R Street Provides Comments to the FCC on Promoting Investment in the 3.5 GHz Band
In these reply comments, we address four aspects of the PAL licensing rules and respond to arguments raised on both sides of each:
- First, on the issue of geographic license areas for PALs, the Commission should adopt a hybrid approach that utilizes larger license areas for urban areas while maintaining smaller ones for rural areas.
- Second, on the issue of term lengths and renewability, the Commission should adopt longer term lengths and a renewal regime designed both to maximize efficient use of the 3.5 GHz band and to stimulate secondary-market transactions among PALs.
- Third, on the issue of how many PALs will be auctioned in each license area, the Commission should eliminate the N-1 rule and make seven PALs available in each license area.
- Finally, on the issue of specific-channel bidding, the Commission should weigh the costs and benefits of the proposal, and perhaps seek further comment, as it is unclear whether the benefits of implementing specific-channel bidding would outweigh the associated costs.