Although competition in the U.S. wireless market is strong, industry players told the FCC that further steps should be taken to facilitate competition, such as the development of non-discriminatory systems for universal service and intercarrier compensation, the promotion of automatic roaming, and providing rural and small carriers with greater access to spectrum. A variety of wireless concerns submitted comments in response to an FCC public notice, issued last month, that seeks industry input on the agency’s 12th annual report to Congress on the state of competition in the commercial mobile radio service market. Describing the current competitive environment as “fierce,” wireless association CTIA offered statistical data showing (1) the presence of 150 facilities-based wireless providers in the U.S., (2) a 75% wireless penetration rate in urban areas, and (3) a rural service penetration rate of 68%. CTIA, however, pointed to the need for reform of the universal service and intercarrier compensation systems, as it urged the FCC to work toward the development of regimes that are nondiscriminatory. Along that same vein, Sprint Nextel complained that the assessment of excessive special access fees by the Bell companies “harms consumers by needlessly increasing the cost of providing wireless services,” adding: “this exercise of market power also retards intermodal competition.” Commenting on consolidation in the wireless sector, MetroPCS asserted: “the most dramatic effect of consolidation . . . has been in the ability of the large national carriers to exercise market power in the roaming market.” To that end, MetroPCS called for the adoption of rules that mandate automatic roaming, noting: “the Commission’s report . . . would be incomplete without considering the harm to competition being caused by the refusal of certain carriers, particularly certain national carriers, to provide automatic roaming services on reasonable terms and conditions.”