TO: Erin McGrath, Mobility Division, Wireless Telecommunications Bureau
Susan Singer, Spectrum Competition and Policy Division, Wireless Telecommunications Bureau
CC: Chairman Kevin J. Martin:
Commissioner Michael J. Copps:
Commissioner Jonathan S. Adelstein:
Commissioner Deborah Taylor Tate:
Commissioner Robert McDowell:
FROM: Mark Landiak, Executive Director, Wireless Business Owners Consortium (WiBOC.org)
RE: Verizon Wireless and ALLTEL – WTB Docket No. 08-95
Our association, the Wireless Business Owners Consortium (WiBOC) represents independent wireless resellers across America. There are well over 12,000 small businesses engaged in the sale of cellular service, equipment and accessories. The purpose of this communication is to make you aware of several concerns about how the pending acquisition of Alltel by Verizon Wireless will negatively impact up to 2500 individual store locations.Alltel is the nations 5th largest carrier of wireless communications services. Approximately 50% of Alltel’s business is transacted by independent wireless resellers, many of whom are members of our trade association. It is the desire of WiBOC to voice specific concerns that may have a negative impact on independent wireless resellers. We are communicating these concerns to you on their behalf so that consideration will be made to address these issues in connection with the approval of this pending acquisition.
Once the transaction with Alltel is completed, Verizon will be able to indiscriminately close down independent Alltel resellers who provide a valuable competitive option in their community and have invested considerable time, energy and money in the growth of their small business. There is currently no protection provision to prevent this from occurring.
Businesses impacted by these closings have in many cases been in their communities for many years and provide an important option to consumers. Elimination of these locations will decrease the number of competitive options available to the consumers especially in the rural areas that Alltel predominantly serves.
There is precedent for this type of outcome, as this was the scenario that occurred when AT&T Wireless acquired Cingular Wireless, when AT&T Wireless acquired Dobson Communications and when Sprint acquired Nextel. This practice led to the demise of hundreds of small businesses
whose contracts were simply cancelled, not renewed, or when unreasonable sales quotas were placed upon the business.
Many of the small businesses have long-term leases and other debt obligations paid through the sales of Alltel products. Often the owners have personal guarantees on the loans and leases. This will put the small business owner in jeopardy of incurring significant losses if Verizon cancels the business relationship.
WiBOC’s fear is that this acquisition will negatively impact thousands of independent business owners and many more thousands of employees and their families – many of which are in rural communities which Alltel predominantly serves. Independent Alltel dealers should be afforded the opportunity to continue to operate their business under the new merged entity’s dealer program.
On behalf of the 2,500+ Alltel dealer locations that will be impacted by this pending transaction, we are asking, as a condition of deal approval, for consideration in protecting the consumer options available in these communities as well as the assets of small businesses that were built on good faith, hard work and considerable personal risk.
We would like to schedule a conference call with you and some of the business owners who will be affected by this transaction. I will be calling to determine a convenient time for such a call. As time is of the essence in this matter, we hope to find a time within the next 10 days to further address our association’s concerns.
We greatly appreciate your time and consideration to this important issue.
Sincerely,
Mark Landiak, Executive Director
The Wireless Business Owners Consortium (WiBOC)
About WiBOC 
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