as New York, Los Angeles, the San Francisco Bay

Area, Boston, Denver, Minneapolis, Miami, Cincinnati, Cleveland and Pittsburgh. 13

In addition to the impressive and ongoing WiMAX network build-out, it is impoltant

to note that the 40 network is creating its own competition as several companies will be sell-

ing/reselling 40 mobile services under their respective brands and in the same markets.

Clearwire is, of course, selling its own CLEAR line of home, mobile and voice products.

Sprint is selling 40 services through a variety of devices including hotspots, modems and

8

9

See generally b\1P:!!WWW&le~r,eQ1]1/.

See Clearwire 2009 Form IO-K at 119.

See CleaIwire 2009 SEC Form 10-K, at 2 (Feb. 24, 2010).

10 See Sprint 2009 Form 10-K at F-17. In fact, Comcast recently launched for its customers a3G-only service. See Comcast News Release, Comeast Expands National Rollout ofHigh-Speed 2goby Adding 3G-only Wireless Data Service (May 5, 2010), available atbttp://www.col11cast.CQI11/AbQut/PressRelease/pressRcleasel)et~il.~sb)(?P1<.II)-989.

"12

13

See http://investors.clearwire.com/phoenix.zhtmJ?c~2J44J9&p=irol-corpoverview

Iel


July 30, 2010Page 4

14

17

handsets (discussed below). In addition, about one year ago, Comcast began reselling Clear-

wire's 40 services in selected markets under the High-Speed 2go™ brand. 14 And, Time

Warner Cable - under a similar resale agreement - sells 40 service branded Road Runner

Mobile™.15

Initially, the only devices available for use with this 40 network were 40 modems and

data cards attached to computers. In December 2008, Sprint introduced the nation's first dual-

mode (30/40) modem so 40 customers could access its nationwide 30 network when travel-

ing outside the 40 coverage area - and further, so its 30 customers could take advantage of

the 40 network when traveling within 40 coverage areas. 16 In August 2009, Sprint intro-

duced the nation's first Wi-Fi router so consumers could connect any Wi-Fi device (e.g., MP3

and game players) to either the 30 or 40 networks. I? In January 2010, Sprint introduced the

nation's first 30/40 mobile hotspot that allows up to five Wi-Fi enabled devices to connect to

these networks. 18

The 40 marketplace changed dramatically on June 4, 2010, when Sprint introduced

the HTC EVO™ 40. 19 This Android-based phone provides numerous capabilities, including

See !1ttp://wW\V,COmcastcom/big!1speecJ2go!; see also Comcast News Release, Comcast Begins National Rollout ofHigh-Speed Wireless Data Service; Portland First to Launch Comcast HighSpeed 2go with Atlanta, Chicago, Philadelphia and More Launching Before Year-End 2009 (June 29,2009), available at bttp:l!vvww,comcas!.com/A!:>oJlt/I'I,:essRel"jlselpressRelease[)etaiI,as!1».?PRIP=8ll.Z.

15 See http://w\vw,timewarncrcab Ie&ol11/KansasC:ity/a!:>()llt/jnthencws.d,ctaiI S,ash».?PRILl=2948&MarketlD=22

16 See Sprint News Release, Sprint Extend,' 4G Leadership with Nation '05 First 3G/4G Dual-Mode Mobile Broadband Service (Dec. 17,2008).

See Sprint News Release, Sprint Add,' 4G Mobile Broadband Router Portfolio as It Preparesto Launch 4G in More Markets (Aug. 5, 2009).

18 See Sprint News Release, Overdrive 3G/4G Mobile Hotspot by Sierra Wireless Can BringSprint's 4G Speeds to More Than 400 Million Wi-Fi Enabled Devices (Jan. 10, 20 I0).

19 See Sprint News Release, The Wait Is Over - America's First 3G/4G Phone, ETC EVO 4G,Available Nationwide Toda", Exclusively ji'om Sprint (J une 4, 20 I0).


July 30, 2010Page 5

a 4.3-inch display, dual cameras, a video chat capability, an HOMI connector port so the

phone can be connected to a big-screen TV, and a built-in hotspot functionality allowing up to

eight Wi-Fi enabled devices to share the 3G/4G experience.2o This phone sells for $199.99

with a two-year service contract and after a $100 mail-in rebate (taxes excluded).21 The EVO

4G has already received numerous awards, including CNET, Laptop Magazine and eWeek

awards for Best of Show when it was announced at CTIA this spring. And, Sprint will soon

launch the Samsung Epic - which will be the first 4G handset with a slide-out keyboard.

B. SPRINT HAS BEEN AN INDUSTRY LEADER IN ENVIRONMENTALLY RESPONSI

BLE (OR "GREEN") INITIATIVES

Our planet is facing increasing environmental challenges, and Sprint believes corpora-

tions have a social responsibility to help create a "greener," more sustainable future. Sprint

has taken this responsibility seriously, as evidenced by its 15th overall ranking of the nation's

500 largest companies in Newsweek's inaugural 2009 Green Rankings survey.22 The Envi-

ronmental Protection Agency ("EPA") has further given Sprint a 19th ranking on its Green

Power Partnership Fortune 500 list. 23 Sprint also scored highest among U.S. based wireless

companies on the Carbon Disclosure Project's 2009 Global 500 Report on carbon disclo-

20 See http://shop.sprint.com/assets/pdfi;/en/shop/whv hte even wins. pdf21

22

Seei)np:j!sbop.sprinLcoll1INA$App/op.linestor,l,n/Action![)isplay$,IPhonep,taiI7pi)ol1eSKU=AI'A9292j(T8r. INICIP=A13: lJI'U:1J;:':RQ: 0<504 10:;:':vo lcalll1ch:9<50,,3 20.

See http://gr,,nrankings.n,,,,s,,,,,I<,cOi]1/toP~OO. See also Daniel McGinn, NEWSWEEK, TheGreenest Big Companies in America (Sept. 21, 2009), available athttp://'''\V,,,,n,,,,s\v,,.k.,comi2009/09/2Qlti)e,greenest,big-eompanieS,i n,america.. pri.11Lhtl11l.,-..' See EPA, Fortune 500 Partners (April 6, 2010), available athltp://w",w,epa,gOv/greenpo",cr/topIists/lortunc500 ,11 tm.

See Carbon Disclosure Project 2009, Global 500 Repoti, at 151-GO, available athltps://www,cdprojcct.nelien-US/Resu ItslPagcslreports. aspx.


July 30, 2010Page 6

25

Sprint has launched "green" initiatives throughout all aspects of its operations25 For

example,

• Sprint has set a greenhouse gas reduction goal of 15 percent by 2017.26

In 2009, Sprint achieved a 9.6 percent reduction, up from 6.8 percent in2008.27

• Over 80 percent of the electricity used at Sprint's corporate headquartercampus in Overland Park, Kansas is generated by a wind farm (outsideDodge City) that was built after Sprint negotiated a purchase contractwith the local electric utility.28 Sprint's purchase of 87 million kilowatthours annually has provided a reduction of over 87,000 metric tons ofC02 equivalents - the equivalent of taking over 16,000 cars off theroad for one year.29

• Sprint has stopped purchasing municipal water for landscape irrigationon its 200-acrc headquarters campus as water requirements are insteadnow met by the capture of on-site run-off water and use of a water recirculation pond.3o

• All new and refurbished retail stores will utilize Leadership in Energyand Environment Design ("LEED") standards that will reduce the carbon footprint of each store by about 19,000 pounds of C02 annually31

By late 2009, approximately 500 stores were updated.32

See generally !mp:l!Y;Y;\Y§PLil]tc90mIx9sPQIl5il;>jLity/~l]yiLol]m"i1tlil)<!"",ht.t11.1;

!mpj/gr""i1.5pri i1t.c:omI1EcJQ=Y!ll1ity:gr<;C:Il;I1ttp:II\Y\YW,sprillt.cQmirC:5POllsil;>iJLtyLeJlyirOIlil)C:11t1C:Ilyim!l11J"'ltlllpQlicy..I1t1l11;http://\ywW,sprint,cQI111rc:sPollsil;>ilitylc:01l1111Un.iJic:s_acrqss!iJl<!ex,btnlI?EclD.C:Yllni(Y:r"c:yc:!c: .

26 See Written Testimony of Daniel R. Hesse, Sprint CEO, Improving Energy Efficiency ThroughTechnology ad Communications Innovation, before the Senate Committee on Commerce, Science andTranspOltation, Subcommittee on Communications, Technology and the Internet, at 7 (Feb. 23, 2010)("Hesse 2010 Senate Testimony"), available athttp://9QI111l1erce•.SCIlate,goy!publi.c/ill<!e,,,c:fm?pc:llC:.llrillg5.8?ContelltR"cor<!.~i<!c:9<!Q9J<!7<!,<!b4c,4.4..7.5,8<!6Q:822cc:f<!0266c:8?Cont<;nJTYPLl<!c:14.f99.~ b9:<!fa~:4.Q7a,9<!J5:

569C715 2a.7.c:<!8?Groupjdc:IIOQc39af:c:033,4cba:9221 :<le6689a.I9.7.8a&.Mol.nIJI)isplayc28?Yc:m:[)isplay:20.IQ.27

29

31

32

See http://www.sprint.eom/responsibility/environment/index.html

See iel.

See id.

See Hesse 2010 Senate Testimony at 9.


See http://ww....sprillt.com/respolls!bility/ellvironlllC:llt/grccllfacilities.html.


July 30, 2010Page 7

Sprint is also using solar-powered energy at cell sites in several States, and it has dep-

loyed more than 250 hydrogen fuel cells at some of its sites. 33 In April 2009, the Department

of Energy ("DOE") announced a $7.3 million grant to Sprint so it can expand this program to

additional cell sites and to extend unassisted backup power to 72 hours (57 percent more than

that typically available today).34 Sprint also has a partnership with DOE to conduct alterna-

tive-energy research, and it currently works with two national laboratories. 35

Sprint was the first wireless carrier to establish a set of "green" design criteria for con-

sumer devices, and last year it developed an industry-first environmental "scorecard" to bol-

ster progress towards these design standards.36 Among other things,

• Sprint has introduced an increasing array of "green" accessories, including solar-powered chargers; an all-in-one vehicle and wall chargerthat meets EPA's Energy Star guidelines; and a variety of device casesmade from either recycled water plastic bottles or cotton and linen.37

• In August 2009, Sprint became the first wireless carrier to introduce aneco-friendly phone, the Samsung Reclaim™, the hardware of which ismade from bio-plastic materials extracted from corn, making 80 percentof the device recyclable.38 Sprint recently introduced two more "green"

TM TM 39devices, the LG Remarq and the Samsung Restore .

JJ

34


See DOE News Release, Secretmy Chu Announces $41.9 Million to Spur Growth ofFuel CellMarkets (April 15,2009), available at I1ttP:/!WIY\v.el1ergy.gQv/Iwws/7292.h!nl; Hesse 2010 SenateTestimony at 6.35 See Hesse 20 I0 Senate Testimony at 5.

37

36 See Hesse 20 I0 Senate Testimony at 16.

See Sprint News Releases, Sprint Launches Eco-Friendly Phone Accessories (May 18,2009),Sprint Expands Portfolio ofEco-Friendly Phone Accessories (Sept. 8, 2009); see generallyhttp://greSI1.spril1 t.'QI11/e'Qca,,essories.pl1p.38 See Sprint News Releases, Sprint Expands Environmental Leadership with New Initiatives andDebut ofEco-Friendly Samsung Reclaim (Aug. 6, 2009); Scllnsung Reclaim Fact Sheet Updated (Feb.11,2010).39 See Sprint News Releases, Affordable and Eco-Friendiy LG Remarq Continues Sprint's Wireless Indusliy Green Leadership (March 22, 20 I0); Sprint and Samsung Mobile Celebrate Earth Dayby Continuing Their Green Leadership with the Eco-Friendly Restore (April 20, 20 I0).


July 30, 2010Page 8

40

41

42

44

To help inform consumers regarding which products are more economically responsible than

the average wireless device, Sprint recently introduced an Eco-Logo on those products satisfy-

ing specified criteria.4o

The EPA estimates that only about 10 percent of all cell phones are recycled.41 Sprint

accordingly has made a public commitment to achieve by 2017 a reuse and recycling rate of

90 percent of device sales,42 and it has established two recycling programs to achieve this ob-

jective:

• Sprint Buyback - Current or new customers can bring in old devices(even if they are from other carriers) and they will receive account credit of up to $250 on over 900 eligible devices;43 and

• Sprint Project Connect - Anyone can recycle for free any phone, battery, accessory or data card - regardless of carrier or condition.

Sprint has already made substantial progress towards its 2017/90 percent goal. Its col-

lection rate for 2009 was 42 percent, up from 34 percent in 2008 (which, in tum, was up over

22 percent in 2007) - rates well above the industry average.44 Since 2001, Sprint's take back

See Sprint News Release, CEO Dan Hesse Profiles Environmental Leadership and GrowingPortfolio ofGreen Products at Earth Day Even Co-hosted by Rep. Markey (April 20, 2010);I1ttp:llww\N •.spr i.nt..99ID!I·esP9nsiPi lilY!el1.vil'Ql1.l.11el1.l!<:Ievieem.ilrke.l·eXileriil.Jl1111.1•

See EPA News Release, EPA Highlights Recycling Opportunities During National CellPhone Recycling Week (April I, 20 I 0), available athttp://w\Nw.epa.gQylilgil1g/pressl''Pil1'eYVs!20JQ/20 I 0._0401).l1tm.

See Hesse 20] 0 Senate Testimony at 19; Sprint Press Release, Sprint Sets Ambitious 90 Percent Wireless Recycling Goal (Feb. 12, 2009).

See Sprint News Releases, Sprint Partners ofthe U.S. EPA to Urge Americans to RecycleTheir Unwanted Cell Phones (April 1,20 10); Sprint Expands Its "Buyback" Program; Customers CanTrade in Any Eligible Cell Phone, Even }i'om Other Carriers, for Account Credit (Feb. 23, 20] 0).

See Sprint News Releases, Sprint Partners of the U.s. EPA to Urge Americans to RecycleTheir Unwanted Cell Phones (April 1,20 I0); Sprint Sets Ambitious 90 Percent Wireless RecyclingGoal (Feb. 12, 2009).

Sprint Nextel CommentsMobile Wireless Competition, WT Docket NO.1 0-133

July 30, 20 I0Page 9

45

46

47

programs have diverted more than 20 million phones from landfills for reuse or recycling,45

while further generating more than $7 million in charitable contributions to such programs as

4NetSafetySM that supports Internet safety for our children.46

In addition to being environmentally and socially responsible, Sprint has found that its

green efforts are good business practices. To begin, Sprint is addressing the growing envi-

ronmentally-conscious consumer market. Indeed, Sprint's three eco-conscious handsets have

proven to be popular devices and market differentiators. In addition, adoption of environmen-

tally responsible practices can also result in sizable cost reductions. For example,

• Last November, Sprint redesigned its packaging for its entire accessoryline, resulting in packaging that is smaller, fully recyclable, free of polyvinyl chloride ("PVC"), and includes recycled content - saving 647tons of waste annually, while reducing packaging costs by over $2 million annually.47

• A 2009 independent audit determined that efforts by Sprint's IT department to eliminate redundancies reduced the group's carbon footprint by over 10,000 metric tons - while cutting the group's operationcosts by $20 million and avoiding the need to build a new data centerfacility.48

Under Sprint's ZerO e-waste policy, none of the electronics collected through its recycling/reuse programs ever enters landfills or waste incinerators. Obsolete and non-functioning equipment/parts are recycled for base materials that receive a "second life" in other products. ImpOltantly,user data is erased from all handsets received, and recycling occurs only in OEeD countries in ISOcertified facilities that meet EPA R2 standards.

See Sprint News Releases, Sprint Partners ofthe u.s. EPA to Urge Americans to RecycleTheir Unwanted Cell Phones (April I, 20 I0); Sprint Expands Its "Buyback" Program; Customers CanTrade in Any Eligible Cell Phone, Even ji-om Other Carriers, for Account Credit (Feb. 23, 20 I0);http://www.spri.nt.cQ.n/4netsafety/.

See Hesse 20 10 Senate Testimony at II; Sprint News Release, Sprint Redesigns AccessoryPackagingfor the Eco-Consc!ous Consumer (Nov. 4, 2009).

See Sprint News Release, Sprint Greens 17: Reduces Carbon Emissions and Operating Costs(April 20, 2009).


July 30, 2010Page 10

Sprint's overall objective in this area is to help change norms so that what we define as

"green" today is "average" tomorrow. And, Sprint is hopeful that its leadership in this area

will provide our competitors with the impetus to take similar eco-friendly action.

C. SPRINT HAS RECENTLY INTRODUCED A WIDE VARIETY OF DIFFERENT PLANSFOR CONSUMERS NOT INTERESTED IN CONTRACT PLANS

The Commission over the past year has had a keen interest in examining service plans

with term contracts and early termination fees ("ETF"). Although most consumers choose a

term/ETF plan, a growing number of consumers are opting for service plans without contracts

and without ETFs. Indeed, Sprint alone offers a set of six different plans to consumers who

do not want to sign a term service contract that includes an ETF:

I. Pay-as-You-Go Prepaid Plans. Sprint introduced in May 2010 a new no-frills pay-

as-you-go plan, known as Common Cents MobilesM, which is available online and at 700

Walmart stores.49 Customers do not pay any activation, long distance or roaming fees, and

they pay only seven cents ($0.07) for each voice minute - and with the new Round Down1M

feature, calls are also rounded down (so, for example, customer pays only 7¢ for a call lasting

I minute and 46 seconds). 50 Customers also pay 7¢ per text, email or instant message and 7¢

per picture message (an unlimited messaging option is available for $20/monthly). Mobile

web is also available at $1 per day per megabyte ("MB").

See http://w.Nw.commoneentsmobilc.com/sh0 pipay -pc r-min ute-phone-p la nsimi nute··ph0 I1C

plansjsp (visited July 15,2010).

See http://www.commoncentsmobile.com/ (visited July 15.,20] 0); Walmart Press Release,WalmaltAddl· New Hi-Tech Devices and More Ways to Savefor the Aiways-Connected Life (May 13,20 I0), avaiiable at http://walmaltstores.com/pressroom/news/9864.aspx.50



51

55

2. A Budget, Lower Voice Usage Prepaid Plan. Two weeks ago, Sprint introduced

payLo™, a prepaid plan designed for budget conscious consumers. 51 Two options are availa-

ble:

I. The 400-Minute Monthly Plan. This plan costs $20 for 400 minuteseach month.

2. The 20¢/Minute Basic Plan. For those consumers that use their phoneless frequently, a customer adding $20 maintains an active account for90 days and pays the basic rate of 20¢/minute - for a monthly cost thatcan be as low as $7.00.

Additional minutes are 20¢/minute; the price for a basic text message is 15¢; the rate for a pic-

ture message is 25¢; and the rate for 3G data is $1.50/MB per day. CUlTently, four phones are

available and they range in price from $9.99 to $39.9952 These plans are available online,53

at Best Buy and RadioShack, and at many drug and convenience stores.

3. An Unlimited Prepaid Plan. For customers who use their wireless more extensive-

ly, Sprint - via its Boost Mobile brand - introduced in January 2009 a $50 monthly unlimited

plan for voice, text, data and walkie-talkie services54 And, Sprint has improved the plan by

adding even more value including unlimited calls to 411, and unlimited access to email and

instant messaging - for no additional fee 5S This plan also includes voicemail, call waiting

See http://\y\y\V,virgil1moQiI''_lI5il.(;OIl1/l2ayJQ/payJQj~la]1>.btmI;see also Sprint News Release,payLo by Virgin Mobile Launches with Minutes as Low as 5 Cents (July 15, 20 IO.

52 http://\y\y\V,yirginl11obiIellsa.col11/paylo/paylo,plans,htl11l (visited July 18,20 I0).

53 See http://w\y\y,yirginl11QQilcllsa.c;QI11/pay!o!paylo,pIamJ1l1111 (visited July 18,20 I0).

54 See Fierce Wireless, Boost Mobile Debuts $50 Unlimited Voice/Data Plan, (Jan. 15,2010),avai1able at http://www.fiercemobilecontent. comlstoryIboost-mobi Ie-debuts-50-un limited-vo ice-dataplan/2009-0 I- I5

See Business Wire, Boost Mobile $50 'Monthlv Unlimited Plan' Keeps Getting Better-- 4ii,Email and instant Messaging Now included, (May 4, 2010), available at http://www.QllSiIlCSS\vire.comIportal/site/home/permalink/?ndmViewld=news_view&newsld=20 I0050400545 I&newsLang=en



56

58

"

and call forwarding. 56 For an extra $10 ($60 monthly), customers can also select a Blackber-

. 57ryoptiOn.

4. Text and Data Prepaid Plans. For consumers who principally use text and data,

Sprint introduced in May 20 I0 three Beyond Talk™ plans on its Virgin Mobile platform.

These plans include unlimited messaging email, data and web. 58 The $25/monthly plan also

includes 300 anytime voice minutes, the $40/monthly plan includes 1,200 minutes, and the

$60/monthly plan includes unlimited voice - and for an additional $1 O/monthly, a customers

can choose the Blackbeny option, which includes web-based mail, BlackBerrl Messenger,

and BlackBerry App World™.59

5. A 3G Broadband Prepaid Plan. For consumers interested in mobile broadband,

Sprint - also via its Virgin Mobile platform - offers several different Broadband2Go plans,

ranging from a $10 option for 100 MB (expires in 10 days) to a $60 option for five gigabytes

CGB") (expires in 30 days).6o

6. Non-ContractlNo ETF Postpaid Plans. Sprint offers a basic month-to-month post-

paid plan. Consumers selecting this plan, however, are not eligible to receive any handset

subsidy; in other words, the customer must purchase a phone at the full retail price61 Again,

however, the customer is not subject to any contract, any term or any ETF.

See http://plans.boostl11obil,,,coll1/il1ol]lbiyunlimited,aspx (visited July 15, 2010).

See http://plans,boostmobile.,,om!blackb''l'l'Y,aspx (visited July 15,20 I0).

See http://W\v\'1,virgi nmobileusa .com/"el1 ,phone,pl3ns/beYolld,talk,pla,ns,html (vi sited July15,2010).

59 See id.

61

60See http://www.virginl11obi Icusa.col11/mobile-broadband# (visited July 15, 20 I0).

Sl11altphone devices, however, require the purchase of a Sil11ply Everything or Everything Data plans).



As seen above, clearly, consumers who do not wish to sign a contract or who wish to

avoid ETFs have ample affordable choices available to them from Sprint alone (with dozens

of additional options available from Sprint's competitors).

D. SPRINT HAS DEVELOPED A NEW SERVICE PLAN DESIGNED SPECIFICALLY TOHELP THOSE AMERICANS MOST NEGATIVELY IMPACTED BY THE RECESSION

While most Americans have been touched by what is being called the "Great Reces-

sion" (e.g., eroded retirement savings, depressed home values), some have been impacted

more severely, whether by reduced hours or job losses. In December 2009, Sprint launched a

new Lifeline program, Assurance Wireless. 62 Assurance Wireless is a free wireless service

developed specifically for the 37 million eligible low-income households who need it most.

With this service, eligible customers receive a free phone, 200 free weekday minutes

of voice (and unlimited usage during nights and weekend), free voicemail, and free call wait-

ing. Beyond the free 200 minutes, customers can pay IO¢/minute for additional domestic

calls, 10¢ for text, email or instant messages, and more. Assurance Wireless is cUlTently

available in nine States,63 and hundreds of thousands of customers have already signed up for

this uniquely tailored offering. Sprint anticipatcs the service will be available in approximate-

ly 25 states by the end of the year.

62See http://www.assuranccwircless,cqm/Puplic/WelcQJllc.aspx (visited July 15, 20 I0).

6)The nine States are: Florida, Louisiana, Maryland, Michigan, New York, North Carolina, Ten

nessee, Texas and Virginia.

Sprint Nextel CommentsMobile Wireless Compelition, WT Docket No. 10-133


64

66

67

In response to this new Sprint program, other wireless carriers offering Lifeline plans

have increased the number of minutes they make available to their Lifeline customers.64 This

is yet another example of how American consumers have benefited by competition.

E. WIRELESS PROVIDERS HAVE MADE IMPRESSIVE GAINS IN PROVIDING CONSUM

ERS WITH A POSITIVE CUSTOMER EXPERIENCE, AS RECENT SURVEYS CONFIRM

The Commission, over the past year, has shown an increased interest in learning

whether consumers are getting the information they need to make informed decisions.65 All

recent surveys show that consumers are increasingly satisfied with their mobile wireless ser-

vices, which suggest strongly that consumers are receiving timely the information they re-

qUIre.

Indeed, the FCC's own survey results, released last month, found that 59 percent of the

respondents were very satisfied with their mobile service (with another 33% somewhat satis-

fied); 58 percent were very satisfied with their coverage (with another 29% somewhat satis-

fied); and 62 percent were very satisfied with the performance of their mobile device (with

another 28% somewhat satisfied)66 A recent Government Accountability Office ("GAO")

survey similarly found that overall, 84 percent of wireless customers were satisfied with their

service while only three percent ("3%") were very dissatisfied.67 Similarly, the University of

For example, historically, with its Safelink Lifeline plan in Florida, TracFone included only 68free minutes a month. In response to Sprint's Lifeline serviee, TraeFone inereased its plan to include150 free minutes/monthly.

65 See. e.g., Consumer !njimnalion and Disclosure NO!, 24 FCC Rcd 11380 (Aug. 28, 2009);Bill Shock Public Nolice. 25 FCC Rcd 4838 (May II, 20 I0); Mobile Broadband Network Performanceand Coverage Public Nolice, GC Docket No. 09-158, DA 10-988 (June 1,20 I0).

John Horrigan and Ellen Satterwhite, Americans' Per,lpeelive on Online Conneclion Speedsfor Home and Mobile Devices, Summary of Findings, at 4 (June 1,2010), available 01

http://hraunfoss,fcc,gov/edocs,public/attachmatch/DQC,298516A I,pdf.

See GAO, Preliminary Observations About Consumer Sati.lfaction and Problems with Wireless Phone Services. GAO-09-800T (July 17,2009).



Michigan's 2010 American Customer Satisfaction Index survey found that since 2005, the

wireless industry as a whole increased its customer satisfaction rate by 10.8 percent, with

Sprint alone increasing its rate by 18.6 percent. 68

These impressive results should not be surprising. The fact is that unhappy customers

will not remain customers for long. Gone are the days where subscriber losses could be re-

placed with first-time buyers of wireless service. As discussed below, given high penetration

levels, the only way a provider can increase its subscriber base is first, by retaining existing-

and then, by convincing the customers of its competitors to switch to it. In this environment,

wireless providers have a powerful economic incentive to ensure their current customers are

satisfied - which includes giving them timely the information they need (because customers

receiving surprises generally become unhappy customers).

Sprint has dedicated itself to improving it customer satisfaction levels. As part of this

effort, Sprint has revamped its practices involving its customer "touch points" to help ensure

consumers are well-informed at all stages of the customer life cycle. And, Sprint's efforts are

paying dividends and receiving recognition. Sprint received the Gartner and Ito I Media

CRM Excellence Award, one of five gold medal winners, as an organization that uses cus-

tomer-focused strategies to improve their business performance.69 And, the J.D. Power &

Associates Wireless Business Satisfaction Survey recognized Sprint as the only catTier to see

its scores improve in the small/mid size business category in each of the 2008, 2009, and 2010

surveys.

It is useful to review these practices through use of three categories:

68

6'See http://www,theacsi .org/index,php?Qptioncon1.yol1tcnt&ctask~vie\V&cid~205&cItem id··2 I8.

See http://www.ltolmedia.comiView.aspx?ltemlD=30794



I. Ensuring Consumers Select the Right Plan and Device. Sprint provides to consum-

ers a variety of tools to help them decide which plan and device is right for them. Among

other things, Sprint provides:

• A sophisticated online coverage map tool so a consumer can assess theSprint coverage is available in the areas where they travel and further,the level of service (e.g., best, ftood, fair, roaming) a consumer can expect to receive in a given area. 0

• An easy-to-understand chart demonstrating what consumers can expectin terms of mobile broadband consumption:

Here's what you can do with 5GB or 300MB of data a month':HrJ'w moo)' 0; these HD'W many af these can

cafl I Eiefid or receive Jsend 0( receive ill aAw<oxima"<i!' in a month {300M8} month (5GB) .....hile or.

rite size· while mamingr the Sprlflt networkr

Email3 KB 100.000 t ,700,000(Tex! QI11y, no imdges)

PhotoSOOKB 600 10,000(low fB:iolut,oo il"(~~)

MUSIC3MB 98 1,667(:!. !l'tillu1e 80ng,\

MOvl€'700 MB 0 7{full ra->.-glh featlJr&)

·lhe-S8 fife e:izeB M<:1 dO\'lnwada awe es1irnated arid \"'it V&)' widely depending on lots 0"1 diff~ent

factor=. S.fr, you shouldn't really use tills ill,formstion to d€<:ide hru/ many ....ideos Of 6lillg5 you CBf1dOWnload. To ctlf'Ck yO'.lf Ct,Iffenl ds:ta usage, log <It! to My Sprint

• Online access to thousands of peer reviews of every device Sprint sells,as well as links to third party expert reviews (e,g., CNET),71 As butone example, the nation's first 40 smartphone, the HTC EVO 40,which Sprint introduced only last month, already contains over 740 different customer reviews,72

• Online access to Sprint's networking community of more than 50,000registered contributors to "buzzaboutwireless," an open forum with discussions about products, services and all things wireless.

• Sprint is also in compliance with the CTIA Consumer Code for Wireless Service ("CTIA Code" or "Code") which contains industry bestpractices for a variety of consumer disclosures including in advertising

70 See http://coveragesprinLcoll1i1rvtI)Ac:Tjsp')lcc:I!)=yanitY:eQyerage (visited July 22, 20 I0),71

72

Seehttp://comnl unity, sprinLcOll1iba\Virey ie\Vsjsp§?INTCli)",,(rvt: AI3: 20091 n4:~ lIQp:p],(lmo2:Com munity: 170x92 (visited July 22,2010).

See http://community,sprint.comibawidevicc-revicwsjspa"dev iceld-c 3562&prodld--BBi\9292W] (visited July 22, 20 I0),



73

and at the point-of-purchase. 73 And, CTIA recently announced updatesto the CTIA Code to improve upon consumer disclosures especially asthey pertain to messaging and data services for both pregaid and postpaid wireless customers (effective on January 1,201 I). 4 Sprint applauds the CTIA for its update of the CTIA Code. As one ofthe original signatories of the Code, Sprint believes these updates address consumer needs brought about by today's rapidly evolving wireless market, and the expanding array of consumer choices. Sprint has alreadyaddressed many of the Code changes in its consumer disclosures andwill continue to adjust its policies to ensure that they are consistent withthe provisions of the updated code. While the wireless retail market ishighly competitive, the CTIA and its carrier members understand fullythat a well-functioning market requires a free flow of information in order to support and protect consumers in their wireless choices.

2. Ensuring Consumers Truly Understand the Plan and Phone They Select. Once a

person selects a plan, Sprint then undertakes numerous steps to help ensure the person under-

stands the plan. Among other things,

• During the sales process, customers visiting a Sprint store are ledthrough the sales process by a Sprint representative. As the customerchooses his or her plan, device and other services, the sales agent entersinformation into Sprint's front-end order entry system. This systemthen auto-populates information that is displayed to the customer whocan review the information in real-time. As part of this process, thesales agent seeks the customer's acknowledgment of key terms andconditions. For example, with respect to the ETF, the customer readsand acknowledges - by clicking on a signature capture device - the following statement, "An early termination fee (ETF) of up to $200 perline applies if you terminate service early. Contracts starting after11/2008 are subject to Sprint's prorated policy ($200 through month 5of term, decreasing $10 a month until $50 minimum applies to remaining term). For more information, visit Yf\Yw.sprillLfQJll/~tJ."

• At the end of the sales process, the customer is then asked to sign theelectronic agreement. This information is captured in Sprint's systemsand the customer is provided a Transaction Summary and a SubscriberAgreement that contains the information reviewed and acknowledged

See http://wW\v.ctia.org/conslunerjnfo/index.cfl11/i\I{)/l0352

See C1'IA Press Release, CTIA-The Wireless Association@Announces Updates to Its "Consumer Code for Wireless Service, " (July 28, 20 10), available athltp: //www.etia.org/media/press/body.cfin/prid/ I992



75

by the customer. The Summary also includes a "Casual Usage andOverage" section so the new customer understands the cost tosend/receive text messages or to download ringers and songs if the customer chooses a plan that does not include some text or data usage.

• With its Ready Now program, a Sprint retail associate works with customers, one-on-one, to personalize their phone, set up its features, andshow them how to use it - before they leave the store.

• Sprint sends, generally within a day or two of the sale, a Welcome Letter to new customers that discloses prominently the terms of service(including ETF) and the contract start and end dates. Sprint also sendsa similar Confirmation Letter for customers who make a significantchange to their plan.

• Upon activation, each new customer's first call is routed automaticallyto Sprint's Welcome Center, which gives Sprint an additional opportunity to answer questions and to confirm the customer understands theplan purchased.

• Customers receive their first bill within 7-10 days of activation, whichbecause it is received well before the 30-day trial period ends, providescustomers with a good chance to reaffirm they chose the right plan (oralternatively, cancel service or change the plan).

Pcrhaps the best way for a new customer to confirm that the plan and device selected

are, in fact, the right ones is to take advantage of the one-month free trial period, available

with Sprint's "Free Guarantee."J5 Under this program, a person can, within 30 days of activa-

tion, cancel service for any reason. Sprint will then:

• Refund the monthly charges incurred as part of the service plan;• Refund the activation fee and the purchase price of the device;• Refund taxes and surcharges associated with the above charges; and• Waive the ETF and restocking fee.

A person cancelling service under this program is only responsible for extras not included in

the plan, premium content, third-party billing, and any taxes/surcharges associated with such

extras.

Seehttp://shop.sprint.col11/cn/shop/why.. sprint/gliarantcc/indcA.htJ111?INTC1[)'~Al3: UPU :IIERO:04111 O:GlIarantcc:960x3 20.



3. Ensuring Customers Remain Satisfied and Modify Their Plans as Their Circums-

tances Change. Sprint also takes many steps following the sale to help ensure new customers

are satisfied, including:

• Sprint provides several different means for customers to contact it withquestions or problems (i.e., an 800 number, via the web, dialing *2 fora free call to customer service), and each of these methods is prominently displayed on the first page of each monthly bill.

• Sprint proactively calls new customers several times during the firstyear to "check in" to ensure the customer is satisfied and has no unresolved issues.

• Sprint has implemented a variety of means (using both "pull" and"push" methods) to minimize the risk of customers receiving unexpected charges on the wireless bill. Sprint discussed many of its effortsin its comments in the "bill shock" proceeding76

, but wishes to highlight a few more examples here:

• International Roaming Alert - Sprint sends a "Welcome Message" when a subscriber first registers in a foreign country. It'sa text message that includes default rates for voice, texts and data. For example, a customer will receive the following textmessage upon registering in South Korea, "In South Korea tocall US dial 002-I-area code-number. Calls:$2.29/min, Data:$0.002/KB, Txt sent:$0.50 recvd:$0.05. Sprint Care 002-1817-698-4199.,,77

• On-Line Alerts - Sprint recently launched a new Sprint.comwhich provides notifications and alerts concerning customers'activity (through My Sprint) on their usage, billing, payment options, devices and more when they log onto Sprint.com. Thesealerts appear prominently upon the customer logging into theiraccount. Sprint has included screen shot examples of these online alerts in Exhibit A.

• Mobile Broadband Re-Direct Alerts - Sprint will soon implement a number of "re-direct" alerts warning mobile broadbanddata card users of their data consumption. The user will receivethe re-direct on their computer as they use Sprint's Smartviewsoftware to connect to the Internet. Importantly, for customers

76 See Sprint Bill Shock Comments, CG Docket No. 09-158, at 5 (July 6, 20 I0).77 Due to technical limitation, Sprint is unable to send a similar welcome text alert to consumersroaming in Canada.



78

79

gO

81

who have exceed the 300 MB data roaming cap and/or the 5 OBtotal data usage limit, the customer's data service will be suspended and the customer must essentially opt-in (after receivinga message concerning data rates) in order to restore service.Sprint has included screen shot examples of these alerts in Exhibit B.

• Text Message and Email Alerts -As part of a new initiativescheduled to launch this summer, for customers subscribing toconnection plans (e.g., mobile broadband cards, USB modems,embedded modems), Sprint will notify customers via text message and/or e-mail when they reach 75 percent and 90 percent ofthe 300 MB data roaming cap and the 5 OB total data usage limit. 78 Sprint has included examples of these alerts in Exhibit C.

• Sprint also offers (at no charge) a variety of parental controls that arealso effective in preventing account holders from incurring unwantedcharges. 79

• Sprint introduced an online Sprint Plan Optimizer so a customer can assess easily, based on past usage, what planes) may best fit that usage. 80

This tool provides customers with a transparent view into their planusage and alternatives and is intended to build trust with Sprint whilesimultaneously helping customers make educated and informed decisions about their plans. Some of the features of the Sprint Plan Optimizer include:

• Ability to change the billing-history range• Average monthly usage patterns for voice minutes, text messaging, da-

ta, etc.• Detailed current plan information• Breakout of monthly costs• Links to view monthly invoices• Average overage charges if applicable• Sprint has provided screen shot examples of the Sprint Plan Optimizer

in Exhibit D.

• Perhaps most impOitantly of all, under Sprint's Right Plan Promise,customers can change their plan at any time - without extending theircontract and without paying any penalties or fees. 81

See Sprint Bill Shock Comments, CG Docket No. 09-158, at 6 (July 6, 20 I0).

See id. at 6

See http://www.sprint.com/landings/spo/?Ec:m··vanity:planfil (visited July 22, 2010).

See http://seareh.spr int. C0111 linquiraapplui j sp?quest ion.~box=rightipJan+prom ise



In summary, Sprint has taken a variety of steps to help ensure that consumers are in-

formed in a timely fashion, do not experience and are ultimately satisfied customers. In the

highly competitive retail mobile services market, transparency and customer satisfaction go

hand-in-hand.

II. THE RETAIL MOBILE WIRELESS MARKET IS EFFECTIVELYCOMPETITIVE

Sprint submits there exists effective competition in the retail market for mobile wire-

less services and fmther, given high customer penetration rates, effective competition in this

wireless space will likely continue in the near term. Nevertheless, as discussed in Part III be-

low, there remain several critical inputs to the production of retail wireless services which the

Commission needs to address to "order to ensure a robust level of competition going for-

ward.,,82

A. THERE EXISTS TODAY EFFECTIVE COMPETITION IN THE RETAIL MARKET FORMOBILE WIRELESS SERVICES

Sprint believes there exists effective competition in the retail market for mobile wire-

less services, and CTIA's comments in this docket will document this fact. Sprint below

highlights three factors that demonstrate that today's market for wireless services is effective-

Iy competitive.

I. Consumer Price Index C"CPI"). Over the ll-year period 1997 to 2008, the price

urban consumers paid for goods and services generally increased by 34.1 percent, while the

prices paid for local telephone service increased by 41 percent. 83 In stark contrast, over the

See Fourteenth Annual Wireless Competition Report. WT Docket No. 09-66, FCC 10-81, at ~3 (May 20, 20 I0)(" 14th Report").

8J See 14'h Report at 110, Table 28.



same period, the price for wireless service decreased by 35.8 percent. 84 In other words, while

goods and services generally increased by one-third, over the same period wireless prices de-

creased by a third.

The wireless services CPI has continued to fall since the end of2008. Specifically, it

fell 1.2 percent during 2009 (from 64.4 to 63.6) and another 1.1 percent during the first six

months of this year (from 63.1 to 62.4) - for a total decrease over this 18-month period of3.1

percent. 85 1n contrast, during this same 18-month period, the CPI for goods and services gen-

erally increased by 3.2 percent (to 218.0 from 211.1).86 Sprint submits this CP1 government

data is compelling evidence of effective competition in the retail market for mobile wireless

services.

2. Sprint Value Enhancements. With respect to postpaid, term contract plans, Sprint's

pricing has held steady during these difficult economic times. For example, Sprint's Simply

Everything'M Plan has remained at $99.99 per month since its inception in February 2008

(nearly 2 Y2 year ago)87 And, Sprint's Everything Data'M has also remained at $69.99 (with

450 anytime voice minutes) over this same time period.

84 Seeid.85

87

86

Seehttp://data.bls.gov:8080/PDQ/scrvlct/SurvcyOutputScrvlctJscssionid=6230d3 bScd80793 b Ib61.

See http://data.bls.gov/cgi,bin/survcymosl.

See Sprint News Release, Sprint Launches Revo!utionCIIY 599.99 "Simp(y Evelything(SMj"Plan, (February 28, 2(08).

Sprint Nextel CommentsMobile Wireless Competition, WT Docket No. 10-J33


88

Sprint has, however, enhanced the value proposition of its plans. In September 2009,

Sprint announced its Any Mobile, AnytimesM plan88 This innovative plan was designed to

burst the bubble of other carriers' so-called "calling circles." Sprint customers can expe-

rience the freedom of unlimited mobile-to-any-mobile (on any carrier) calling by signing up

for one of the Everything Data or Everything Data Family plans. Additionally, when Sprint

launched Any Mobile, AnytimesM , the benefit was provided to millions of current customers

on the Everything Data plans automatically, at no additional charge, and without any effort on

the customer's part. Further, with Sprint's Right Plan Promise, existing customers who are on

a different plan can take advantage of Any Mobile, Anytime by switching to an Everything

Data plan without being required to renew or extend their existing service agreement.

3. Comparison of U.S. and U.K. Wireless Plans. It is, the Commission has recog-

nized, an "established practice" to use "international benchmarking to assess effective compe-

tition in mobile markets."s9 Sprint below compares some of the plans its sells to American

consumers with those Vodafone sells to U.K. consumers. Sprint chose the U.K. because the

U.K. has the most competitive mobile market in Europe, has five national mobile operators,

and has a Herfindahl-Hirschman Index ("HHI") comparable to that in our country.90 This

comparison confirms that American consumers receive good value compared to their counter-

pailS in the UoK.

See Sprint News Release, Sprint Customers Can Break Free ofCalling Circles with Any Mobile, Anytime, (September 10, 2009).

89 See 14'h Report at 104 n. 961.

90 See id. at 197, Table 41 and'1366.



91

92

94

93

For example, both companies offer postpaid plans with two-year contracts. Sprint's

Simply Everything® plan and Vodafone's £60 Plan are available at a similar monthly price:

$99.99 and $99.16 respectively.91 With Sprint's plan, a consumer receives unlimited voice,

unlimited push-to-talk and unlimited messaging (text, picture and video).92 With Vodafone's

plan, a consumer receives lots of minutes (3,000 monthly) and unlimited text messaging; it is

unclear whether picture and video messaging are included within this text messaging allot-

ment93 There are, however, three major differences between the two, similarly priced plans:

I. Data/Web Browsing. With Sprint's Simply Everything'M plan, onereceives unlimited data/web usage. 94 In contrast, Vodafone's £60 Planincludes only I OB of usage, and usage above this limit is charged at76¢ for each 25 MB consumed each day.95 Thus, if a Vodafone customer wishes to download a movie and has already reached his I OBallotment, the customer would pay over $21 simply to download themovie - a cost the Sprint customer would not incur96

2. Long Distance. Sprint's Simply Everything plan includes no long distance charges, so a customer can make a voice call to anyone in theU.S. without incurring any extra fees. In contrast, the 3,000 voice minutes included in Vodafone's £60 Plan apply only to calls made withinthe U.K. Thus, a £60 Plan customer must pay an additional £1 (or$1.53) per minute to call someone located elsewhere within Europe.97

3. Coverage. The unlimited usage in Sprint's Simply Everything plan applies regardless of where the customer travels on Sprint's nationwide

In the above analysis, Sprint uses the British pound (GBP")/dollar ("USD") exchange rate thatapplied on July 20, 20 IO. On this day, the exchange rate was one GBP = $1.5253 and one USD =£0.66.

Seehill'://,hop, .\pril1/, cOJ}//NASApp/ollliuesrore/en/;icrionjDispl{lyplan\?!iVTiV;i Ve;i TQ"ELI'I{ll1.\ (v is itedJuly 20, 20 I0).

See http://s!lQp,voclaf'olle,co,,lk/shop!J11(lbile,pl'ice,plal1s/all,plam (visited July 20, 20 I0).

Sprint continues to offer unlimited data usage while on the Sprint network within their SimplyEverything and Everything Data plans.

95 See http://shop. vodafone.co,ukJshop/mobile,price,plans/all,plans.

96 This example assumes a full-length motion picture consumes 700 MB.

97 See http://shop,vodafclnc,co.uk/shop/mobile-price-plans/all-plans.



98

99

network. In contrast, Vodafone's £60 Plan applies to usage only withinthe U.K. If the U.K. customer wishes to use her mobile device whiletraveling elsewhere in Europe (including on Vodafone's EU network),the customer must pay extra for that usage and will be billed at highroaming rates. 98

Sprint submits that American consumers interested in postpaid plans receive a far better value

than their counterparts in the U.K.

Similar differences exist with respect to non-contract plans. For example, both com-

panies offer pay-as-you-go prepaid plans. With Sprint's Common Cents MobilesM plan, a

customer pays seven cents (7¢) for each voice minute and 7¢ for each text message, instant

message, picture message or emai1.99 With Vodafone's "Vodafone Simply" plan, a U.K. con-

sumer would pay 31 ¢ a minute for voice,lOo l5¢ for each text message, and 55¢ for each pic-

ture message; it is unclear whether email and instant messaging is available with this plan. IOI

Again, while Vodafone's prepaid plan applies to usage within the U.K. only, Sprint's plan ap-

plies regardless of where the customer travels on Sprint's national network. Sprint submits

that American consumers interested in prepaid plans also receive a far better value than their

counterparts in the U.K.

The E.U. Parliament recently imposed caps on roaming prices within Europe because E.U.roaming charges were so high. See Sprint Bill Shock Comments, GC Docket No. 09-158, at 8-12 (July6,2010),

See http://vvww.c()Jl1JnOnCel1tsll1ob.ilcSom/s!loP!pay,pe.l',mi.ll.l1te.,.p.h()11c.,plans/.l11inlltc,pllonC,plansjsp (visited July 20, 20 I0). Common Cents customers also have the option to obtain unlimitedmessaging (text, instant, email and picture) for $20/monthly. No such unlimited option appears to beavailable with the Vodafone Simply plan.

100 With Europe's calling-party-pays system, consumers typically pay only to originate a voicecall, not to receive a call.101 See hltp:l/shop,vodafone,co,uk/pay:as,yoll:go/hllb/vodafoncl (visited July 20, 2010).



102

The U.K.'s regulator, Ofcom, recently determined that "competition within the [U.K.]

mobile sector is generally working well."I02 For example, Ofcom decided last year not to

adopt any net neutrality rules because "competition in the mobile sector is currently address-

ing access concerns adequately":

[I]n a competitive market we expect that the degree of "net neutrality" (if any)will be determined by consumer choice and therefore does not require regulation. 103

Sprint submits that if the mobile services sector in the U.K. is competitive, then the mobile

services sector in the U.S. is competitive as well.

B. HIGH PENETRATION RATES SHOULD ENSURE THAT THE RETAIL MARKET FOR

MOBILE WIRELESS SERVICES WILL REMAIN EFFECTIVELY COMPETITIVE IN

THE NEAR TERM

Sprint believes that effective competition in the retail mobile wireless space will likely

continue for sometime. This is because of the competition that necessarily results when a

market like mobile wireless services becomes saturated. However, preserving this competi-

tion will require the Commission to address the scrious market failures surrounding critical

inputs to the wireless market, including special access services controlled by the two largest

carriers in the United States, AT&T and Verizon.

The Commission has calculated that at the end of 2008, the nationwide penetration

rate for mobile wireless service was 90 percent. 104 While this calculation is correct, the calcu-

lation includes children who do not make decisions regarding subscription to wireless services

and generally are not heavy users of such services. If children under the age of II are ex-

Ofcom, Mostly Mobile; Ofcom 's Mobile Sector Assessment, Second Consultation, at 42 ~ 4.5(July 8, 2009), available at http://www.ofcom.org.uk/consult/condocs/msa/.103

104

ld. at 67 ~ 4.88, 69, Q 4.4, and 67, 11 4.91.

See 14'" Report at ~ 156.



105

106

107

cluded from the calculation, the national wireless penetration rate at the end of2008 would be

104.8 percent. 105 If children under the age of 14 are excluded, the national wireless penetra-

tion rate at the end of2008 would instead be 113.3 percent. 106 Penetration rates at the end of

2009 may be even higher because CTIA estimates that wireless connections increased by 5.7

percent in 2009 (to 285.6 million from 270.3 million at the end of2008), 107 while the Census

Bureau estimates that our population increased by only 1.0085 percent between 2008 and

2009 (from 304.4 million in July 2008 to 307 million in July 2009).108

Regardless of how penetration rates are calculated, the important point is that penetra-

tion rates for wireless service are very high. This fact has enormous ramifications for wireless

providers. Specifically, given current penetration levels, the only way a provider can increase

its customer base is by (l) retaining as many of its current customers as possible (i.e., have a

low churn rate), and (2) attracting current customers away from its competitors by convincing

them they would receive lower prices and/or better value by switching providers. Put another

way, the number of first-time buyers of wireless service has become so minuscule as to be-

come largely irrelevant as a practical matter.

This situation becomes even more challenging given that new customers tend to gen-

erate lower revenues than existing customers. Patt of this is due to the growing popularity of

The Census Bureau has estimated that in July 2009, there were a total of 307 million Americans, of which 42.9 million were under the age of 11 and 265 million people over the age of 10. With277.6 wireless subscribers at the end of2008, the penetration rate of wireless subscribers over the ageof 10 would be 104.8 percent.

The Census Bureau's July 2009 estimate is that there were 61.9 million Americans under theage of 15 and 245.1 million people over the age of 14, resulting in a year-end 2009 penetration rate of113 J percent.

See CTIA Semi-Annual Wireless Industry Survey, Annualized Wireless Industry Survey Results - December 1985 to December 2009.108 See htlp:!/WW\\ .eensus .gov/popest/slales/N ST-ann-esl.hlm I.



prepaid plans, which generally generate lower average revenue per unit ("ARPU,,).I09 Part of

this is also due to the fact that with continuing competition, the per unit price of wireless ser-

vice - whether voice minutes, text messages sent and received, or gigabytes consumed - con-

tinues to fall.

As all wireless carriers know very well, it is considerably cheaper to retain an existing

customer than to acquire a new customer. Service providers, therefore, have powerful incen-

tives to improve customer satisfaction, build loyalty and reduce churn. The central point the

Commission needs to understand is that when wireless penetration rates are high, competition

in the retail market necessarily will be intense - and the beneficiaries of this competition are

consumers.

III. THE COMMISSION MUST ADDRESS PROMPTLY THE CRITICAL INPUTSTHAT AT&T AND VERIZON CONTROL OVER THE MOBILE WIRELESSECOSYSTEM

One major risk to the future competitiveness of the mobile wireless space is vertically-

integrated companies that hold virtual monopolies over critical upstream or input markets. It

is no surprise and certainly not by chance that the two most powerful and vertically-integrated

telecommunications service providers also control "60 percent of both subscribers and reve-

nue" within the wireless market. These vertically-integrated providers also exert tremendous

control over the LEC and wholesale markets. As such, Sprint applauds the recent 14th Wire-

less Competition RepOli because, for the first time in its mmual repolis, the Commission ana-

lyzed competition across "the entire mobile wireless ecosystem, including ... in-depth ana-

lyses of 'upstream' and 'downstream' market segments." 110 The Commission correctly rec-

109

110

See 14th Report at , 98.

14th

Report at' 2.



ognized that "input segments can affect entry, competition, output, or prices in the provision

of mobile wireless services."lll Analysis of key inputs is thus important in order to "ensure a

robust level of competition going forward." I 12

Sprint below discusses three critical inputs to the production of wireless services.

These three different inputs share one point in common - namely, this nation's two largest

communications corporations, AT&T and Verizon, have considerable control over each of

these inputs. As a result, as the Commission has correctly recognized, wireless providers like

Sprint that are "unaffiliated with a wireline provider often must rely on their competitors affil-

iates for access.,,113 AT&T's and Verizon's bottleneck control over these critical inputs ob-

viously poses problems in the retail market for mobile wireless services.

Indeed, the Commission has previously recognized that LECs with wireless affiliates,

given their "control of 'bottleneck' wireline local exchange facilities," have both the incentive

and ability to engage in anticompetitive practices such as "unfair 'price squeezes'" to harm

wireless carriers not affiliated with any LEC. 114 And, the Commission has noted, this LEC

incentive increases when wireless services compete directly with the LEC's own local ex-

ehange services. I 15

A. THE COMMISSION SHOULD PROMPTLY RESOLVE ITS LONG-STANDING SPECIAL

ACCESS BACKHAlJL INVESTIGATION

Cell site backhaul connections are "an integral component of a wireless service pro-

vider's network":

III

! 12

113

114

115

Id at1i 10.

Id. at ~ 3.

14'h Report at ~ 296.

See Wireless Safeguard\' Order. 12 FCC Red 15668. 15670 ~ ], 15688-90 ~~ 27-30 (1997).

See id. at 15670 ~ 1 and 15692 ~ 36.


In light of the growing need for backhaul, cost-efficient access to adequatebackhaul will be a key factor in promoting robust competition in the wirelessmarketplace. I 16


Record evidence before the Commission demonstrates that in many areas of the coun-

try, AT&T and Verizon possess monopoly (or bottleneck) control over special access back-

haul facilities. The Commission has been examining AT&T's and Verizon's special access

prices and practices since 2005 and is in the process of establishing an analytical framework

to help examine whether or not the current regulation of special access services is ensuring

rates, terms, and conditions that are just and reasonable as required by the Act. 117 The Com-

mission must promptly address this long-standing investigation and to again acknowledge in

its next annual report that the availability of special access backhaul facilities, at reasonable

rates and terms, remains a critical input to the provision of mobile wireless services - espe-

cially for those providers that are not affiliated with LECs.

B. THE AVAILABILITY OF DATA ROAMING AT REASONABLE RATES AND TERMS Is ACRITICAL INPUT TO THE PROVISION OF MOBILE BROADBAND SERVICE

Wireless carriers compete with each other based on their respective network cover-

age. 118 As the Commission has recognized, "roaming remains an important means for mobile

wireless providers in areas where they do not have coverage":

Due to the challenges inherent in building out a wireless network, which caninclude both economic and environmental obstacles, it may be more cost-

116 14'" Report at ~ 293 and ~ 296.117

118

See Public Notice, Parties Asked to Comment on Analytical Framework Necessary to Resolvehsues in the Special Access NPRM, 24 FCC Rcd 13638 (2009).

See, e.g., Tenth Annual Wireless Competition Report, 20 FCC Rcd 15908, 15949 ~ 105 (2005).Vcrizon Wireless' advertising campaign last year, 'There's a map for that," illustrates the importanceconsumers place on coverage.

Sprint Nexte1 CommentsMobile Wireless Competition, WT Docket No. 10-133

effective in some areas for a mobile wireless provider to attain roaming agreements with other providers than to build out its own facilities. 119


Indeed, the fact is that "no mobile wireless provider - including the four nationwide providers

- has built out its entire licensed service area, and consequently all providers employ roaming

to some extent to fill gaps in their coverage.,,120

The Commission, "recogniz[ing] the importance ofroaming,,,121 recently reaffirmed

that wireless carriers must provide roaming for voice services at just, reasonable and nondi-

scriminatory rates. 122 It also issued a further NPRM asking whether it should "extend roam-

ing obligations to data services such as mobile broadband and Internet access services.,,123 If,

as the Commission has found, roaming is important for voice services, roaming certainly is

important for broadband and other data services. Sprint therefore encourages the Commission

to complete expeditiously this data roaming rulemaking.

While the 14th Report addressed the subject of roaming, it did so as part of its general

discussion of the wireless ecosystem generally. Sprint submits that for its next report, the

Commission should instead address roaming in the section discussing input segments. Input

segments are those functions that can "affect entry, competition, output or prices in the provi-

sion of mobile wireless services,,,124 and data roaming certainly meets that definition.

119

120

121

14'h Report at~~ 124-25.

Id.at~125.

See id. at ~ 126.122 See Roaming Reconsideration Order, 25 FCC Red 4181 (2010).

123 See 14'h Report at ~ 126. See also Data Roaming Further NPRM, 25 FCC Red 4181,4207-24~~ 50-91 (April 21, 2010).

124 14'" Report at ~ 10.



125

C. THE HARMFUL IMPACT OF TODAY'S ANTIQUATED AND DISCRIMINATORY IN

TERCARRIER COMPENSATION REGIME ON THE WIRELESS ECOSYSTEM

There is one critical input to the provision of wireless services that the Commission

did not address in its 14th Report, but which Sprint submits should be added to the 15th Report

- namely, today's severely broken system governing intercarrier compensation.

Congress determined in the 1996 Act that the exchange of all telecommunications traf-

fic should be subject to reciprocal compensation. 125 Under the statutory "additional cost"

standard,126 such compensation is appropriate only if a LEC incurs additional costs in call

termination - to wit, traffic sensitive end office costS. 127 Given the switching technologies in

use today, most LECs no longer incur any traffic sensitive switching costs in terminating

another carrier's traffic. As a federal appellate court held in affirming a state public utility

commission decision directing two interconnecting LECs to use bill-and-keep because they

incurred no traffic-sensitive switching costs, "But if no additional costs are incurred, there is

nothing to pay":

The district court's reading of § 251(b)(5) would force carriers to pay oneanother regardless of whether they incurred additional costs or not. Such areading would directly contradict the plain meaning of § 252(d)(2)(A)(ii).128

See 2008 ISP Remand Order, 24 FCC Rcd 6475, 6483 'il15 (2008)("[T]he transpott and termination of all telecommunications exchanged with LECs is subject to the reciprocal compensation regime in sections 251 (b)(5) and 252(d)(2)(italics added); 200IISP Remand Order, 16 FCC Rcd 9151,9166 'il32 (200 I)("Unless subject to further limitation, section 251 (b)(5) would require reciprocalcompensation for transport and termination of all telecommunications traffic - i.e., whenever a localexchange carrier exchanges telecommunications traffic with another carrier.")(italics in original).126 See 47 U.S.c. § 252(d)(2)(A)(ii).

127 See Local Competition Order, II FCC Rcd 15499, 16025 'iI 1057 (1996)("For the purpose ofsetting rates under section 252(d)(2), only that pOltion of the forward-looking, economic cost of endoffice switching that is recovered on a usage-sensitive basis constitutes an 'additional cost' to be recovered through termination charges.")(italics added). The FCC latcr clarified that usage-sensitivecosts also exclude the "getting started" costs of such switches. See Virginia Arbitration Cost Order,18 FCC Rcd 17722, 17872 n'il378, 17876 n.l 016, 17877 'il391, 17912 'il488 (2003).

128 Ace Telephone v. Koppendrayer, 432 F.3d 876, 881 (8 th Cir. 2005).

Sprint Nextel CommentsMobile Wireless Competition, WT Docket No.1 0-133


129

Accordingly, under the Act and given the evolution of switching technologies, Congress ex-

pected that all traffic today would be exchanged under a bill-and-keep arrangement.

Yet, most wireless-LEC traffic today is not exchanged per bill-and-keep, and a consi-

derable volume of such traffic is rather exchanged at above-cost LEC access charges. This

situation was initially caused by Congress' enactment of Section 251(g), a grandfather provi-

sion that permitted LECs to continue to impose access charges for traffic that was subject to

access charges in 1996. But as the Commission and federal courts have recognized, this

grandfather provision was to be temporary only:

[T]hat section [251 (g)] is worded simply as a transitional device, preservingvarious LEC duties that antedated the 1996 Act until such time as the Commission should adopt new rules pursuant to the Act. 129

Thus, the principal reason that LECs have been able to assess above-cost terminating access

charges on wireless carriers has been Commission inaction over the past 14 years.

But the situation is actually much worse. This is because while LECs have been per-

mitted to charge above-cost access charges for terminating interMTA mobile-to-Iand traffic,

the Commission has prohibited wireless carriers from accessing any access charges for termi-

nating land-to-mobile traffic. 130 Thus, the pre-Act regime that still remains in place is grossly

discriminatory, because intercarrier compensation for interMTA traffic flows in one direction

only (to the benefit ofLECs including Sprint's primary wireless competitors, namely AT&T

and Verizon).

WorldCom v. FCC, 288 FJd 429, 430 (D.C. Cir. 2002). See also Feature Group IP Forbearance Order, 24 FCC Red 1571, 1572 ~ 2 (2009). It is perplexing how a LEC can claim its receipt ofabove-cost access charges constitutes a "LEC duty."DO See Wireless Access Charge DeclaratOlY Order, 17 FCC Red 13192 (2002).



132

131

The consequence of this state of affairs is that there is an ongoing and massive wealth

transfer from wireless carriers to LECs - in effect, the wireless industry subsidizes the LECs

with whom they compete for the consumers' telecommunications dollars. These wealth trans-

fers have little impact on vertically integrated companies such as AT&T and Verizon - be-

cause at the holding company level, it makes little difference whether revenues, costs and

profits are recorded by their wireless or wireline subsidiaries. But this arrangement has an

enormous impact on carriers like Sprint that are not affiliated with a LEC, because money that

could be spent on broadband or expanding coverage must instead be diverted to payment of

above-cost LEC access charges - with many LECs having affiliates that also compete in the

wireless space.

The Commission has been considering intercarrier compensation reform for nine

years,13I and it has announced it will issue yet another further NPRM by the end of this

year. 132 Sprint urges the Commission to complete expeditiously this investigation once and

for all. But at minimum, the Commission should address this important subject in its next an-

nual repOll. Clearly, the continuation of this discriminatory system of implicit subsidies is

having an enormous impact on robust competition within the mobile wireless ecosystem.

IV. THE COMMISSION SHOULD ASSURE THE AVAILABILITY OF ADDITIONAL SPECTRUM

FOR COMPETITIVE MOBILE BROADBAND SERVICES

The Commission, in its National Broadband Plan, established as one of its overarching

goals that our nation "should lead the world in mobile innovation, with the fastest and most

See Unified Interearrier Compensation Refimn NPRM, 16 FCC Rcd 9610 (2001).

According to its Proposed 20 I0 Key Broadband Action Agenda Items, the FCC intends to issue another NPRM before the end of this year. See fCC News, FCC Announces Broadband ActionAgenda (April 8, 20 I0).

Sprint Nextel CommentsMobile Wireless Competition, WT Docket No, 10- J33


extensive wireless networks of any nation,',133 Mobile broadband represents "the convergence

of the last two great disruptive technologies - Internet computing and mobile communications

- and may be more transformative than either of these previous breakthroughs,,,134

Consumers' use of mobile broadband is already growing at "unprecedented rates,,,135

For example, Cisco projects that data usage on North American wireless networks will in-

crease 40-fold in the next four years alone,136 The Commission has further recognized, cor-

rectly, that the growth of mobile broadband will be "constrained if the government does not

make spectrum available to enable network expansion and technology upgrades":

If the U,S, does not address this situation promptly, scarcity of mobile broadband could mean higher prices, poor service quality, an inability for the U.S, tocompete internationally, depressed demand and, ultimately, a drag on innovation,137

The Commission has concluded that, to address this mounting demand for mobile

broadband services, it needs to make "500 megahertz of spectrum newly available for broad-

band by 2020, with a benchmark of making 300 megahertz available by 2015,"138 In imple-

menting this goal, the Commission should assure that as it makes additional spectrum availa-

ble, it is not concentrated in the hands of veltically integrated carriers exercising dominant

market power. Spectrum is a critical input in fostering a robustly competitive mobile broad-

band marketplace,

133

134

135

136

137

138

National Broadband Plan at 25,

Id at 75,

M at 25,

M at 76-77,

Id at 77,

National Broadband Plan at 26, See also id at 84,


V. CONCLUSION


In summary, Sprint submits these comments to help inform the Commission as it pre-

pares its next, 15"1 annual wireless competition report.

Respectfully submitted,

SPRINT NEXTEL CORPORATION

lsi Charles W McKeeCharles W. McKeeVice President, Government AffairsFederal and State RegulatorySprint Nextel Corporation900 Seventh Street N.W., Suite 700Washington, D.C. 20001703-433-3786

Scott R. FreiermuthCounsel, Government AffairsFederal RegulatmySprint Nextel Corporation6450 Sprint ParkwayOverland Park, KS 66251913-315-8521

July 30, 20 I0

On-Line Account Alerts

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Number XXXXX6039

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Dear [CUSTOMER] :

Sprint has completed a modification(s) to your account.minute to carefully review this confirmation:

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Confirmation no.: 454925340 Rep Id: 11111Date/Time: Jul 28, 2010 06:05 am(CST)

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Email NotificationMobile Broadband Connection Plans

100% of 5 GB on Sprint Network

-----Original Message-----From: nore p 1 y@ s p r i n t . corn [~_?_J_~_:t::_S?":_.I!.?_:r::~.P.~.Y~__~p.:r::_j..r~_:t:: __.,,gg_~ ]Sent: Thursday, Jul 29, 2010 10:46 PMTo:Subject: SPRINT ALERT: Data Usage Update XXXXX6039


Dear [CUSTOMER]:


Please take a

Confirmation no.: 455995817 Rep Id: 11111Date/Time: Jul 29, 2010 09:41 pm(CST)

Modification(s): - Important Notice for 9136098884: As of 07/29/2010at 11:03am, you have used 5268270.00 KBytes of your 5242880.00 KBytesmonthly Sprint Data allotment. If you exceed the monthly usage cap, youwill incur overage charges of $0.05 per MB until your usage is reset on08/04/2010. You can avoid overage charges by monitoring your usage;simply sign into your account at sprint.com.


Email: Cl.1.c k \',1_i:'!_\I>1 ' __~E!:_:\"f.l_:t:: __:"s::g"~/,,~_~_9}_,~,,g~_E __~_Chat: Click ~Y!,i:'!__.....~.P.J:.:_~_0_:t:: ~ __~g_~l<:::_h_9_~Phone: Press *2 from your Sprint phone If you have trouble with the





Note: If you have recently provided us with a new email address, weare required to send notices (like this one) to your old address forthe first 30 days. Once the 30-day transition period has elapsed, wewill send notices to the new email address.

-----Original Message-----from: [email protected] [mailto:nOEoEly@sprint,com]Sent: Wednesday, July 28, 2010 7:08 AMTo:Subject: Sprint Notification for Account Number XXXXX6039


Dear [CUSTOMER] :


Please take a


Modification(s): - Important Notice for 9136098884: As of 07/27/2010at 03:09pm, you have used 3947522.00 KBytes of your 5242880.00 KBytesmonthly Sprint Data allotment. If you exceed the monthly usage cap, youwill incur overage charges of $0.05 per MB until your usage is reset on08/04/2010. You can avoid overage charges by monitoring your usage;simply sign into your account at sprint.com.


Modification(s): - Important Notice for 9136537413: As of 07/27/2010at 09:11pm, you have used 233492.00 KBytes of your 300 MB monthlySprint Data Roaming usage allotment. The terms and conditions of yourplan state that you are allowed 300MB of data roaming usage. Accordingto these terms, Sprint can suspend your domestic roaming data usageuntil your next billing cycle begins on 08/04/2010. You can avoidoverage charges by monitoring your usage; simply sign into your accountat sprint.com.


Email: CI i c k _~~_~ __. $£_~A __D__~_.,_~_qJ!l_l5;!'~''?M~.~~S::.?_E~~Chat: Clie k _~~_~_~__§E~_J:~!_' __~5?_r:llL~h __?_t_Phone: Press *2 from your Sprint phone If you have trouble with the




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Email NotificationData Roaming

100% of 300 MB&

Suspension Notification

-----Original Message-----From: [email protected] [rnaiJj:g:[email protected] ]Sent: Wednesday, July 28, 2010 8:41 AMTo:Subject: Sprint Notification for Account Number XXXXX6039


Dear [CUSTOMER] :


Please take a


Modification(s): - Important Notice for 9136537413: As of 07/27/2010at 10:01pm, you have used 307200.00 KBytes of your 300 MB monthlySprint Data Roamj.ng usage allotment. The terms and conditions of yourplan state that you are allowed 300MB of data roaming usage. Accordingto these terms, Sprint can suspend your domestic roaming data usageuntil your next billing cycle begins on 08/04/2010. You can avoidoverage charges by monitoring your usage; simply sign into your accountat spr.int.com.


Modification(s): - Important Notice for 9136537413: As of 07/27/2010at 10:01pm, you have used 307200.00 KBytes of Sprint Data Roamingusage. To avoid further violation of your service agreement, we havesuspended your domestic data roaming ability until your monthly usageallotment is reset on 08/04/2010. This alert only applies to domesticroaming; you are free to continue using your device on the Sprintnetwork. To use data beyond your monthly domestic usage cap for $0.25per MB, please call 1-866-957-6899 to change your plan. You can avoidoverage charges by monitoring your usagei simply sign into your accountat sprint.com.


Email: eli c k ~,t.:V_l,t,1,_~ __ $P.:r:'__~_0__t '__::;.9_I"fl_/_~_~?:_:~Jt:::,C:lE_,~,Chat: C1 i c k ~,~.J.:'1__:__.:?,PE.A_0_!: ~ ~g.r!.t/.<::: __b_?:_tPhone: Press *2 from your Sprint phone If you have trouble with the






Text Message Alerts

Mobile Broadband Connection Plans100% of 5 GB on Sprint Network

SprintFreeMsg. 9136098884 on 07/29/2010@11:03am has used 5268270.00KBytes of 5242880.00 KBytes Sprint Data.Overage is $0.05MB.

75% of 300 MB Data Roaming

SprintFreeMsg:Usage Alert:9135756749 on 06/25/2010@06:08pm has used230227.0 KBytes Sprint Data Roaming allowance.Monthly usage resets07/25/2010.

Sprint

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Your current plan Your plan is a good fit

We re<:ommend you stay on your ~n. Sased on your extra charges and the way you us-ed your phonE" in thepast, your pl.an is the best value for }'ou.

Everything Messaging Family/Share 1500

Prim",ry line:JESS: 936·499·7327

1> 3 Mdition~ tinn

1> Contri5ct end date

Talk 1500 anytime minutes $ 99.99t> Additional tine charges 12 tinesl S 19.98t> Nights and weekends stllrtini inducl~

at 10m (4 lints)t> Mobile to mobil" fncludt'd

t> Unlimited Sorint!!> Mobile to included

Mobile (1 lint)

;'\essaging 1> MfWlgfs, Text. Picturfs and includedVideo 14 lines)

Data Yoo do not own a Data add'onOther • Sprint Premier inc~

I Plan charges $119.97

+ Taxes and fees See bill

Extra charges A/ Averai~additionaL uSllge and overage

charges for the past 12 months

See your usage trends

Data i8Skb S 12.72

Extra charges SH.n

Average total monthly bill 5132.69

~

Want to do more with your phone?

Clle<k out our Everything Data plans with My MObl1e, Mytime. Unlimite<:!

domestic call$ from the Sprint network to and from ANY U.S. mobile phone

reiClrdO?Ss of carriE"r. Plus get TV, music, email. and more!

See plans

Want to see your usaee history?

~e how you've been using your device- with detailed cost charts and usage

graphs including minutes, messaging and dat! trends.

View usage

Please note: This is intended to assIst you with making choices about our products and serVIces. We do not guarantee Its appl.icability 10

regards to individual circumstances . .All eYamples are for iU.ustrative purposes only. If you need additional assistance, p1.ease contact Spnnt

at 1·800·SPRINT·1 or visit other areas of our web site for detailed mformation on pl.ans and services.

Let us help you with your plan ';'''''''''''''','''J< .,:J Got quesliOns? ClICk to chat.

1m Oul RJghl Plan Promise

9 Send us your feedback

Your current plan Additional plan options

See this plan

Your plan is II good fit based on the way you'~'e been using your phone, but if you want to do more

with your phone, Check out our other ~n options.

Plans you mieht like

• EVl!'rythini Oata Family/Share 1500

""charies

5ee thk ran.

• 1SOO minutes to share across 4 lines

• Any /'Iobill!', Anytiml!': You're now free to call any mobill!',

anytime.

• A::lditionatminutes 40,/mln

• Unlimit~ J.',essai1ne: text, pictures &: video

• Unlimited Dlltll: Web, emai, TV E: music""chare~

Talk for Family/Share 700

• • 700 minutes to share across 41,mes

_ • A:lcMionalmlnutes 4Se/min

II

Everythinr Messaeing F"amilylShare 1500

Primary line:JESS: 936-499-7327

t> 3 Additionalti!!t'sl> Contract eng "!!tt

ToU< 1500 anyti!'lle' mlnutt's S 99.99

l> Adst!tionj!llln(' Ch\H!!eS IZlinul S 19.98

t> 'lights and wr:krnds starting m,~

lit 7pm f4 tlntsl

Do "'.obk to rnobk inctudedt> Unlimited Sprint/ll MObit to included

,lt9bitrl1linf:)Mess~iini t> "~UPgM' Trxt Picturfs.and incilJded

VldJ:O /4 tines)

Dllt" You do not own a Data add-onOther • Sprint Premier included

• Plan charges $119.97

+ TAXes dod f~ See bill

Extr" Chlll"ie5 /">../ Av('rage additional usage and overllg',hllri~ for It>@' pan 12 months

~ your usage trends

Catll 788 kb S 12.72

Extra charges 512.72

Average total monthly bill 513Z.69

Please note: ThIs is mtendea to assist you With makme choICes about our products and servIces. We do not euaranleoe ItS a¢lcab~lty 10

re&art1s to indIVidual cIrcumstances. Allexam~ are for illustrative purposes only. If you need addItional aSSIstance, please cOfltact Sprint

at 1·aoo-SPRI NT-1 or visit other areas of our ~b site for dt'tail~ informatiOfi on tians and services.

Plans you might like 5'"",00.".'''t1234

Back to Qven'lew

Your current plan

Ev~rythini l.\esweine FamilylShar@' 1500 Talk for Family/Shar~ 700

Primary line': ~ L.t ''"' "oj" '" hm' with t"'" 'oj,,-O«, ,h."dJESS: 936-499-7327 ' . :~ f plllns.

[> 3 AddJhonalltn£s.. lNrn more abou( thIs dan

.. . .What'sneow

t> Contract rnd date l> (O!!trtet en(l (jate Same

T"" 1500 anytime minutes S 99.99 700 3nytUTl(' minutes S M.99 X 800 fE'~r minut~

po Additional lint charm /2 S 19.98 t> ACdlt!onal\ine charge'S (211M'S! S 19.98

Iln<>Jl> NlgflH and wekrn<!s "'.... l>~ Incllld~

startln!! at 70m 14 h!!t's.! ~hghts&Weel<eflOs' 70m !4lmesl

l> WIe to rnobk included l> .....oMet9r:'lOb~ included

l> V!tlm1ted SDnnl«l,,\obK to includedJ,\obk 11 hoe)

~~ijni Do &a1us· Text PKtum lnc~d l> Messaging· Unlimited (2 ImeSI S 40.001!ad yfdfto 14 tinnl

po Messagmg' 1000 plmel S 10.00 X f~er messaiesDlIlta [> You do oot swm a Pala t> O"ta Pack 11 hnel S 15.00 ../ N!'W Feature

~

Ot~r • Sorint Premier lnctudt'd No Sprint Premier X You may lose

your Sprint

Premier benefits

• PltUl ch"'r"le!> S 119.97 • PIM ch"'r"le!> S 154.97

+ T<l.X~ aod fees See bill + Taxes and f~ See bill

Extra Ch"'r"l9S A/ Avt-raet- ad\litional usaee and overaep What's new You may save a few bucks on this Cl,an.

charees for the ~st 1Z months• CNngf to this pbIn...See your usage trends

Da.ta. 788 kb S 1Z.n

Extra chartes S 12.72Cnan~Jni your plan does NOT reQuire a contract extPIlSlon, a.ctivationf~s or penalties, that's our Right P\an Promise.

9J Got questions? Click lo chat.

ftD Quf Right Plan PrQ"lll3e

8 ~nd us your feedback

• Everything DataFamily/Share 1500

·1500minut~to shareacross 4 hn~

• Any Mobile, Anytime:You're now free to C/llI

My mobHe, anytime,

• .6ddition31 minutes 40c/min

• Uriimited Messaging: text,pictures & video

·UnlJmit~Data: Web, email,TVe music

• 5169.97 ~ncharies

see this pl~n

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Your current plan-

Everythinc Messaiin, Fami1y/Shar~ 1500 Talk for Family/Shar~ 700

Primary llne: ~ L" ,ou, "0'" '" h,,,, With th." "0;".....' ,h.",JES~ 936-499,7327

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l> Contract wl dBte l> Contract end date Same

T"" 1500 ..nyti~minute5 S 99.99 700 aflytime mmutl!'s S 69.99 X 800 feWf!r minutPS

[> AddihonailiDt charm f2 S 19.98 l> PiJditlona!\lne charges 21'nesl S 19.98

I!!I<1lt> NIghts !lnd wW<,!!'ndl. included l> Unlimltftd Includ~

starting at 70m 14 linn) Nlghts&Weeke-o(ls- 70m (411ne-.1

t> MohR to mobIC inc""" i> "".obite to noble inclUd~

l> Unlllmte<l Spnnt~ Mob!lr to lncluc!~

Mobie f1 botl

J,'~ssailni t> MemFN' ltd P!ctum Included l> N.esslIgll1l!· Unhml!N! I2llnesl S 40.00

and Vlqeo 14 boo)

l> Messaging· 1000 !111llt>1 S 10.00 .. f/!Wer meSsllilPS

O"t& l> )'00 do not own a DatA l> Data Pllck 11 Imel S15.00 .., New Feature-Other • Sprint Premier incluaed No Sprint Pr~mi~r " You mav loseyour Sprint

Premier benefits

• Plan char"i~ S 119.97 • Plan char"ie!> S 154.97

+ T<lxes <lnd f~ See bill • Taxes <lnd fees S&e bill

Extra chal'J~s ,r../ Av~rai~ llddltional USilli~ and ov~rai~ What's new You may sav~ a f~wbUcks on this .un.

chillr'i~S for th~ past 1Z months• C~n8e to this pliil!!..lSee your uS3ge trends

Data 788 kb S 1Z.72

Extra chafies S 12.72CtlillOi\ni your.un doe-s NOT require <l contract extenSH)fl, activatIon

fees or penalties, that's our R:i'iht P\a.n Promise.

~ Got quesllOllS? Click to chat.

ftD Our Right Pilln Promise

o Send us you~ feedback

• Everything DataFamity/Shore 1500

·1500 minut~ to !.hareacross 4lmes

·A.ny Mobile, Anytime:You'rt' now free to coJl1<lny mobile, illnytimt'.

• Additional minutes 40~ Imm

• Unlimiteo Messaiing: t~xt.

pictures & viceo

• Unlimited Dilltll: .....eb. ~a't,TV e: music

• 5169.97 Flan chllries

SH this plan.

(ornparf rtilns

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Your usage historyUse the charts below to see your usltie trends. You can s~ect the months that ~~t retied t~ WIt'J you use yourphone.

Note: We appreciate your patience! Yoor usage data may take up to 10 Mine55 days after your billlni cycle to

ap~ar. ~thovihwe've built this toot to find the best fit for you, in some cas~ • WIth Older or complex Plans· you

m"y see discrepancies. '.'Ie contln~ to improve this handy tool. If you ex~nence any Dr~ms, pease ~nd usyour (~dbac k.

Cost Talk

I Messaging I Data

!.!J 0J ~ ~ ~

I -'COO' An Anytime Nlghta & Mobil.

MnuQ.' I Web & o.taMI,..,t.. MlnutH W.."-nch "."IIIM

p;J Got QUCSlIOO!J Click to Chat.

1m OUr Right Plan Pronllle

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Phm ch,rllft $19.9! $19.9! S19.98 $19.98 $19.98 $195! $119.97 $109."! $109.98 $10U! $109.'18 $119.'n "'''CO (Stt..·.

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Your usage historyUse thE' cnarts be{.ow to see your usage trends. You can select the months that best fe-nett the way you use- yourphone.

tlote: We appreciate your patience! Your us.age data may take up to 10 business days after your billing cycle to

appear. ALthough we've bunt this tool to find the best fit for you, in some case:; • with older or complex plans· you

may see dis<repancies. We continue to improve this handy toot If you experience any problems, p,eas€' SEnd us

your feedback.

Cost I TalK r.lessaging I Data

~I .

cl.!:JI

-, ...... --' ,.........,I

t--- /~ I--J

Cost A' AnytIme Nights & Mobile MeaNS·s Web & OatsMlnutH Minutes Weekends Minutes

l..!I PH Lines

V JESS: 936·499·7327

V CHRI5TI "A/o\1 LES: 936·647·7455

u CHRI5TI"AMILES: 936·443·5063

U CHRI5TI"AMILES: 936·647·7454

tJ Got questions? Click to chat.

!D Our Right Plan Proollse

o Send us your feedback

AveraiE Usaa@

TOTAL 2#4

Anytime Minules

Nighu &W~kEnds •

M.obilE MinulEs •

147

t9B1

'"

Nights a WeeKendS

Mobile Minutes

Anytime Minutes

Your usage historyUse the<:h21rts below to SeE' your usage tr~nds. You can select the months that best refle'(;t thE' way you use your

phone.

Note: We apprecIate your patience! Your usage data may take up to 10 business days after your billing cycle to

appear. Although we've buUt this tool. to find the best fit for you, in some cases· with older or complex ~ns - youmay see discrepancies. \'Ie continUE" to improve this handy tool. If you experience any problems, ple-ase send us

your feedback.

~ Got questions? Click [0 c.hat.

o OUf Right Plan Promise

() Send us yOUf feedback

Cost Talk Messaging Data

, ..U, ..oj ~ ~, ~, .---, .....,.,Cos. All Anyti_ NIghl8 & Mobile

Minutes M1...... Weekends MinutesMessages Web & Data~.-.........-".- - - .>t'__"_' oR..-

-!V P4 Lines

v JESS: 936·499·7327

v CHRIs-'INAMILES: 936-647-7455

V CHRISTINA MILES: 936-443-5063

U CHRI5TI~IA"'ILE5: '936·647-7454

1..louse over a dot to see more details

"00 <~,,'~I

1200

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Usoit!: AVt!rogt!

Minut., u,.d '05 213 '" 178 " 210 22.. '" " " " :as '47

Additionl COlt $0.00 $V.oo !;o.oo !O.OO $0.00 $0.00 ~{l.OO 50.00 5-0.00 $0.00 50.00 $0.00 5-0.00

Your usage historyUSE' the <:harts bt!ow to~ your usajE' trends. You can s!l.e<t t~ months that ~st fl!'flt'Ct the way you USE' yourphone.

Note: We appr~late your patienCe! Yoof usae;e ol'ota may take UP to 10 business days after your biUina cycle to

appei!lT. ;Ilthouah we've bvtt this tool to find the ~st fIt for you, in somt' casE'S' with older or complex plans· youmay See' "istrepanties. We continue to improvE' this handy toot. If you experience any proNems, p1.ea~ sefid U1your ffflback.

~ Got qurostions? Cl1c.k to chat.

1m Our Rrght Plan P'Ol1'u&e

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Cost

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Plan OptimizerSorry!Hey, we're sorry. we can't analyze your plan. we'd love to walk you thrOUih your plan options. Pl~ase chat With us (by cLickine the' icon In t~ upper riaht·hand corner of the paae) or Ci!I!lus at -2. Note: Chat is only avaitable durine c!rta1n hours of goeratlO!!.

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.,u.n. If you fett, yOU'rt~mi this I'fltH"it 'n nror, ::e"~ chn WIth lIS (Ily clicklnl tlot Icon on tlot~rrllt!t·h.nd Sidt of tilt P"itl or ca:! \/S "t '2. f'lott; Chat IS Of'iy .y.utlt ':UIlnl ctrUln Nu' I o·gptrfllOf'l.

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~Want to see your usa,e history?

Set how you'''t bttfI usin, your dtVlct WIth c:tt>lliWd cost ch.rts and \lUlItir>llph~ inc!ul:ini minuus, llltSS"iini "nd data trend~.

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Unlock your plan's potential

iV. •...'etl, Clrf'Ction~, monIC~ I'IOrt· "rt· yO\l \/Sinlalol the ltilt\lln onclu<:ltdIn your con! Chtck O\It"" th.t our strviUI c.n 00 for you•

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comments of sprint nextel corporationbefore the federal communications commission washington, d.c....

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