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Commission Document Attachment





Applications of GCI Communications Corp., ACS Wireless License Sub, Inc. ACS of
Anchorage License Sub, Inc. and Unicom, Inc. for Consent to Assign Licenses to the Alaska
Wireless Network, LLC, WT Docket No. 12-187; WC Docket No. 09-197.

Time is of the essence. It's true of the communications marketplace given the rapid evolution of
technology and insatiable consumer demand. And it's especially true in Alaska, where the building
season is short and winters are long. Hence, when two carriers plan on consolidating their operations in
order to reinvest in their communities, we owe it to them to move quickly.
Unfortunately, that didn't happen here. Our informal transaction shot clock is 180 days, but we
did not resolve this transaction until day 275. (To our credit, once Commissioners saw a draft order
eleven days ago, we approved it in short order.) This--along with the continued calls for FCC process
reform in last week's hearing before the House Energy and Commerce Committee's Subcommittee on
Communications and Technology--highlights the necessity of codifying the 180-day shot clock and
reexamining our procedures to make sure we meet it (perhaps using our forbearance procedural rules as a
model). Parties seeking Commission approval for their transactions deserve to know when they will get
an answer. There's nothing like a real deadline to keep us on track.

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