May 31, 2011
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554
Dear Members of the Commission:
In less than a lifetime, wireless communication has become deeply ingrained in the Latino community as it has expanded across America and the world. Our communities have come to depend upon this transformative technology to connect with their families, access medical services, continue their education, engage civically, and launch small businesses among other life enhancing capabilities. We write to you about AT&T's proposed acquisition of T-Mobile (Proceeding Number 11-65) to offer our initial perspective as the leading national voices for diverse Latino communities following an independent analysis of the information available regarding the impact of this transaction. The national organizations communicate our support for what we believe to be potential benefits of the proposed transaction including expanded access to faster, more reliable wireless broadband networks; additional domestic investment; increased diversity in the telecommunications sector and the opportunity for T-Mobile workers to unionize - as well as areas that we would like the FCC to further review. We look forward to participating in the Commission's review process to ensure that the interests of Latino consumers and businesses are represented during the Commission's deliberations.
The National Hispanic-serving organizations (national organizations) signed herein have been engaged with AT&T for many years, advocating for practices and policies across the telecommunications industry that would result in enhanced services that expand access and affordability for all Latino communities - particularly the most economically vulnerable communities who are also most likely to find themselves on the wrong side of the digital divide. This advocacy has resulted in a continuing evolution of the ways in which the industry serves Latino consumers -- with AT&T serving as an exemplar in the areas of supplier diversity, diverse hiring and retention, and in establishing beneficial partnerships with community-serving organizations. In this, we have considered AT&T a valued community partner.
Since the announcement of this proposed merger, the national organizations have examined how AT&T's acquisition of T-Mobile will impact Latino communities. We have highlighted the following areas as priorities for the Latino community in this transaction:
1) Access and Digital Literacy -- Latino digital adoption and digital literacy must be a focus of community investment efforts flowing from the merger as unserved and underserved communities gain access to high speed wireless broadband networks. We understand that AT&T plans to pursue a robust adoption program that includes outreach, affordable broadband services, and training to help close the digital divide. We urge the FCC to consider the impact that this program can have on Latino adoption and digital literacy rates which still lag far behind the national average, especially for Spanish-speaking families. This acquisition in particular could be a catalyst for opening up high speed wireless broadband networks to underserved communities.
2) Price Education and Affordability - The national organizations urge the FCC to closely examine how the merger will impact pricing and competition in the wireless industry. Mobile services including voice, mobile broadband and related services, should continue to be more available and to fall in price as they have historically. Educating and empowering price-sensitive Latino consumers - so that they are in charge, empowered and in control of their monthly mobile bill are of key importance -especially to those least likely to use the tools available to avoid bill surprise. We also want AT&T to provide culturally sensitive and linguistically inclusive materials to the Latino community as they communicate the immediate and long-term impact of this acquisition. Existing T-Mobile customers should not see an increase in their monthly bills as a result of the proposal.
3) Latino Business Opportunities - If, in the process of the DOJ and FCC's analysis, AT&T is required to divest properties or business units, it is imperative that Latino-owned businesses have an opportunity to fully participate in the divestiture process and compete successfully for those opportunities. We therefore encourage the FCC to strongly support, or to mandate if possible, participation of Latino-owned businesses in any bidding process by hosting workshops in order to educate parties interested in acquiring such assets or licenses on the application process, necessary qualifications, financial obligations and sources of financing and other relevant information. We commit to working with ATT to identify additional partners in expanding its renowned commitment to supplier diversity.
4) Job Consolidation - The national organizations expect the proposed acquisition will increase overall employment by the combined companies as AT&T invests heavily in its promised 4G network. However, it is of the utmost importance that the merged companies identify an approach to mitigating potential job loss-particularly for lower-end retail workers and managers in storefront locations so that any losses will be accompanied by appropriate reemployment support services. We hope that the FCC, if it pursues any conditions on this deal, will work to ensure that the most vulnerable of workers are not harmed by this transaction and that customer service to our community is not disproportionately compromised by consolidations or store closures.
Having expressed the community's interests in these areas, as the Commission conducts its review of this transaction, we respectfully request that the Commission give special attention to the following issues that we believe will most affect and benefit Latinos throughout the country, including Puerto Rico.
In the national organizations' review, we have identified certain potential benefits of the proposed merger that serve the public interest:
Adoption and Digital Literacy. AT&T's historic commitment to educating communities, including under-served communities, is evident in its extensive partnerships. Post acquisition, AT&T has committed to increasing broadband adoption among Latinos consistent with its historic commitments.
Pricing & Deployment. Increased affordability and quality of service have been crucial in spurring adoption among the Latino community throughout the mainland and Puerto Rico. Latinos have adopted wireless because it is often a less expensive, more convenient and accessible option. Even as the wireless industry has restructured during the past decade, there have been significant price declines in phone calls, texting and mobile data as more Americans adopt the technology. Hispanic Americans rank among the nation's leading users of mobile phones, texting, and the wireless Internet because of this fact.
The resulting deployment of high-speed wireless Internet through this transaction, to areas of America currently unserved or underserved is an important opportunity for Latino communities. Recent Census data shows that Latinos are more dispersed among rural communities than ever. These communities also tend to be more mobile and less likely to adopt home wire line broadband. Latinos need more access to evolving technology, at an affordable price. The future of technology is more mobile, and more personal. Online health, mobile health, telemedicine and eLearning will become more widely adopted as networks become faster and increase capabilities. This merger will give T-Mobile customers access to LTE technology-something that T-Mobile currently will not or cannot deploy on its own.
Supplier Diversity and Corporate Responsibility. As a leader in supplier diversity, AT&T has spent more than $50 billion with minority, women, and disabled business veterans. By 2009, over fourteen percent of its total vendor procurement was dedicated to diversity suppliers. Post merger, we look forward to the growth and expansion of AT&T's supplier diversity program to the combined company in the future. Supplier diversity is a key vehicle of corporate support for advancing economic opportunities for small businesses in the Latino community and we will work with AT&T to ensure this important trend continues.
Benefits to Latino Small Businesses. Broadband is an economic engine. More and more business owners are turning to wireless broadband to help keep costs down, explore the ability to have employee's telework, and utilize new business solutions. Expanding high-speed wireless access through this merger will benefit Latino entrepreneurs and small businesses, from both the mainland and Puerto Rico, helping them to grow their business while not tying them to a particular location. Improved wireless access will help those in home-based businesses, especially in areas where wired broadband is either unavailable or where bandwidth is not fully robust. Small and medium-sized businesses rely heavily on the mobility, speed, and the ability to connect to their clients and customers anywhere at any time. AT&T has further committed to pursue a partnership program to develop and mentor diverse suppliers to bid on divested properties in the telecom sector at large.
Benefits to Latino workers. Many of the teams deploying the next generation of wireless systems rely on Hispanic workers. The proposed additional $8 billion investment by AT&T for wireless deployment will mean more jobs for these workers through an investment that would not have otherwise occurred. With the support of labor unions, the merger promises to increase what is already the biggest organized full-time work force of any broadband provider in the country. This is tremendously beneficial for Hispanic workers.
In conclusion, we look forward to working with the Commission throughout this process to ensure that the Hispanic community's voice is heard and its needs considered in full. As community leaders, we have been advocating for more and faster access, adoption and affordability so that the people we serve will be in a better position to take advantage of the evolving digital economy. As such, we believe this merger could provide opportunities to achieve many of these objectives by bringing the possibility of faster, smarter wireless networks to more Hispanics, further shrinking the digital divide, and bringing more Latinos in more places a critical tool to achieve the American Dream. We look forward to providing the commission the benefit of further comment as we continue to study the impacts of this merger on the Latino community.
Ronald Blackburn Moreno
President and CEO
ASPIRA Association, Inc.
President and CEO
CNC - Formerly Cuban American National Council
The Hispanic Federation
Labor Council for Latin American Advancement
League of United Latin American Citizens
Alma Morales Riojas
MANA- A Latina National Organization
National Conference of Puerto Rican Women
Dr. Yanira Cruz
National Hispanic Council on Aging
President and CEO
Dr. Elena Rios
President and CEO
National Hispanic Medical Association
National Puerto Rican Coalition
President and CEO
Ser Jobs for Progress National, Inc.
President and CEO
US Hispanic Chamber of Commerce
Dr. Juan Andrade
United States Hispanic Leadership Institute
President & CEO
United States - Mexico Chamber of Commerce