There have been several comments that criticize auction rules that prevent the two major low-frequency incumbents from winning all of the newly available spectrum and incorporating it into their proprietary networks. Such rules include new-entrant set-asides, new-entrant bidding credits, and the...

We comment on the service and auction rules discussed in the Report and Order and Further Notice of Proposed Rule Making, FCC 07-72, 27 April 2007. We recommend that the FCC designate one license for a wholesale operation that provides open access nationwide on nondiscriminatory terms. This is...