R Street comments in the matter of transforming the 2.5 GHz band
To encourage more effective use of the 2.5 GHz band, the Commission should take several steps. First, it should rationalize the geographic areas for 2.5 GHz licenses by using standard geographic service areas (“GSAs”) defined along census tract boundaries. Second, the Commission should maximize flexibility in the 2.5 GHz band by expanding license eligibility, removing educational-use requirements, and eliminating arbitrary term lengths that stifle long-term investment in the band. Third, it should move directly to auction EBS spectrum without any priority access windows. Fourth, the Commission should avoid placing any strict performance requirements on EBS licensees. Finally, the Commission should give due consideration to alternative approaches to managing EBS spectrum, including incentive and overlay auctions, so long as it takes a realistic view of the transaction costs involved.
[Download the pdf to read the entirety of the comments]
 Transforming the 2.5 GHz Band, Notice of Proposed Rulemaking, WT Docket No. 18-120, ¶1 (May 10, 2018) [hereinafter “NPRM”], https://goo.gl/qPmkzr.
 47 U.S.C. § 303(g).