Comments sought for Mobility Fund Phase II
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
TTY: 1-888-835-5322DA 12-1853
November 27, 2012
FURTHER INQUIRY INTO ISSUES RELATED TO MOBILITY FUND PHASE II
WC Docket No. 10-90; WT Docket No. 10-208Comment Date: December 21, 2012
Reply Comment Date: January 7, 2013
In this Public Notice, the Wireless Telecommunications Bureau and the Wireline
Competition Bureau (the Bureaus) seek further comment on a limited number of specific issues relating to
the implementation of Phase II of the Mobility Fund. As established in the USF/ICC Transformation
Order and FNPRM, under Mobility Fund Phase II the Commission will award $500 million annually to
ensure the availability of mobile broadband and high quality voice services in areas where such services
would not otherwise be available.1
Building on the comments filed in response to the FNPRM and our experience to date in
implementing a reverse auction to award one-time Phase I support, the Bureaus seek to develop a more
comprehensive, robust record on certain of the issues related to the award of ongoing support for
advanced mobile services. In this regard, we note that a number of commenters support having an
opportunity to evaluate and learn from Mobility Fund Phase I before the program details of Phase II are
finalized.2 In considering the issues discussed below, we request that commenters keep in mind that
Phase II support is not one-time support, but is ongoing Phase II support aimed at expanding and
sustaining mobile services.
In the USF/ICC Transformation Order and FNPRM, the Commission comprehensively
reformed and modernized the universal service high-cost program.3 Among other things, for the first
1 See Connect America Fund et al., WC Docket No. 10-90 et al., Report and Order and Further Notice of Proposed
Rulemaking, 26 FCC Rcd 17663 (2011) (USF/ICC Transformation Order and FNPRM or Order or FNPRM), pets.
for review pending sub nom. In re: FCC 11-161, No. 11-9900 (10th Cir. filed Dec. 8, 2011).
2 See AT&T Comments at 33; Blooston Rural Carriers Comments at 3; C Spire Wireless Comments at 4; Cellular
South, Inc. d/b/a C Spire Wireless et al. Reply Comments at 14; CTIA – The Wireless Association Comments at 4;
General Communication, Inc. Reply Comments at 4; Rural Telecommunications Group, Inc. Comments at 17;
T-Mobile USA, Inc. Comments at 2-3; and United States Cellular Corporation Comments at 6.
3 See Order, 26 FCC Rcd 17663, supra, n. 1.
time, the Commission explicitly recognized the important benefits of and demand for mobile services
through the creation of a two-phase Mobility Fund within the high-cost program.
For Phase I, the Commission allocated $300 million in one-time support to expand the
availability of advanced mobile services, plus an additional $50 million dedicated to Tribal lands.4 For
Phase II of the Mobility Fund, the Commission dedicated $500 million annually (including up to $100
million dedicated to Tribal lands) and proposed to make awards through a reverse auction to support
providers of voice and mobile broadband service in areas where such services cannot be sustained or
extended without ongoing support. The Commission further proposed to award support on the same
terms and conditions as it adopted for Phase I, but sought comment on whether any modifications were
needed to reflect the ongoing nature of support in Phase II.
Under the Commission’s proposal, a Mobility Fund Phase II reverse auction would
assign support to maximize coverage of unserved road miles (or other units) within the budget. To
implement an auction, the Commission proposed a basic framework of auction rules that would give the
Bureaus flexibility under delegated authority to establish specific procedures for a Mobility Fund Phase II
Identifying Areas Eligible for Support6.
In the FNPRM, the Commission sought comment on various issues associated with
identifying the geographic areas that would be eligible for Phase II support.6 In light of experience with
Mobility Fund Phase I and Auction 901, we seek further comment on certain of these issues.
Identifying Areas Eligible for Support. To target Phase II support to only those areas
where it is needed, the Commission proposed to use Mosaik Solutions (Mosaik)7 data to exclude all
census blocks where an unsubsidized carrier is providing 3G or better service.8 For purposes of
determining areas with unsubsidized service, the Commission proposed in the FNPRM that areas
receiving one-time Mobility Fund Phase I support would still be eligible to receive Mobility Fund
Phase II support.9
4 The Mobility Fund Phase I single round reverse auction (Auction 901) took place on September 27, 2012, and
results were released on October 3, 2012. The 33 winning bidders are eligible to receive a total of $299,998,632 in
one-time support for deploying 3G or better mobile service covering up to 82,494.23 road miles in 795 biddable
geographic areas located in 31 states and one territory. See “Mobility Fund Phase I Auction Closes; Winning
Bidders Announced for Auction 901; FCC Form 680 Due November 1, 2012,” Public Notice, 27 FCC Rcd 12031,
12032, para. 1 (2012).
5 FNPRM, 26 FCC Rcd at 18077, paras. 1154-56.
6 Id. at 18070-71, paras. 1123-24.
7 When the Commission adopted the FNPRM, Mosaik Solutions was called American Roamer. However, in
February 2012, the company changed its name. See http://www.mosaik.com.
8 FNPRM, 26 FCC Rcd at 18070-71, paras. 1123-24.
9 Id. at 18070, note 2247. See Rural Telecommunications Group, Inc. Comments at 6.
Some commenters express concern about the accuracy of the Mosaik database.10 We
now seek further comment based on our use of Mosaik data as a factor in determining eligible areas for
Phase I support. To the extent that parties assert that Mosaik data inaccurately reflects the availability of
service, we seek comment on whether there are any other data sources that the Commission could use to
better identify eligible areas. We request that commenters provide specific information on what makes
these alternate sources superior and how they could be used instead of, or in combination with, the
Mosaik database.11 We also seek comment on whether there are other factors the Commission should
consider in addition to the availability of unsubsidized service. For instance, how should providers’
planned expansion of unsubsidized service affect our identification of areas eligible for support?12
Use of the Centroid Method. In the FNPRM, the Commission proposed to determine the
eligibility of a particular census block for Phase II support based on the absence of unsubsidized 3G or
better service at the centroid.13 Some commenters expressed concern that the centroid method is an
ineffective measure to determine whether large areas are unserved.14 We ask commenters for feedback on
the centroid method in light of their experience in Phase I. Should the Commission consider alternatives,
such as the proportional method?15 For instance, should it consider unserved any census block if the data
indicates more than 50 percent of the area is unserved?
Prioritizing Areas Eligible for Support10.
In the FNPRM, the Commission sought comment on whether to target Phase II support to
particular areas, such as those that lack any mobile service or ones that lack current generation (3G)
service.16 Some commenters suggest prioritizing support to rural carriers or carriers with 2G or less
10 See Blooston Rural Carriers Comments at 18. Universal Service for America Coalition proposed an indefinite
challenge process (as opposed to the limited timeframe allowed in Phase I) would correct inaccuracies in the data.
Universal Service for America Coalition Comments at 20-21; see also Alaska Communications Systems Group, Inc.
Comments at 17-18 (interested parties should be given an opportunity to suggest additions to the list of eligible
11 FNPRM, 26 FCC Rcd at 18076-77, paras. 1153-54; see also Order, 26 FCC Rcd at 17785, para. 337; “Mobility
Fund Phase I Auction Scheduled for September 27, 2012; Comment Sought on Competitive Bidding Procedures for
Auction 901 and Certain Program Requirements,” Public Notice, 27 FCC Rcd 530, 536, para. 19 (2012); “Mobility
Fund Phase I Auction Scheduled for September 27, 2012; Notice and Filing Requirements and Other Procedures for
Auction 901,” Public Notice, 27 FCC Rcd 4725, 4734-35, para. 20 (2012).
12 For example, in Mobility Fund Phase I, the Commission excluded areas from auction where a provider has made a
regulatory commitment to provide 3G or better wireless service, or has received a funding commitment from a
federal executive department or agency in response to the carrier’s commitment to provide 3G or better service.
Order, 26 FCC Rcd at 17781, para. 324. In addition, the Commission required applicants for Mobility Fund Phase I
support to certify that they were not seeking support for any areas in which they had made a public commitment to
deploy 3G or better wireless service by December 31, 2012. Order, 26 FCC Rcd at 17082-83, para. 410; 47 C.F.R.
13 FNPRM, 26 FCC Rcd at 18070-71, para. 1124. The term “centroid” refers to the internal point latitude/longitude
of a census block polygon. See Order, 26 FCC Rcd at 17786, n.576.
14 See Alaska Communications Systems Group, Inc. Comments at 16; Rural Telecommunications Group. Inc.
Comments at 12-13; United States Cellular Corporation Comments at 25 and United States Cellular Corporation
Reply Comments at 35.
15 See, e.g., Order, 26 FCC Rcd at 17787, para. 344 (discussing centroid versus proportional method for determining
unserved areas in Phase I).
16 FNPRM, 26 FCC Rcd at 18073, para. 1132.
capacity;17 another opposed prioritization of funding to areas with no service at all.18 Others suggested
that the Commission should take into account additional factors, such as poverty level or whether an area
is served by the National Highway System, instead of – or in addition to – coverage level. 19 Despite this
discussion in the record, we received little input on implementation and specific measures for prioritizing
The Bureaus seek additional comment on whether and how the Commission might
implement priorities for support among eligible areas. We ask commenters to address whether the
Commission should prioritize ongoing support to areas that lack coverage, a designated level of coverage,
or whether there are other measurable factors that should be taken into account. We observe that in the
FNPRM the Commission suggested that targeted areas could be prioritized by making a bidding credit
available.20 We seek additional specific comment on how the Commission might set an appropriate
level(s) of bidding credit(s) to prioritize areas based on the existing level of coverage in a particular area.
Similarly, we seek comment on whether and how the Commission might assure that support goes to areas
that would lose service absent the receipt of ongoing support. In this regard, commenters are invited to
discuss how, if at all, the availability of Remote Areas Fund support for the highest cost areas should
affect the areas targeted for Mobility Fund Phase II.
Establishing Bidding and Coverage Units12.
In the FNPRM, under its auction proposal, the Commission proposed to establish bidding
units in each eligible census block for purposes of comparing bids and assessing performance, and to base
the number of bidding units on the number of road miles in each eligible area.21 Road miles directly
reflect the Mobility Fund’s goals of supporting mobile services, and indirectly reflect many other
important factors – such as business locations, recreation areas and work sites – since roads are used to
access those areas.22 Several commenters recommend that the Commission consider other alternatives,
including population, terrain, workplaces, annual revenues, and straight-line miles or traditional river
miles, instead of – or in combination with – road miles.23 Some commenters also suggest that we revisit
the issue of bidding and coverage units after the Phase I auction before deciding on whether to use road
miles as the sole bidding unit.24
Given the results of the Mobility Fund Phase I auction, we seek further comment on the
use of road miles to determine bidding units and corresponding coverage requirements.25 We also invite
17 See Blooston Rural Carriers Comments at 10; Alaska Rural Coalition Comments at 23; Rural
Telecommunications Group, Inc. Comments at 13; see also Universal Service for America Coalition Comments at
18 See United States Cellular Corporation Comments at 27-28.
19 See Alaska Rural Coalition Reply Comments at 19; General Communication, Inc. Comments at 17; National
Tribal Telecommunications Association Comments at 38.
20 FNPRM, 26 FCC Rcd at 18073, para. 1133.
21 Id. at 18073, para. 1134.
23 See Blooston Rural Carriers Comments at 15-16; Universal Service for America Coalition Comments at 17; see
also Alaska Communications Systems Group, Inc. Comments at 19-20.
24 See, e.g., CTIA – The Wireless Association Comments at 7.
25 We note that the Commission concluded that for Phase I of the Tribal Mobility Fund, it would base bidding units
on population rather than road miles. Order, 26 FCC Rcd at 17822, para. 488.
additional comment on how specifically the Commission might measure or factor various suggested
alternatives, such as terrain or topography, into our determination of bidding units and ask for input on the
benefits or drawbacks of any particular approach.26
Public Interest Obligations14.
In the FNPRM, the Commission proposed that recipients of Mobility Fund Phase II
support would be required to provide mobile voice and data services that meet or exceed a minimum
bandwidth or data rate of 768 kbps downstream and 200 kbps upstream, consistent with the capabilities
offered by representative 4G technologies.27 The Commission proposed that these data rates should be
achievable in both fixed and mobile conditions throughout the cell area, including at the cell edge, at a
high probability, and with substantial sector loading.28 The Commission further noted that the proposed
measurement conditions may enable users to receive much better service when accessing the network
from a fixed location or close to a base station.29 The Commission sought comment on whether, and in
what ways, these metrics should be modified during the proposed 10-year term of support30 to reflect
anticipated advances in technology.31 The Commission also proposed that the performance characteristics
expected of Mobility Fund Phase II recipients be required “to evolve over time, to keep pace with mobile
broadband service in urban areas.”32 Commenters generally recommend periodic review and
modification of these requirements through a rulemaking proceeding.33 We now seek to further develop
the record on how often, and through what process, the Commission should modify the performance
metrics applicable to Phase II support recipients. Commenters should address the threshold question of
whether an evolving standard is appropriate given the proposed term of support and anticipated advances
in technology. For example, should the Commission require that broadband networks built with support
be capable of meeting increasing consumer demand for capacity and over a specified time period? If so,
should the Commission mandate any specific network attributes?
Term of Support15.
In the FNPRM, the Commission proposed a fixed term of support of 10 years and sought
comment on a shorter term.34 In seeking comment on an optimal term for ongoing support, the
Commission noted that it sought to balance the need to provide certainty to carriers to attract private
investment and deploy services, while taking into account changing circumstances.35 Commenters
generally agreed that a 10-year term was appropriate, noting that the term reflects the “economic realities
26 See Blooston Rural Carriers Comments at 16 (suggesting that “a Phase II applicant should receive ‘triple credit’
for each mile of tertiary roads that it proposes to serve in a rural area, as compared to an interstate highway.”).
27 FNPRM, 26 FCC Rcd at 18074-75, paras. 1141-43.
28 Id. at 18075, para. 1142.
30 Id. at 18074, para. 1138.
31 Id. at 18075, para. 1144.
33 See Information Technology Industry Council Comments at 4; United States Cellular Corporation Comments at
34 FNPRM, 26 FCC Rcd at 18074, para. 1138.
of network building,”36 and need for financial assurance to upgrade or extend networks.37 We seek
additional comment on establishing an appropriate term of support, in light of the timeframes for
deployment and private investment and the pace of new technology and marketplace developments.
Further, we request comment on the tradeoffs between using a 10-year term versus one or more shorter
terms and which approach would provide the best structure for dealing with dynamic changes in the
In the FNPRM, the Commission proposed to require that parties seeking Mobility Fund
Phase II support satisfy the same eligibility requirements that were adopted with respect to Phase I.38
Commenters generally support the Commission’s proposal, though some advocate size-based and other
restrictions.39 We seek further comment on certain of these issues.
Interplay with other universal service mechanisms. We seek comment on the inter-
relationship between eligibility for Mobility Fund Phase II support and other universal service support
mechanisms. The Commission noted that a party may be eligible to participate in both Connect America
Phase II and Mobility Fund Phase II, but noted that carriers would not be allowed to “receive redundant
support for the same service in the same areas.”40 We seek additional comment on how to implement this
principle so as to provide advance information to potential participants in a Mobility Fund Phase II
auction. In particular, we ask commenters to provide input on how the deployment of mobile service
under Mobility Fund Phase II could be supplemented or modified for purposes of meeting the public
interest obligations of Connect America Phase II. We also seek comment on any interrelationship
between eligibility for Mobility Fund Phase II support and the Remote Areas Fund that is to provide
support in the highest cost areas.
Small business participation. In the FNPRM, the Commission sought comment on
whether small businesses should be eligible for a bidding preference in a Mobility Fund Phase II
auction.41 Commenters were asked to address the effectiveness of a preference to help smaller carriers
compete at auction and whether the Commission should adopt a preference even if the bidding credit
would result in less coverage than would occur without the bidding credit.42 The Commission also sought
comment on how to define small businesses and what size bidding credit may be appropriate.43 Several
commenters supported the use of bidding credits to increase the competitiveness of small and rural
36 Windstream Communications, Inc. Comments at 18.
37 See Alaska Communications Systems Group, Inc. Comments at 20; see also United States Cellular Corporation
Comments at 35.
38 FNPRM, 26 FCC Rcd at 18074, para. 1140.
39 See, e.g., Universal Service for America Coalition Comments at 21-23; Blooston Rural Carriers Comments at 3-5.
40 Order, 26 FCC Rcd at 17674-75, para. 28.
41 The Commission noted that in a spectrum auction context, the Commission typically awards small business
bidding credits ranging from 15 to 35 percent, depending on varying small business size standards. FNPRM, 26
FCC Rcd at 18077-78, paras. 1157-60.
42 Id. at 18077-78, para. 1157.
43 The Commission sought comment on whether a small business should be defined as an entity with average gross
revenues not exceeding $40 million for the preceding three years, or whether it should use a larger size definition,
such as average gross revenues not exceeding $125 million for the preceding three years. Id. at 18078, paras. 1159-
carriers.44 We now seek to develop the record in light of commenters’ experience in Phase I, where
bidding preferences were not available, except for Tribally-owned or controlled providers.45 Would the
entities that were successful bidders in Auction 901 qualify as small businesses under the definitions the
Commission asked about? To what extent do commenters continue to believe that a bidding credit is
important to smaller carriers’ ability to effectively compete at auction for support and how does that
weigh against other Commission objectives?
ACCOUNTABILITY AND OVERSIGHT19.
In the FNPRM, the Commission proposed to generally apply to Mobility Fund Phase II
the same rules for accountability and oversight that will apply to all recipients of CAF support.46 Among
other things, the CAF accountability and oversight proposals are intended to create a process for the
reasonable and prudent disbursement of universal service support. In Phase I, the Commission authorized
disbursement of funds in three equal installments, linked to completion of certain milestones.47 The
Bureaus seek comment on how to structure ongoing support payments over the term of support in a way
that achieves the Commission’s goals of providing sufficient and predictable support throughout the term
of the Mobility Fund Phase II, while ensuring compliance with the Anti-Deficiency Act.48 Should
support be tied to completion of certain milestones, disbursed on a regular recurring basis, or some
combination of both?
TRIBAL PRIORITY UNITS20.
In the FNPRM, the Commission proposed and sought comment on a number of
provisions targeted at the specific connectivity challenges on Tribal lands. Among other things, the
Commission sought comment on a possible mechanism that would allocate a specified number of
“priority units” to Tribal governments to afford Tribes an opportunity to identify their own priorities. As
discussed in the FNPRM, priority units for each Tribe could be based upon a percentage, in the range of
20 to 30 percent, of the total population in unserved blocks located within Tribal boundaries. Tribal
governments would have the flexibility to allocate these units in whatever manner they choose. Tribal
governments could elect to allocate all of their priority units to one geographic area that is particularly
important to them, or to divide the total number of priority units among multiple geographic units
according to their relative priority.49 The Commission requested comment on whether this approach
should apply to both the general and Tribal Mobility Fund Phase II, and how such priority units should be
awarded in Alaska and Hawaii given the unique conditions in those states.50 The Commission also sought
comment on how this mechanism, if adopted, would interact with the proposed 25 percent Tribal bidding
44 See Alaska Rural Coalition Comments at 24; Blooston Rural Carriers Comments at 10-12; Rural
Telecommunications Group, Inc. Comments at 13-16; USA Coalition Comments at 24-25; Blooston Rural Carriers
Reply Comments at 6-8.
45 Order, 26 FCC Rcd 17807, para. 430.
46 FNPRM, 26 FCC Rcd at 18082, para. 1173.
47 Order, 26 FCC Rcd at 17815-16, paras. 464-69.
48 See FNPRM, 26 FCC Rcd at 18092, para. 1221 (noting that the Anti-Deficiency Act prohibits any officer or
employee of the U.S. Government from involving the “government in a contract or obligation for the payment of
money before an appropriation is made unless authorized by law”).
49 Id. at 18081, paras. 1170-71.
50 Id. at 18081, para. 1171.
51 See id.
Few parties offered comments addressing the priority units mechanism for Tribal
governments, and those that did generally focused on issues unique to Alaska.52 In light of the relatively
light record the Commission received on this issue and the results of Mobility Fund Phase I, we seek
additional comment on the Tribal priority units proposal. In particular, we seek further comment on
whether this approach should apply to Tribal governments participating in both the general and Tribal
Mobility Fund Phase II, and, if so, how such priority units should be awarded in Alaska and Hawaii.
Would the 25 percent Tribal bidding credit and the Tribal engagement obligation proposed in the FNPRM
be sufficient to ensure that Tribal priorities are met with respect to ongoing support under Phase II?53
The USF/ICC Transformation Order and FNPRM included an Initial Regulatory
Flexibility Analysis (IRFA) pursuant to 5 U.S.C. § 603, exploring the potential impact on small entities of
the Commission’s proposal.54 We invite parties to file comments on the IRFA in light of this additional
Interested parties may file comments and reply comments on or before the dates indicated
on the first page of this document. When filing comments, please reference
WC Docket No. 10-90and
WT Docket No. 10-208.
Comments may be filed using the Commission’s Electronic Comment Filing System
(ECFS) or by filing paper copies.55 Comments filed through the ECFS can be sent as an electronic file via
the Internet to https://www.fcc.gov/cgb/ecfs/. Generally, only one copy of an electronic submission must
be filed. If multiple docket or rulemaking numbers appear in the caption of the proceeding, commenters
must transmit one electronic copy of the comments to each docket or rulemaking number referenced in
the caption. In completing the transmittal screen, commenters should include their full name, U.S. Postal
Service mailing address, and the applicable docket or rulemaking numbers. Parties may also submit an
electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters
should send an e-mail to firstname.lastname@example.org, and should include the following words in the body of the
message, “get form.” A sample form and directions will be sent in reply. Parties who choose to file by
paper must file an original and four copies of each filing. If more than one docket or rulemaking number
appears in the caption of this proceeding, commenters must submit two additional copies for each
additional docket or rulemaking number.
Filings can be sent by hand or messenger delivery, by commercial overnight courier, or
by first-class or overnight U.S. Postal Service mail (although we continue to experience delays in
receiving U.S. Postal Service mail). Parties are strongly encouraged to file comments electronically using
the Commission’s ECFS. All filings must be addressed to the Commission’s Secretary, Office of the
Secretary, Federal Communications Commission, 445 12th Street, S.W., Washington, DC 20554.
All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. All hand deliveries must be held together with rubber bands or
52 See Tanana Chiefs Conference Comments at 7; General Communication, Inc. Comments at 19-20; Alaska Rural
Coalition Comments at 26-27.
53 See FNPRM, 26 FCC Rcd at 18080-81, paras. 1166, 1171.
54 USF/ICC Transformation Order and FNPRM, 26 FCC Rcd at 18364-95, App. P; see 76 Fed. Reg. 78384, 78430-
55 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13
FCC Rcd 11,322 (1998).
fasteners. Any envelopes must be disposed of before entering the building. The filing
hours at this location are 8:00 a.m. to 7:00 p.m.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
Parties shall also serve one copy with the Commission’s copy contractor, Best Copy and
Printing, Inc. (BCPI), Portals II, 445 12th Street, S.W., Room CY-B402, Washington, DC 20554,
(202) 488-5300, or via e-mail to email@example.com.
Documents in WC Docket No. 10-90 and WT Docket No. 10-208 will be available for
public inspection and copying during business hours at the FCC Reference Information Center, Portals II,
445 12th St. S.W., Room CY-A257, Washington, DC 20554. The documents may also be purchased from
BCPI, (202) 488-5300, (202) 488-5563 (fax), (202) 488-5562 (tty), e-mail firstname.lastname@example.org.
To request materials in accessible formats for people with disabilities (Braille, large print,
electronic files, audio format), send an e-mail to email@example.com or call the Consumer & Governmental
Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).
This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the
ex parte rules.56 Persons making oral ex parte presentations are reminded that memoranda summarizing
the presentations must contain summaries of the substance of the presentations and not merely a listing of
the subjects discussed. More than a one- or two-sentence description of the views and arguments
presented generally is required.57 Other requirements pertaining to oral and written presentations are set
forth in section 1.1206(b) of the Commission’s rules.58
For further information, contact Sue McNeil, Auctions and Spectrum Access Division,
Wireless Telecommunications Bureau at (202) 418-0660.
56 47 C.F.R. § 1.1200 et seq.
57 See 47 C.F.R. § 1.1206(b)(2).
58 47 C.F.R. § 1.1206(b).
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