700 MHz Spectrum Auction Documents

The complete filing is available in PDF Format.

In the Matter of

Applications of Cellco Partnership d/b/a Verizon Wireless and Atlantis Holdings LLC

For Consent to Transfer Control of Licenses, Authorizations, and Spectrum Manager and De Facto Transfer Leasing Arrangements

WT Docket No. 08-95
File Nos. 0003463892, et al., ITC-T/C-20080613-00270, et al.

The Ad Hoc Public Interest Spectrum Coalition (PISC) respectfully submits this Petition to Dismiss or Deny the above-captioned applications. The applicants have failed to meet their burden of demonstrating how the applications, as filed, serve the public interest.

With the conclusion of Auction 73, the Public Interest Spectrum Coalition (PISC) write to ask that the Commission not move immediately to reauction the D Block. Rather, as consistent with public statements made by several members of Congress and Commissioner Adelstein, PISC requests that the Commission sever the D Block from auction 73, reveal the results of the auction, and conduct a thorough investigation into why the D Block failed to attract bidders. After conducting the investigation, the Commission should place any proposed changes or remedies, including a decision to award the D Block to the current bidder, on public notice.

This letter is also available in PDF Format.

The full filing is available in PDF format.

In the matter of:

Service Rules for the 698-746, 747-762, and 777-792 MHz Bands:
WT Docket No. 06-150

Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band:
PS Docket No. 06-229

Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures:
WT Docket No. 05-211

Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010:
WT Docket No. 96-86

SUMMARY

The Ad Hoc Public Interest Spectrum Coalition (PISC) applauds the Commission for including issues raised by PISC in the initial comment period.

The United States continues to fall further behind the rest of the world in broadband Internet access — our markets lack the competition necessary to serve consumers with lower prices, faster speeds and universal access. Even as the broadband market has further consolidated — leaving 96% of the market in the hands of two technologies — our policy framework has only served to diminish opportunities for competition. The auction of the 700 MHz spectrum creates a new possibility for competitive broadband provision. It is imperative that we learn the lessons of the wireline market and make the appropriate policy corrections in the launch of the most promising wireless broadband markets.

The Commission simply cannot choose to let current market conditions and participants control the outcome of the upcoming auctions. To date, existing wireless broadband providers do not offer a useful “third pipe” for American consumers. Perhaps most importantly, this market for broadband capable mobile devices is dominated by the same incumbent firms that control the wireline broadband market. These incumbents make clear that they have no intention of offering broadband with the freedom to attach any device and run any application.

To foster real wireless broadband — the fast, ubiquitous, and dynamic third pipe everyone agrees our country desperately needs — PISC recommends that the Commission take the following steps both to ensure that new spectrum is offered on an open and nondiscriminatory basis and to bring in new entrants interested in challenging the current cozy wireless oligopoly and broadband duopoly:

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

• Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)

• Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)

• Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)

• Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission:

Consumer Federation of America, Consumers Union, Free Press, Media Access Project, New America Foundation and Public Knowledge (collectively referred to here as the “Public Interest Spectrum Coalition” or “PISC”), file these ex parte comments urging the Federal Communications Commission (“FCC” or “Commission”) to condition the award of licenses for at least half of the 700 MHz band on the licensees’ compliance with open access principles. The auction of licenses in the 700 MHz band is a unique and critical opportunity to bring broadband to American consumers and open an avenue for competitive broadband providers. It is without question the best opportunity to open a legitimate “third pipe” for consumer broadband connectivity—long a goal of the Commission. Given the state of the market failure in US broadband and our unenviable position relative to international performance in broadband connections, a pro-competitive policy in the 700 MHz auction is imperative. The undersigned public interest groups urge the FCC to adopt our recommendations in order to maximize the opportunities for new, competitive entrants and promote greater broadband access in the United States. We recommend that the FCC require that a portion of the auctioned licenses be subject to a service condition of open access. This will create a competitive retail market for wireless broadband services in a national marketplace. It will bring innovative, competitive providers into the market that would otherwise never appear.

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

• Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)

• Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)

• Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)

• Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission:

Consumer Federation of America, Consumers Union, Free Press, Media Access Project, New America Foundation and Public Knowledge (collectively referred to here as the “Public Interest Spectrum Coalition” or “PISC”), file these ex parte comments urging the Federal Communications Commission (“FCC” or “Commission”) to condition the award of licenses for the 700 MHz band on the licensees’ compliance with a service rule that requires 700 MHz license holders to provide broadband Internet access service on a non-discriminatory basis in a manner that enables consumers to attach any compatible device and to reach any web site, post any information, provide any service, access or provide any application, without degradation, prioritization or interference by the network operator.

The complete filing is available in PDF Format

FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

• Service Rules for the 698-746, 747-762, and 777-792 MHZ Bands (WT Docket No. 06-150.)

• Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHZ Band (PS Docket No. 06-229.)

• Implementation of the Commercial Spectrum Enhancement Act and Modernization of the Commission’s Competitive Bidding Rules and Procedures (WT Docket No. 05-211.)

• Development of Operational, Technical, and Spectrum Requirements for Meeting Federal, State and Local Public Safety Communications Requirements Through 2010 (WT Docket No. 96-86.)

To: The Commission

Media Access Project, on behalf of Consumers Union, Consumer Federation of America, Free Press, New America Foundation and Public Knowledge (collectively referred to here as the “Public Interest Spectrum Coalition” or “PISC”), files these ex parte comments addressing the proposal submitted by Frontline, the proposed Band Optimization Plan, and auction and service rules needed to ensure that this auction of unique and highly valuable spectrum will maximize the likelihood of competitive entry in broadband wireless that protects public safety, increases opportunities for minority and women owned businesses, and promotes broadband access by all Americans.

This letter is also available in PDF format.

March 2, 2007

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

RE: Docket WT 07-16

Dear Ms. Dortch:

We are writing to express qualified support for the application of M2Z Networks, Inc. for license and authority to operate a broadband wireless service in the 2155-2175 MHz band.