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Incentive Auctions NPRM
I will start by thanking the incentive auction team for their thoughtful and diligent work on what
is perhaps the Commission’s most difficult undertaking since I took office. I am excited that our agency
is on the cutting edge of history and I commend you for your tireless efforts and creativity because we
simply don’t know where the facts will lead us.
I also thank Chairman Genachowski for his leadership and his willingness to accommodate edits
and suggestions to improve the notice and to provide a meaningful opportunity for interested parties to
submit comments. We agree that working together is especially important given the unique
characteristics and complexities of the project. There are many proposals and an even greater number of
questions posed. At this early stage, some ideas appear to be better than others. Nonetheless, I’m pleased
that we included questions designed to capture comments regarding all practicable ideas.
We have completed our work on this stage of the process and the time has come to seek comment
from stakeholders on the myriad issues we have flagged thus far. As we move forward, I will follow a
number of important ideas quite closely. Among them are (but not limited to):
· Whether the proposed five megahertz channel blocks would result in a band plan that
reserves too much spectrum for unlicensed use, contrary to Congress’s explicit intent;
· Or, whether auctioning spectrum in six megahertz channels, that is, on a broadcast
channel-by-channel basis, would be more intuitive and thus lead to a more efficient and
fruitful auction;
· Whether the Commission will attempt to adopt rules or policies that run contrary to the
directives of the statute either directly or indirectly;
· Whether adopting six megahertz guard bands (as proposed) is necessary to prevent
harmful interference given the technological improvements that may come over the
horizon after we adopt rules;
· Whether the proposals for determining future broadcast channel assignments and reverse
auction winners would result in a process that is as objective and transparent as it must
· Whether issues related to the coexistence of Lower 700 MHz A Block operations and
those of neighboring TV channel 51 are resolved prior to the auctions;
· Whether imposing spectrum caps prior to the auction would exclude specific potential
bidders thus producing the net result of frustrating Congress’s directive that the
Commission attempt to raise at least $7 billion for a nationwide, interoperable public
safety network; and

· Whether the Commission would be able to finish its work without undertaking a further
notice and comment. This being – literally – the most complex spectrum auction in
world history
, I think we should keep all of our options open, including measuring twice
before making the cut, as carpenters say.
As we know, the law mandates that the Commission accomplish a number of important goals. I
have advocated that success will come more easily if we proceed with an eye toward regulatory humility,
simplicity and restraint. In the past, regulatory efforts to over-engineer spectrum auctions have caused
harmful, unintended consequences. I remain hopeful that our new rules will be minimal, intuitive and
“future proof” to pave the way for uses that we cannot imagine today as technology and consumer choices
We start a lengthy process today that is sure to be filled with many unforeseen twists and turns. I
am eager to contribute to the Commission’s ongoing effort and will greatly appreciate the thoughts and
insights of all involved.

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