BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554

To: The Chief, Wireless Telecommunications Bureau

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.

Over the last nine months, hundreds of organizations, community leaders, and politicians have written to the Federal Communications Commission in support of M2Z Network's proposal for a free national broadband service.

But while the idea may stumble over FCC auction rules, it has stimulated an interesting debate about the agency's competitive bidding system for spectrum.

Menlo Park, California based M2Z petitioned the FCC for their proposed "family-friendly, free, nationwide wireless broadband service" in May of 2006. Here is how their idea works:

• Users of the free, advertiser based service will access it from their computers like television after they purchase a "relatively inexpensive M2Z-certified reception device available from various competitive vendors."
• Their wireless network would operate in the 2155-2175 MHz spectrum, working at a capacity of 384 kpbs downlink/128 kbps (kilobits per second) uplink. This qualifies as high speed broadband, according to the FCC, which defines the term as a service that provides Internet access in at least one direction at a speed faster than 200 kbps.
• The service will include a "compulsory setting that will utilize state of the art network filtering technology to take every reasonable and available step to block access to sites purveying pornographic, obscene or indecent material."
  The system will filter porn out "without the need for special end-user software," the company promises.
• M2Z will make the network available to any public safety organization without putting any limits of the number of devices used.
• The company will voluntarily pay the U.S. Treasury five percent of its gross revenues from its "Premium Service."

M2Z says that it wants to roll out the network to 95% of the population of the United States within ten years of receiving a license. One of the proposals' biggest selling points is its claim that the network will save the FCC's Universal Service Fund billions of dollars by taking on the USF's mission of bringing broadband to poor and rural areas.

Needless to say, the smut free aspect of M2Z's proposal makes it a strong sell with parents, community, and indecency groups across the United States, who have filed hundreds of pro-M2Z comments with the FCC.

The FCC Advanced Wireless Services auction of radio spectrum has ended, with 104 bidders spending almost fourteen billion dollars for the right to use frequency allotments made available by realignment of radio applications. Auctioned off were 1087 licenses for spectrum slices across the United States, with varying geographical scope. The bidding ended on September 18th.

Big bidders included T-Mobile (owned by Deutsch Telekomm AG), Verizon Wireless, and Spectrum LLC, a consortium of cable companies led by Comcast. Missing after the first week’s bidding were satellite TV companies DirecTV and EchoStar.

With the closing of the 52th round of bidding, the FCC’s Advanced Wireless Spectrum (AWS) auction today approached $13.5B in total amount bid. The net total is a bit less since credits for small companies reduces the amount that they pay.

Bidding began on August 9 and will continue with two rounds daily until no new bids are submitted.

1,122 licenses are for sale in this auction, ranging from a modest 10MHz frequency slice serving Wyoming up to licenses covering the northeast United States. Prices range from $7,200 to $1.335B, respectively.

Top bidders include Cingular, T-Mobile, and Verizon, competing to offer so-called "3G" services, combining mobile phone, laptop, and video. Some companies want to deny spectrum to their competitors.

The largest FCC spectrum auction in a decade has netted the government over $11,367,759,500 so far, the Commission reported yesterday. The Advanced Wireless Services auction, which began on August 9th, offers 1,122 licenses to the public in the 1710-1755 MHz and the 2110-2155 MHz bandwidths. These frequencies will be used for wireless voice and data, Internet browsing, and video content.

With round 28 finished, the top spenders include T-Mobile, Verizon Wireless, SpectrumCo, and MetroPCS.

T-Mobile, a division of Germany's Deutsche Telekom AG, has bid and provisionally won 125 licenses at a price of $3,798 billion. SpectrumCo, a business group that includes Time Warner Cable, Cox Communications, Comcast, Bright House Networks and Sprint Nextel, has come in second, winning 100 licenses at a price of $1,718 billion.

Speaking at a spectrum management conference, FCC Commissioner Jonathan Adelstein had strong words for the FCC's recent attempts to reform the Agency's system for auctioning off wireless broadband spectrum.

"I worked hard to put in place policies and rules that would promote opportunities for all carriers in the auction, such as a more diverse group of license blocks," Adelstein told an audience at the National Spectrum Managers Association, held in Arlington, Virginia. "But I'm afraid that recent decisions made by the Commission may substantially undercut that effort."