Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Connect America Fund
A National Broadband Plan for Our Future
Establishing Just and Reasonable Rates for
Local Exchange Carriers
High-Cost Universal Service Support
Developing an Unified Intercarrier
Federal-State Joint Board on Universal Service
Lifeline and Link-Up
Universal Service Reform – Mobility Fund
WC Docket No. 10-90
GN Docket No. 09-51
WC Docket No. 07-135
WC Docket No. 05-337
CC Docket No. 01-92
CC Docket No. 96-45
WC Docket No. 03-109
WT Docket No. 10-208
PCIA—THE WIRELESS INFRASTRUCTURE ASSOCIATION
PCIA—The Wireless Infrastructure Association (“PCIA”) hereby submits these
comments in response to the above captioned Federal Communications Commission (“FCC” or
“Commission”) Report and Order and Further Notice of Proposed Rulemaking regarding
Universal Service Fund (“USF” or “Fund”) and intercarrier compensation reform.1 Consistent
1 In re Connect America Fund; A National Broadband Plan for Our Future; Establishing Just and Reasonable Rates
for Local Exchange Carriers; High-Cost Universal Service Support; Developing an Unified Intercarrier
Compensation Regime; Federal-State Joint Board on Universal Service; Lifeline and Link-Up; Universal Service
Reform – Mobility Fund; WC Docket No. 10-90, GN Docket No. 09-51, WC Docket No. 07-135, WC Docket No.
05-337; CC Docket No. 01-92, CC Docket No. 96-45, WC Docket No. 03-109; WT Docket No. 10-208 Report and
Order and Further Notice of Proposed Rulemaking, FCC 11-161 (rel. Nov. 18, 2011) (“R&O and FNPRM”).
with the public interest obligations for Phase I of the Mobility Fund, the Commission should
continue to encourage the efficient use of wireless support structures.2 Efficiencies are achieved
when wireless providers share the underlying physical support structure for wireless antennas.
Recognizing the array of regulatory restrictions imposed on wireless infrastructure, the
Commission should require that Mobility Fund Phase II support recipients allow for reasonable
collocation by other service providers on newly-constructed, Phase II-funded wireless support
structures. However, the Commission should not impose additional, specific collocation
practices, including a set number of collocation spaces.
II. PUBLIC INTEREST OBLIGATIONS FOR PHASE II MOBILITY FUND
SUPPORT SHOULD ENCOURAGE THE EFFICIENT USE OF WIRELESS SUPPORT
In its Report and Order, the Commission acknowledged the benefits of advanced mobile
services and their role in delivering consistent, high-speed broadband access across the country
by establishing Phase I and Phase II of the Mobility Fund.3 As part of Phase I, which is designed
to support to spur the deployment of mobile voice and broadband networks to unserved areas, the
Commission adopted several public interest obligations on support recipients, including
“allow[ing] for reasonable collocation by other providers of services . . . on newly constructed
towers that Mobility Fund recipients own or manage in the unserved area for which they receive
support.”4 Just as the Phase I collocation requirement will reduce the cost of deployment, speed
build out and spur competitive entry into the market, so too will such a requirement impact
beneficially Phase II’s ongoing support.
2 The phrase “wireless support structures” as used herein refers to all types of towers and other support structures
constructed for the purpose of supporting antennas and other equipment for the provision of wireless services.
3 See R&O and FNPRM at ¶¶301-478, 493-497.
4 Id. at ¶376.
Efficiencies are achieved when wireless providers share the underlying physical support
structure for wireless facilities, and ultimately collocation promotes the Commission’s goals for
improving coverage and competition across the country.5 The Commission recognized as much
in its 15th Mobile Wireless Competition Report when it found that “the ability of wireless
service providers to lease space for new cell sites on established towers can ease and speed their
entry into new geographic areas by eliminating the need to build a new tower.”6 Though the
costs associated with deploying infrastructure can vary dramatically based upon individual
factors such as the cost of land, local zoning processes, and the design of the structure to be built,
PCIA members estimate that an average new build costs approximately $250,000 to $300,000
whereas an average collocation costs $25,000 to$30,000 to deploy.7 The cost advantage of
collocation is essential in reducing capital expenditures, thereby facilitating deployments
necessary to increase a provider’s coverage and capacity. This is particularly true for deployment
in high-cost areas.
Furthermore, the Commission should allot the same flexibility for a Phase II collocation
public interest obligation as it did for Phase I. In applying the collocation public interest
requirement to Phase I, the Commission aptly recognized that mandating specific terms,
conditions, or collocation spaces per structure “may unduly complicate efforts to expand
coverage.”8 Wireless infrastructure siting decisions are a complex interplay between the
technical and engineering requirements of the provider, and the state, local, and federal
regulations governing wireless infrastructure siting. In fact, the Commission noted that
5 Comments of PCIA – The Wireless Infrastructure Association, WC Docket No. 10-90, GN Docket No. 09-51, WC
Docket No. 07-135, WE Docket No. 05-337; CC Docket No. 01-92, CC Docket No. 96-45, WC Docket No. 03-109,
at 3 (filed April 18, 2011).
6 See In re Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, WT Docket No.
10-133, Fifteenth Report, FCC 11-103, ¶ 317 (rel. June 27, 2011) (“Fifteenth Competition Report”).
7 Id. at ¶312.
8 R&O and FNPRM at ¶376.
“obtaining the necessary regulatory and zoning approvals from state and local authorities” is a
“significant constraint” to wireless infrastructure deployment.9 Requiring Phase II recipients
only “to construct towers where reasonable in a manner that will accommodate collocations,” the
new Mobility Fund will capitalize on the benefits of collocation while allowing service and
infrastructure providers to address the myriad, unique factors they must consider when siting and
building new support structures.
As described herein, to maximize competition, flexibility, and efficiencies, the
Commission should require that recipients of Mobility Fund Phase II support allow for
reasonable collocation by other service providers on newly-constructed, Phase II-funded wireless
PCIA – THE WIRELESS
Michael T. N. Fitch
President and CEO
Director, Government Affairs
D. Zachary Champ
Government Affairs Counsel
Kara Leibin Azocar
901 N. Washington Street, Suite 600
Alexandria, VA 22314
January 18, 2012
9 Fifteenth Competition Report at ¶ 311.