Verizon also sought to assure the Commission that it would not use Alltel’s dominance in the rural markets as a weapon against its competitors. As the largest rural provider, CDMA operators from Sprint to the smallest regional carrier depend on Alltel for roaming outside of their core territories. Alltel even runs some GSM networks for roaming agreement purposes. “Upon closing of the transaction, Verizon Wireless will honor all of the terms of those CDMA and GSM roaming agreements, thereby ensuring that other carriers’ customers will continue to enjoy roaming services,” Scott’s later stated. The letter said Verizon would honor all current roaming agreements with regional, small and rural operators, and if those carriers have roaming agreements with both Verizon and Alltel, the operator has the option to choose the most beneficial contract. On the subject of operators that don’t happen to be regional, small or rural (i.e. Sprint, AT&T and T-Mobile) the letter said nothing.

Verizon is hoping for a quick turn around on the acquisition approval, ideally in the 4^th quarter before the change in administrations and Congress. The deal would primarily fill in holes in Verizon’s footprint, reducing its focus on population centers and metro regions and allowing it to provide nationwide service on its own network. The deal would also sizably increase VZW’s customer base. Assuming the DOJ requires no additional divestitures, Alltel would add 11 millions subscribers to Verizon’s roles. Rural Cellular would add another 800,000. If both deals closed today, Verizon would have more than 80 million subscribers, compared to AT&T’s 73 million.