Calling for an end to the "hymns of praise for the status quo," a coalition of media reform groups have filed a 32 page document rebutting incumbent wireless company arguments against fairer FCC auctions in the 700 MHz spectrum band.

"The lack of substantive evidence has not stopped incumbents and other special interests from submitting thousands of pages into the record repeating the same unsubstantiated claims in innumerable variations," the Ad Hoc Public Interest Spectrum Coalition (PISC) wrote to the Federal Communications on July 6th, prompting their Ex Parte reply.

The FCC will soon sell off spectrum in the 700 MHz band, much of it available thanks to the analog-to-digital television signal transition. Engineers call the 700 MHz band as "beachfront" spectrum, ideal for broadband services, and estimated to be worth billions of dollars.

But filers in the FCC's proceeding on how to conduct the auction disagree on rules for the sale. Incumbents like AT&T, Verizon, and other big telcos have filed hundreds of briefs with the FCC resisting proposals that media reform groups say will make it easier for new entrants to obtain spectrum licenses in the auction or to access affordable spectrum after the sell off.

"The 700 MHz auction represents a unique opportunity to transform the broadband and wireless communications landscape," PISC writes. "Unsurprisingly, incumbents urge the Commission to avoid any significant changes and maintain the status quo."

The controversial proceeding has also drawn the public input of two presidential candidates: Democrat John Edwards and Republican U.S. Senator John McCain, both of whom have sided with various reform proposals.

PISC includes the Media Access Project, Freepress, the Consumers Union, the New America Foundation, and seven other groups. The reforms mentioned in their July 6th document include:

• Ensuring that some portion of the band be made available to an "open network" that leases spectrum to the public on an affordable basis.

  "Significant demand exists for an open network that can provide spectrum wholesale, so that wireless innovators can provide customers with new services that the existing oligopoly refuses to provide," PISC writes.

  The proposal parallels calls by Frontline Wireless for the creation an "E-Block" section of the spectrum, about 12 MHz of the 700 band, to be auctioned off on the proviso that the winner use the space to build an open access national public safety broadband communications network. Third party firms could lease the spectrum at wholesale rates, making it easier for police, fire, and emergency agencies to create new communications systems.

• Directly or indirectly excluding incumbents from the auction. PISC wants either caps on the amount of spectrum big telcos can buy, or the outright exclusion of major spectrum holders. The coalition also wants new entrants, defined as entities that do not already run wireless, terrestrial, or PCS networks, to receive auction credits—essentially discounts.

  "A new entrant credit available to any new entrant regardless of size, therefore, serves not merely to attract new bidders," PISC writes. "Such a credit would also help ensure that a successful new entrant does not emerge so laden with debt that it cannot compete effectively against incumbents."

• Anonymous bidding. "Anonymous bidding remains the sine qua non of a competitive auction," PISC contends. Critics of the FCC's present auction system charge that big incumbents use open bidding rules to collude with each other, signalling their intentions to collaborators with pre-agreed upon bids.

  "For those who have successfully gamed the system in the past, the opportunities for collusion, signaling and retaliatory bidding are features rather than defects of the FCC's rules," PISC argues. "Rather than permit these bidders to continue to manipulate the auction system under the guise of various claimed 'benefits' of collusion, the Commission should adopt anonymous bidding.

PISC also urges the FCC to reject arguments by Google and other firms suggesting that the impending availability of unlicensed technologies, capable of accessing temporarily unused spectrum, or "white space," will offer opportunities to smaller wireless providers presently unavailable.

"Rather than adopting this 'let them eat unlicensed cake' attitude, the Commission should view the synergies between licensed and unlicensed spectrum as an additional reason to set aside 30 MHz of spectrum for open access," PISC writes.

As mentioned, proposals for auction reform have received endorsements from two presidential candidates.

On May 30th Democrat John Edwards appeared at Google's headquarters in Mountain View, California and endorsed the concept of anonymous bidding.

"By setting bid and service rules that unleash the potential of smaller new entrants, you can transform information opportunity for people across America—rural and urban, wealthy and not," Edwards' statement concluded.

John McCain has also filed comments with the FCC on the 700 MHz auction. McCain's statement did not mention Frontline, but called the E-Block idea "an excellent use of the public's spectrum and an outstanding example of a public-private partnership."