In this proceeding, the Federal Communications Commission (“FCC” or “Commission”) seeks to transform the 2.5 GHz band (2496–2690 MHz), which has been assigned to Educational Broadband Service (“EBS”) and subject to strict regulatory constraints for decades.[1] Today, the 2.5 GHz band is “the single largest band of contiguous spectrum below 3 gigahertz and has been identified as prime spectrum for next generational mobile operations,” and yet it “currently lie[s] fallow across approximately one-half of the United States, primarily in rural areas.”[2] It therefore presents a tremendous opportunity for the FCC to pursue its statutory mandate to “generally encourage the larger and more effective use of radio in the public interest[.]”[3]

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.


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[1] Transforming the 2.5 GHz Band, Notice of Proposed Rulemaking, WT Docket No. 18-120, ¶1 (May 10, 2018) [hereinafter “NPRM”],

[2] Id.

[3] 47 U.S.C. § 303(g).

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