As the 700 MHz auction approaches, we are writing to clear up a common misconception about the nature of spectrum auctions and the impact of various rules on auction revenues.

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...