The FCC has an upcoming auction, dubbed Auction 73, of the 700 MHz bandwidth range, which stands to greatly impact the telecommunications industry. The auction’s main functions are the reallocation of bandwidth to:
- promote the development of new cellular networks and companies,
- improve the availability, scope and quality of services offered by existing cellular networks,
- develop and implement a national, first responder broadband network that supports national interoperability in emergency situations, and lastly,
- generate funds for the US Government.
I intend to discuss the legal, political, and financial impact of Auction 73, as well as the influence of and differences from previous auctions. Lastly, I will use a fictitious company, Pines Telecommunications, Inc., to outline the auction process to provide a first-hand look at what a company must go though to participate in the auction and how the auction itself will be conducted.
Current and Future Allocations of the 700 MHz Frequency Range
The government has ruled all analog television transmissions must cease by February 18, 2009, at which time that frequency range will be turned over to the winning bidder(s) from Auction 73. The 700 MHz range is currently used by the analog television channels 52-69 and is divided into two broad categories, the upper and lower bands. The lower band utilizes channels 52 to 59 (698-745MHz) and the upper band utilizes channels 60 to 69 (746MHz to 806 MHz).
To prepare the frequencies for auction, and better manage the auction process, the FCC separated the frequencies in each band into blocks, most of which are then paired. (The use of blocks and the pairing of blocks were changes resulting from comments generated by the first edition of the FCC’s Report and Order of Proposed Rule Making, the guidelines for the auction process.1) The blocks in each band are labeled A through E. The upper band is represented by upper block A-E; likewise, the lower band is represented by lower block A-E. The blocks are paired up to facilitate better cellular communications by allocating a bandwidth per block. Pairing the blocks gives cellular network companies the ability to utilize separate frequencies for up-linking and down-linking, which better utilizes the limited frequency spectrum and provides more reliable communications. The exception to this is block C, which is unpaired because it uses the largest bandwidth range, 22 MHz, and is able to support robust frequency engineering and frequency reuse on its own.
Separating the bandwidth into blocks also ensures the FCC has a uniform way of tracking to prevent frequency blocks from the previous 700MHz auction in 2000, Auction 63, from being re-auctioned. Originally, the FCC planned to overlap blocks A-E in the upper and lower bands of the 700MHz range. However, to prevent confusion during the auction, each block is now separate in the upper or lower bands. Therefore, in Auction 73, only the unused portions of the band are available. The lower band is assigned to blocks A, B, and E; blocks C and D correspond only to the upper band of the 700 MHz range. For example, block A now occupies the 757-758 and 787-788 MHz range and block B was repositioned as a guard band for the public safety network in the upper band section at the 775-776 and 805-806 MHz range.
As mentioned earlier, separating the bandwidth into blocks was critical to the FCC’s ability to manage the 1000 plus licenses being auctioned. The FCC allocated a different number of licenses to each of the blocks. Block A received 176 licenses, which are grouped by Economic Areas (EAs) in the 698-704 and 728-734 MHz bandwidth. Block B received 734 licenses grouped by CMAs in the 704-710 and 734-740 MHz ranges. Block C received 12 licenses grouped by REAG in the 746-757 and 776-787 MHz ranges,2 and is also the only block that does not have a paired channel allocation. Block D, which occupies the 758-763 and 788-793 MHz range, will auction the single national license allotted for the development of the national first responder network. Block E, which utilizes the 722-728 MHz range, will auction 176 licenses from the EAs.3
Geographic Service Areas
The 1000 plus licenses listed above are going to be distributed among four major geographic service areas, or regions, listed in smallest to largest order: Cellular Market Areas (CMA), Economic Areas (EA), Regional Economic Area Group (REAG) and one national level license. The intent of each geographic region is to ensure the frequency is allocated to the largest portions of each geographic area. CMAs are small regions that focus on the small businesses supporting specialized, local markets. The CMAs are further divided into Rural Service Areas (RSAs) and Metropolitan Statistical Areas (MSAs) to fulfill two different requirements. The RSAs allow rural locations to provide cheaper services because the specialized, local service can focus on just that market. The MSAs serve the heavier populated areas, supporting integrated services across a specialized area. The CMAs are the areas most likely to utilize the Universal Services Fund (USF)4 if the FCC decides to extend the definition to include cellular communications.
The EAs provide mid to large sized companies with the appropriate capital to enter into existing cellular markets and help telecoms reach new customers by supporting coverage in wider subscription areas. The two frequency blocks assigned to EAs, A and E, allow for easier penetration over longer distance. Block E in particular provides EAs with the flexibility to utilize Frequency Division Duplexing, which prevents the sender and receiver from utilizing the same physical frequency for up-link and down-link from the cellular Base Station (BS) to the cellular devices.
REAGs were developed to assist larger companies interested in developing a national footprint by helping them buy into the 22 MHz spectrum bandwidth. The purpose of REAGs is to facilitate homogeneous services across larger areas and to support a robust network. The 12 licenses, or blocks, assigned to block C correspond with the 12 state and territory level REAGs. Blocks 1-8 cover all 50 states, block 9 refers to Guam and the North American Islands, and block 11 refers to the American Samoas. Blocks 9 and 11 together are collectively referred to as the Pacific region. Block 10 covers Puerto Rico and the US Virgin Islands and block 12 is the Gulf of Mexico; together they are referred to as the Atlantic region.
Lastly, the primary purpose for the national license is to facilitate the development of a national broadband first responder system, which will be discussed in detail later.5
Legal and Political Concerns for Auction Participants
Like any government undertaking, there are numerous political and legal aspects that must be addressed throughout the auction. The 700MHz auction has not been without its share controversy due to a few key changes in the way the FCC will be conducting Auction 73 in comparison to past auctions. One change to the auction is to ensure bidders are anonymous. This change was made to facilitate fair bidding between small and large businesses. Previous incidents recorded during the AWS-1 Auction in 2006 included situations where large telecoms like AT&T, Verizon, and Sprint used their incumbent positions, along with large capital resources, to conduct "retaliatory bidding."6 Retaliatory bidding was one way the larger, incumbent telecoms forced smaller business to stay away from a particular block or license. Larger telecoms would bid simply to raise the price on a block or license they knew a small business was interested in, even if they were not truly interested in that block or license. By driving the bid prices higher, the smaller telecoms would be forced to scale back the scope of their anticipated auction participation, including possibly withdrawing from previously desired block and license auctions entirely. Once the smaller telecoms dropped out of planned multiple bids to concentrate funds on the block with the inflated price, the larger telecoms could win their desired bids will little or no competition. By keeping the bidders anonymous in Auction 73, the FCC hopes to level the playing field and eliminate the ability of larger companies to intimidate smaller, newer organizations.
As in the past, Auction 73 allows any business, individual or entity to comment on the auction rules, found in The Report and Order of Proposed Rulemaking, prior to its finalization. Using the FCC’s process for submitting comments about the auction process, Google requested the FCC allow the winning bidders to resell the spectrum for a profit as a wholesaler. The FCC denied the proposal, however Google did persuade the FCC to allow additional opportunities for competition in the cellular industry by allowing an open standard for hardware and software platforms. The intent of Google’s request to permit hardware and software development through the use of open architecture was to assist small and mid-sized companies in their attempt to enter into the telecommunications and cellular industries. Open architecture would lower the high cost barrier created by the need to not only purchase a license, but to also build a cellular infrastructure.7 Sharing existing software and hardware makes these two major financial concerns less overwhelming and prohibitive for small and medium companies with limited resources. However, Google’s motives were not entirely benevolent, as their secondary intent was to become a telecom wholesaler in the cellular market.8
Not all interested parties were pleased with the FCC’s decision to allow open standards for hardware and software. After Verizon learned of the open standard ruling, they submitted a Petition for Review with the United States Court of Appeals in the District of Columbia, effectively suing the FCC to prevent this ruling. Verizon felt the FCC overstepped its authority under the Communications Act of 1934 and Administrative Procedure Act. Verizon’s specific complaint was the FCC ruling was "arbitrary, capricious, unsupported by substantial evidence and otherwise contrary to law."9 This sounds very similar to the defense AT&T used in their failed attempt to prevent the outcome of the Carterphone decision, which allowed devices other than AT&T manufactured products onto the Public Switched Telephone Network (PSTN). In their reply to Verizon, the FCC used the same defense was used in the Carterphone decision, stating any vendor can implement open standard hardware and software as long as it doesn’t damage the existing network.
The legal and political issues do not end there. Another concern for bidders is whether or not the government will enforce the February 18, 2009 end of service date for those currently using the 700MHz bandwidth. This ruling requires commercial and government providers of the fixed station mobile radios and analog TV channels currently utilizing the 700MHz bandwidth to relocate to the Advanced Wireless Services (AWS-1) network, also known as the Third Generation (3G) network. The cause for concern stems from the fact that the government failed to enforce a similar end of service deadline in the previous auction, AWS-1 Auction 66. According to the rules published in an FCC news release, federal funds were to be allocated for the transfer of the incumbent users of the spectrum because they were federal organizations, such as the Department of Defense (DoD), Alcohol Tobacco and Firearms and Explosives (ATF), Drug Enforcement Administration (DEA), Federal Bureau of Investigations (FBI), Immigration and Custom Enforcement (ICE) and Secret Service. However, according to an article in Total Telecom, the transfers have not taken place and the winning bidders, including the majority license winner T-Mobile, still have not been allowed to access the spectrum. Interestingly, the only organization that has stopped using their allocated spectrum from Auction 66 is the Secret Services. As of July 17, 2007 the other agencies refused to comment on the matter.10
Another important concern is key legislation governing Auction 73 has been postponed multiple times. Initially, the Telecommunications Act of 1996 intended to start the process of transitioning from analog to digital TV signals. No progress was made and a year later the Balanced Budget Act of 1997 mandated no analog TV signals were to be renewed past December 31, 2006. Since that deadline has passed, a new deadline was extended until February 2009. Additionally, further mandates for moving from analog to all digital TV broadcasts were included in the Digital Television Transition and Public Safety Act of 2005. The Digital TV Act mandated that all analog TV signals on the 470-894 MHz range, specifically analog television channels 14-83, be reallocated to digital signals. None of the mandates or rulings have been adhered to as of late 2007.11
If Auction 73 unfolds as its predecessors have, the winning bidders may be in for a long and expensive wait. Despite this, Auction 73 has been described as the "last beachfront real estate" for the cellular industry12 due to two factors. First, it is most likely the last opportunity for new providers to enter into the cellular industry as the government does not have an unlimited supply of bandwidth to reclaim and re-auction. The government is also offering numerous credits to auction participants to help them with the financial aspects of the auction. Second, the 700 MHz band has ideal physical frequency characteristics. The lower frequency, indicating a longer wavelength, leads to vast geographic coverage potential as it is less susceptible to distortion. This clarity allows the receiver to decode the transmitted signal with a higher success rate. The 700MHz range is also an ideal wavelength due to its ability to penetrate walls, trees and other obstacles. Even one of these two factors would be enough to make the financial and legal complications found in the preceding auctions well worth it, but there are further financial aspects to consider this time around.
For the FCC and bidders alike, Auction 73 can have a major impact on them financially. The FCC views the auction as an opportunity to generate large profits. To calculate their potential profit they have determined the minimum (or reserve) bid for each block and license, the amount of the upfront payments required to participate, an estimated overall return for the auction, and finally the type and impact of bidding credits. The FCC analyzed each license block to compute the overall minimum Cost Per License (CPL), which then determines the FCC’s minimum profit margin. When determining the minimum CPL they considered the population of the coverage area for the licenses, bandwidth of the block, if the geographic areas requiring paired or unpaired frequencies, and lastly the frequency ranges. The FCC then calculated the impact of providing credit, or discount, opportunities to bidders to make sure the maximum range of prospective bidders are able to participate.
FCC Bidder Credits
There are multiple opportunities for bidders to qualify for FCC-sponsored credits in Auction 73. The FCC has two types of credit available, one of which is reserved for small and very small businesses. Very small business are defined as having an average annual gross income that does not exceed $15 million over the last three years. These companies will receive a 25% discount on their winning bid(s). Small businesses are defined as having an average annual gross income of $15-40 million over the last three years and can qualify for a 15% discount on their winning bid(s). Small and very small business must complete and submit the applicable paperwork prior to the auction in order to qualify for this credit. The second credit opportunity is called the Tribal Lands bidding credit and is available to all businesses regardless of their size. In order to qualify for the credit, the winning bidder must plan to develop wireless services for federally recognized tribal areas that do not currently have coverage. However, the winning bidder’s plan to implement cellular wireline services can not exceed 85% of the existing telecommunications market. It is important to note the Tribal Credit is in addition to any other credit(s) granted by the FCC. It differs from the small business credit because it must be submitted 180 days after the auction, using FCC form 601.13
The willingness of the FCC to provide multiple credit opportunities to bidders does not mean it has lax financial requirements, as demonstrated by the FCC requirement for upfront payments and the use of reserve bids. Upfront payments eliminate casual bidders and also allow the FCC to gauge the level of interest in each license by observing how many parties participate in the upfront payment bids. Reserve bids are a means to ensure profits.
Since the 700 MHz spectrum has more attractive frequency characteristics then the AWS-1 auction, the FCC will put reserve bids in place for all frequency blocks to ensure a competitive price is paid for each. The reserve bid was determined by observing the frequency characteristics of the band and the size of geographic are affected, and then comparing these factors to the winning bids from the recent AWS-1 Auction 66. The FCC has conducted this analysis to ensure public interest is maintained and fair market value is represented for the 700 MHz spectrum.
The reserve bid is considered met when the gross bid amounts total the reserve bid. The exception to the reserve bid rule is block C, which can be purchased in packages, thereby creating the possibility that a second auction will be conducted to meet the reserve bid for block C. The FCC has determined the blocks to be the threshold for minimum bids and because block C bids can be merge and the calculated reserve is done on an individual bids. This might require a separate auction preceding Auction 73 to meet the reserve price. If the reserve for each block is not met, no licenses will be award to bidders in that block, and the opportunity for rebidding will commence to ensure reserve bids are met.Ibid.^
After all of their research and analysis, the FCC has set the following prices as approximate reserves for Auction 73, listed by block:
@ $1.8 Billion
@ $1.4 Billion
@ $4.6 Billion
@ $1.3 Billion
@ $903 Million
The reserve bid estimates combine for a total of approximately $10 Billion.
National First Responder Broadband Network
The most important development unique to Auction 73 is the mandated development of a national public safety first responder broadband network. The FCC has required the winner of the WP-NWQ511-D license (the only nationwide license) to implement and support the structure necessary for a nation-wide public safety first responder network. License WP-NWQ511-D is a 10 MHz bandwidth utilizing the 758-763 and 788-793 MHz frequency ranges.14 Once the winning bidder is awarded the license, the company’s development and support of this network will be governed by the FCC using the Network Sharing Agreement (NSA). The NSA is the contract between the federal agency outlining responsibilities for interoperability between the winning bidder and the US Government. The agreement will cover the applicable upfront service fees and oversee a schedule that outlines the construction of the infrastructure by the winning bidder.
The need for such a network was identified as a key finding from the 9/11 commission report – prior to any funding or licensing. This national broadband network is to be part of the solution to the interoperability issues that plagued first responders responding emergencies of 9/11. The network will be developed through the joint effort of the commercial industry and federal, state, and local first responders. Fire, police, safety, medical, and crisis personal will utilize the network to coordinate training and exercise missions seamlessly across the nation.
The first responder network will receive a portion of its funding through the Digital Television Transition and Public Safety Act of 2005. This act empowered the National Telecommunication and Information Administration (NTIA), along with Department of Homeland Security (DHS), to provide funds for the interoperability of first responders with the stipulation that it was not to exceed one billion dollars from 2005 to 2010. The first step in this process was realized recently on September 30, 2007 when the Public Safety Interoperable Communications Grant Program (PSIC) awarded funds to 56 States and territories.15 This awarding was accompanied by a requirement for the funds to be assigned to a project for interoperability by December 3, 2007.The proceeds from Auction 73 will be the main funding stream to pay for the PSIC. The national first responder broadband network will also reap the benefits of many grants, with a small portion of the grant monies earmarked for strategic implementation, and a larger portion allocated to network hardware.16 It remains to be seen whether or not the FCC will allow grant monies to subsidize the commercial obligations for hardware and installation.
To best illustrate the auction process, I will describe a fictitious company going through all the steps necessary to participate in Auction 73. The business is a small, regional telecom called Pines Telecommunications, Inc. (PTI) with the following properties:
- based out of Oklahoma
- three-year gross income of $25 million
- operates in the wireline market for rural and tribal land markets in Oklahoma where it purchased an existing license from a bankrupt telecom company
This is their first FCC auction, and their intent is to extend their coverage to rural and tribal land cellular markets inside and outside of Oklahoma. They are motivated to expand their business due to their strong customer base and success in the wireline market.
To begin the auction process, PTI is required to establish a FCC Registration Number (FRN) by registering electronically using the Commission Registration System (CORES).17 A FRN is mandatory when conducting any business with the FCC. The FCC uses this number to track auction participants and provide updates, feedback, and refunds for auction purposes.
Since this is the first auction PTI is participating in, it is in their best interest to attend the auction seminar. Only the president of PTI will likely attend, due to their small size and restricted resources. PTI’s president is required to submit Attachment J of FCC form DA 07-4171 as part of the seminar auction registration. Attachment J provides basic attendance information along with information on the company represented. The seminar provides an overview of the following topics:
- registration requirements
- key deadlines and dates
- upfront payment requirements
- instructions on filing all auction paperwork
- how to use the automated auction tool.
Other PTI employees who are not attending the seminar can view the event live and for free online.
Along with the auction seminar and FRN registration, another key early deadline is the submission of FCC form 175 to the FCC no later than 6PM EST December 3, 2007. FCC form 175 allows the FCC to determine if a particular organization is eligible to participate in the auction by reviewing an organization’s legal, technical and financial information. PTI should allow approximately one and a half hours to obtain and fill-out this form electronically and could face perjury charges if false information is knowingly included. The form will require basic business data including business status, the POC for the auction, the name and company information of 3 employees eligible to participate in the bidding, and whether or not the business qualifies for or will be pursuing any of the FCC’s bidding credits. License information is also necessary to ensure a bidder is eligible to bid on certain license(s) during the auction. Preregistration for specific licenses is mandatory in order to be able to bid on a license during the actual auction. An organization doesn’t have to bid on all license during the auction, however PTI must ensure all desired license(s) are noted on their FCC form 175, as additional license can not be added once this form is submitted. Lastly, PTI must submit their gross financial income for the last three years. The $25 million gross income qualifies PTI for the 15% small business discount.18
The FCC is encouraging interested parties to research equipment purchasing and market trends, and conduct cost benefit analysis in order to develop business plans related to their potential participation in Auction 73. After compiling this information, let us assume PTI chooses to submit a bid for licenses WY-CMA057-B, which represents CMA057 Frequency B in the Tulsa OK Cellular Market Area, along with license WY-BEA124-A Tulsa OK-KS Block A Economic Area. They must submit their upfront bid payments no later than 6PM EST December 28, 2007, along with FCC Form 159 – the Remittance Advice or upfront payment form. The only authorized payment method is via wire transfer. The required amount of the upfront bid factors in the type of license, REAGs, MSA, CMA, and EAs – and varies between 3 or 5 cents per MHz-population. For example, the upfront calculation for license WY-CMA-057-B is calculated by multiplying Bandwidth per MHz by Population by a constant value of .05 cents for an upfront bid payment of approximately $505,000 (12 MHz x 841,604 × .05 = $505,000). A complete list of upfront payments, minimum opening bid and reserve bids can be found in Attachment A of DA07-4171.19
After all the required FCC and auction documents are confirmed and processed, the FCC publishes a list of qualified bidders on January 14, 2008. PTI and other approved bidders are then able to participate in a mock auction on January 18, 2008.
The mock auction provides the bidders with the opportunity to become familiar with the two available auction participation methods: telephone and internet. Since PTI is bidding via the internet, they will be mailed a SecurIDÂ® token to be used in conjunction with a Personal Identification Number (PIN) created by the bidder in order to authenticate participation in both the mock and actual auction.20
The actual auction is divided into two stages requiring different levels of bidding eligibility based on available funds. Stage one requires 80% of eligible funds be directed to the open license bids. Stage two requires bidders present an opening bid of at least 95% of eligible funds in order to be considered an active bidder. These requirements are in place to prevent bidders from withholding funds until later rounds. The bid increase is calculated by utilizing last round’s bidding activity in order to maximize the price increase in the next round. A smaller multiple is utilized to identify the minimum increase to the current price estimate (CPE) round.
When PTI enters the active bidding round, they initially bid the minimum bid for license WY-CMA057-B at 349K. PTI decides to use a bidder’s waiver for license WY-BEA124-A to maintain interest in the license and to ensure they are in compliance with the minimum bid requirement without having to actually allocate funds to a bid. Throughout the rounds, the bidding increases above the level PTI is willing to spend on BEA124-A, eliminating their eligibility for that license. This prohibits PTI from bidding on BEA124-A during the rest of the auction. However, during the final round of bidding, PTI is the highest bidder for license CMA057-B. Since all minimum bids are reached, including block C, the FCC will publicly announce the auction closed. They will proceed to publish the winning bidders and the amount paid, along with notification of any additional funds required from the winners (due 10 days after the announcement).
Upon receiving the winning bid announcement, PTI completes and submits a second eligibility form, FCC form 601. FCC form 601 is a more detailed version of FCC form 175, providing additional corporate, financial and industry details. PTI now moves on to implementing the business plan they developed based on obtaining license CMA057-B.21
Auction 73 will provide a great opportunity for the FCC to generate funds for the federal government with a minimum payday of $10 billion. The auction will ensure the frequency range is utilized more effectively because it will now support first responder land mobile radios coverage, cellular coverage, and open standard competition, along with a shared first responder and commercial agreement. The increase in cellular competition with the participation of non-incumbent cellular providers will provide better options, services and features not currently considered or available to cellular subscribers.
This will inevitably lead to new market exploration and creativity, some of which is already showing up e.g., Google’s recent announcement stating they will be creating software for cellular phones in the US). The large cellular hardware companies are already developing plans in anticipation of the auction. The key chip makers are focused on determining which technologies can be best implemented and how the new products and plans can be integrated into the new networks.
Ultimately, though, it is up to the winning bidders to determine what protocols to implement on their bands. Auction 73 will be a key fixture in defining the future of cellular services in the US because of its unique characteristics, new rulings, and the possibility of new participants.
1 "Public Notice DA 07-4171: Auction of 700 MHz January 16, 2008 Notice and Filing Requirements, Minimum Opening Bid, Reserve Prices, Upfront Payments, and Other Procedures for Auctions 73 and 76." Federal Communications Commission_. 5 October 07. Accessed November 2007 from http://wireless.fcc.gov/auctions/default.htm?job=resleases_auction&id=73auction&id=73.
2 "Auction 73: 700 MHz Band License DA07-3415 Attachment D- Subsequent Contingent C Block License Summary." Federal Communications Commission_. 2 September 2007. Accessed November 2007 from http://wireless.fcc.gov/auctions/default.htm?job=resleases_auction&id=73auction&id=73.
4 The Universal Services Fund (USF) is a program the FCC instituted and modified in the Telecom Act of 1996. The Law allocates an entire section to the concept of universal services, with the seven principle points outlined in section 254 (b). The 7 principle points of universal service are: quality and rates, access to advanced services, access in rural and high cost areas, equitable and non-discriminatory contributions, specific and predictable support mechanisms, access to advanced telecommunications services for schools, and health care and libraries. The last principle is an open ended principle that allows the FCC to determine any future universal service capabilities as long as they protect public interest, add to the convenience of services, and identify emerging needs.
5 "Auction 73: 700 MHz Band License DA 07-4171 Attachment A- All License Summary." Federal Communications Commission_. 5 October 2007. Accessed November 2007 from http://wireless.fcc.gov/auctions/default.htm?job=resleases_auction&id=73auction&id=73.
6 Rose, Dr. Gregory. "Spectrum Auction Breakdown: How Incumbents Manipulate FCC Auction Rules to Block Broadband Competition." New American Foundation Wireless Future Program, Working Paper#18_. June 2007. Accessed November 2007 from http://www.newamerica.net/files/WorkingPaper18_FCCAuctionRules_Rose_FINAL.pdfFINAL.pdf.
7 Some of the items or activities required to build-out a cellular network are very expensive (e.g., radios, leasing/purchasing cellular towers, obtaining proper permits to erect new towers and Mobile Subscriber Offices (MSOs), etc.).
8 "Pubic Notice DA 07-3415: Auction of 700 MHz Licenses Scheduled for January 16, 2008: Comments Sought for Competitive Bidding Procedures." Federal Communications Commission. 17 September 2007. Accessed November 2007 from http://wireless.fcc.gov/auctions/default.htm?job=resleases_auction&id=73.
9 "Case No. 07-1359 CELLCO Partnerships d/b/a Verizon Wireless v. Federal Communications Commission and United States of America." Free Press, Web Site_. 10 October 2007. Accessed November 2007 from http://www.freepress.net/docs/vzw_appeal_700_petition.pdfpetition.pdf.
10 Boles, Corey. "US Govt Crime Surveillance Keeps Mobile Companies Off Airwaves." Total Telecom. 14 September 2007. Accessed November 2007 from http://totaltele.com/View.aspx?t=2&ID=95161 (subscription required).
11 "Digital Television Transition and Public Safety Act of 2005." National Telecommunications and Information Administration. 17 Oct. 2007. Accessed November 2007 from http://www.ntia.doc.gov/otiahome/dtv.
12 Markoff and Matt Richtel. "F.C.C. Hands Google a Partial Victory." New York Times. 1 August 2007. Accessed November 2007 from http://www.nytimes.com/2007/08/01/technology/01spectrum.html.
13 "Public Notice DA 07-4171." FCC.
14 "Auction 73: 700 MHz Band License DA 07-4171 Attachment A- All License Summary." FCC.
15 "Public Safety Interoperable Communications Grant Program." National Telecommunication and Information Administration. 27 September 2007. Accessed November 2007 from http://www.ntia.doc.gov/psic/index.html.
16 Moheny, Doug. "The Cash Grab Begins." Mobile Radio Technology_. April 2007. Accessed November 2007 from http://mrtmag.com/policy_and_law/mag/radio_cash_grab_begins/begins/.
18 "Public Notice DA 07-4171." FCC.
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