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
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: