Yesterday, the Communications Liberty and Innovation Project submitted comments in response to the FCC’s Notice of Proposed Rulemaking regarding spectrum holdings released in late September. The filing recommends that the FCC:
I. Not alter its framework for analyzing spectrum aggregation during its review of a particular transaction or license application.
II. Establish a spectrum aggregation benchmark equal to one-third of mobile spectrum.
III. Include all spectrum that is suitable for mobile service in the one-third benchmark.
IV. Not make distinctions among mobile spectrum bands.
The text of this filing is copied below. Read More