In comments that respond to an FCC rulemaking request filed by the Rural Telecommunications Group (RTG), rural and regional wireless carriers clashed with national wireless giants Verizon Wireless and AT&T on RTG’s proposal to revive wireless spectrum caps that were eliminated seven years ago by the FCC. Recommending a 110 MHz per county limit on wireless spectrum controlled by any one entity in channels below the 2.3 GHz band, RTG cited the trend toward market consolidation that has resulted in more than a dozen wireless carrier mergers or acquisitions since 2001—the year in which wireless spectrum caps were dropped. Although the FCC has since used a flexible spectrum “screen” (ranging from 95 MHz to 145 MHz per market) that triggers a more detailed review of transactions that leave the merged entity in control of excessive amounts of spectrum, United States Cellular Corp. joined RTG in calling for spectrum caps, claiming that the spectrum screen used by the FCC has failed to prevent “massive industry consolidation.” Arguing that “excessive concentration of licenses contradicts the Commission’s stated goal and Congressional mandate of avoiding such concentration,” the National Telecommunications Cooperative Association also voiced support for the RTG proposal, declaring: “a cap on the amount of spectrum [a] carrier can hold will promote competition and further diversity.” Verizon Wireless, however, argued that that RTG “fails to provide any basis for the Commission . . . to consider reimposing the same blunt and unwarranted economic restraint on the commercial mobile radio services market that the Commission properly repealed,” as it pointed to the results of an economic study warning that reimposition of spectrum caps “can harm competition and consumers by increasing the costs of expansion for a service provider that has developed a successful business model that requires additional spectrum to meet consumer demand.” Noting that annual reports issued by the FCC have described the U.S. wireless sector as competitive, AT&T added that RTG’s proposal “would impair competition and threaten efficiency-producing marketplace behavior.”