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Commission Document Attachment




Policies Regarding Mobile Spectrum Holdings, WT Docket No. 12-269
There is no question that it is time for the Commission to update its policies on measuring how
spectrum aggregation impacts competition in the wireless industry. Our last comprehensive review of
these policies occurred in 2003, and since then, we have seen a number of developments in mobile
wireless services. The two most significant are the dramatic increase in demand for wireless services
especially mobile broadband, and the reduction in the number of carriers, providing competitive mobile
service options for consumers. It is also worth noting that, in the spectrum provisions of the Act passed
earlier this year, Congress reaffirmed the Commission’s authority to, and I quote: “adopt rules of general
applicability, including rules concerning spectrum aggregation that promote competition.”
Under Chairman Genachowski’s leadership, the Commission staff has been working diligently to
improve our understanding about how all relevant aspects of the wireless market impact competitive
options for consumers. We have substantially improved our analysis of the market structure in the annual
mobile wireless reports. We have also adopted a number of important rules or proposed policies in the
areas of universal service reform, tower siting, data roaming, spectrum sharing, wireless backhaul, and of
course, the allocation of more spectrum, for commercial mobile services, to ensure the Commission is
doing what it can to promote rapid deployment of more wireless broadband networks.
To ensure the mobile wireless ecosystem continues to offer consumers the highest quality
services at affordable prices, we must also review our spectrum aggregation policies to facilitate access,
by all providers, to valuable spectrum resources. Therefore, the NPRM properly identifies several
relevant factors, the Commission should consider, in properly reviewing and revising these policies. I
particularly appreciate the analysis and discussion about how the Commission should evaluate different
technical characteristics of the spectrum bands allocated for commercial wireless service. This is relevant
to whether spectrum below 1 GHz should be valued as highly as spectrum above 1 GHz. It is also
important in determining which currently allocated bands should be included in any spectrum screen we
may use in the future. As we learned from the lack of interoperability in the lower 700 MHz band, just
because the Commission auctions a spectrum band, does not necessarily mean it becomes immediately
available and suitable to offer services to the public.
It is important that we review these policies, in a timely fashion, and take into account any
considerations that could also help us design our voluntary incentive auctions. I thank Ruth Milkman,
Jim Schlichting, Nese Guendelsberger, and Maria Kirby for their detailed briefing. I also wish to
commend Christina Clearwater, and Monica DeLong, along with the other staff members who worked
hard to produce an excellent item.

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