on Competition’s Effect Just and Reasonable Rates. Market Concentration Verified Greenlining argued that the The Commission conducted a of study of the broader Commission’s evaluation the state of competition should telecommunications market as include a robust examination of well as relevant submarkets. market concentration, While the Final Decision did including specific study of not make specific findings disparate competitive impacts regarding market concentration on communities of color. in communities of color, it Goodman 3/15/2016 found that the largest markets Testimony at p. 4; Opening for fixed and mobile voice Brief at p. 8. Greenlining were highly concentrated, further noted that many (D.16-12-025 at pp. 71, 74) households from communities and that the largest markets for of color are intermodal voice service were “wireless-only” households and that many moderately concentrated households from communities (D.16-12-025 at p. 78). of color cannot afford both Additionally, the Final wireline and wireless service. Decision noted that rural (Goodman 06/01/2016 communities likely face higher Testimony at pp. 3, 8-9). levels of concentration than their urban counterparts. (Final Decision at pp. 56-57). These findings, while not specific to communities of color, so provide some insight into the state of competition for communities of color. Greenlining The Final Decision did not rely opposed carriers’ arguments that a competitive on an evaluation of the number market is characterized by a of service offerings in a variety of service offerings, market, instead relying on rather than competitors. other indicators such as the Opening Brief at p. 7; Reply HHI, as discussed above. See Brief at p. 5. Final Decision at pp. 54-56.
Competition’s Effect on Just and Reasonable Rates. Market Concentration Greenlining argued that the Commission’s evaluation of the state of competition should include a robust examination of market concentration, including specific study of disparate competitive impacts on communities of color. Goodman 3/15/2016 Testimony at p. 4; Opening Brief at p. 8. Greenlining further noted that many households from communities of color are “wireless-only” households and that many households from communities of color cannot afford both wireline and wireless service. (Goodman 06/01/2016 Testimony at pp. 3, 8-9). The Commission conducted a study of the broader telecommunications market as well as relevant submarkets. While the Final Decision did not make specific findings regarding market concentration in communities of color, it found that the largest markets for fixed and mobile voice were highly concentrated, (D.16-12-025 at pp. 71, 74) and that the largest markets for intermodal voice service were moderately concentrated (D.16-12-025 at p. 78). Additionally, the Final Decision noted that rural communities likely face higher levels of concentration than their urban counterparts. (Final Decision at pp. 56-57). These findings, while not specific to communities of color, so provide some insight into the state of competition for communities of color. Verified Greenlining opposed carriers’ arguments that a competitive market is characterized by a variety of service offerings, rather than competitors. Opening Brief at p. 7; Reply Brief at p. 5. The Final Decision did not rely on an evaluation of the number of service offerings in a market, instead relying on other indicators such as the HHI, as discussed above. See Final Decision at pp. 54-56.
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