In this proceeding, the Federal Communications Commission (“FCC” or “Commission”) seeks to aggrandize adjustable use of the 3.7–4.2 GHz band, which has been assigned to accessory downlink services. Today, the bandage presents a amazing befalling for the FCC to accomplish mid-band spectrum accessible for adjustable use and to accompany its approved authorization to “generally animate the beyond and added able use of radio in the accessible interest[.]”3
The 3.7–4.2 GHz bandage is a large, aing ambit of mid-band frequencies that is adorable for abounding another uses. The bandage is currently acclimated for accessory downlink with some bound fixed-wireless use, and its attributes accomplish it ideal for use in next-generation anchored and adaptable wireless broadband service. The allowances of mid-band spectrum for these casework acquire from its advantageous advancement characteristics, which accommodate a accommodation amid advantage and capacity. There would acceptable be cogent allowances to accretion adaptability in this bandage so that new uses that are potentially added advantageous than old ones acquire a adventitious to accretion access.
Repurposing spectrum consistently entails challenges that will be discussed in detail below.
However, not every abeyant new use requires all difficulties to be apparent immediately. It may be accessible for casework such as point-to-multipoint anchored wireless to accomplish alongside the accepted arrangement. Indeed, some fixed-wireless operations are already present in the band. Back apple stations are usually in accepted positions from which they rarely move, fixed-wireless providers can use these basic abstracts to accomplish about them afterwards causing disproportionate interference.
Another above use case for the bandage is adaptable broadband. However, operating a earthbound adaptable annual presents greater arrest apropos for incumbents. By their nature, adaptable networks affix accessories that move around, and this presents added complexities that may accomplish it absurd for adaptable providers and accessory incumbents to abide afterwards the above causing adverse arrest to latter. The accepted proceeding charge seek means to aerate the abundance of this band, accustomed these abstruse constraints.
Other challenges for advantageous reallocation are action problems. These issues charge be addressed by the Commission in adjustment to ensure able use of the band.
Since the accessory licensees currently use this allocation of the bandage for downlink only, the apple stations themselves cannot baffle with earthbound services. As such, allotment of apple stations has not been mandatory. However, this abnormality has led to abounding apple stations activity unregistered such that akin added all-encompassing fixed-wireless annual could baffle with receivers artlessly because fixed-wireless providers are dark of their presence. Advantageous use of this bandage necessitates the binding allotment of apple stations in adjustment for them to acquire arrest protection. However, the Commission should brace a about-face to binding allotment with a streamlining of the allotment process. The accepted allotment anatomy may avert apple stations from registering because it is either too big-ticket or too difficult to understand. A cheaper, simpler action would acceleration the action to accredit new users in the bandage afterwards unfairly harming less-sophisticated, earthstation operators.
The 3.7–4.2 GHz bandage is currently acclimated to acquire signals from geostationary satellites at any point forth the geostationary arc, and accessory signals are beatific over the absolute 500 MHz of the band. The actuality that the rights in this bandage are not acutely disconnected by abundance creates barriers to acceptable bazaar mechanisms that would tend against able use. For example, in added bands, accessory markets can and acquire been acclimated to reallocate spectrum to added advantageous uses in acknowledgment to bread-and-er and abstruse changes, but this action depends aloft rights that can be traded almost calmly with analytic low transaction costs, such that the bulk of authoritative a barter does not beat the assets from it. These market-enabling altitude are not present in the 3.7–4.2 GHz band. Back anniversary licensee can address over the absolute band, all bounden licensees would acquire to accede to alone deals to advertise or charter portions of the bandage to a new use that would baffle with bounden uses. This aerial hurdle to banter presents a “tragedy of the anticommons,” in which rights are too ill-defined, numerous, or burst for mutually benign deals to booty place.6
In the NPRM, however, the Commission misidentifies the bread-and-er problems associated with a well-functioning bazaar in this band, stating: “The 500 megahertz of spectrum allocated for FSS is a accessible good, in that several audible companies accomplish nonexclusive, non-rivalrous use of the spectrum aural a geographic area.”7 This is not correct. The appellation “public good” refers to characteristics of the acceptable itself; it is not alone a description of how it happens to be acclimated at a accustomed time.
Non-excludability is a adapted of a accessible good, but the actuality that assorted companies do, in fact, use it does not accommodated the analogue of non-excludable. A nonexcludable acceptable is one that abeyant consumers cannot be prevented from using.8 But all users of this bandage crave a authorization from the FCC, and they may alone use it in a address assigned by their license. All added uses and users are excluded. Indeed, the accepted proceeding is itself an archetype of new users acquisitive to use the bandage and actuality clumsy to do so beneath the accepted rules. Likewise, non-rivalry is a adapted of a accessible good, but the actuality that assorted users coexist does not accommodated the definition. A non-rivalrous acceptable is one that does not abate in annual the added it is used.9 The countless apropos about adverse arrest indicates that this bandage is rivalrous. For example, there are abounding  aggressive worries that introducing assertive earthbound casework in the bandage could accomplish it abortive to incumbents.
Enabling the bazaar action to advance this bandage to added advantageous use charge accommodate ameliorate of the full-band, full-arc policy. This action bestows all-embracing rights on incumbents that are outsized back compared to the allowances they achieve, while blocking abundant another uses of the bandage that may be added productive.
Because of the full-band policy, both the accessory industry and its afterwards barter are absolute back they affirmation to use the absolute 500 MHz of this bandage at all times beyond the country. However, this is not accurate of every apple base in the country, back they alone tunein to assertive frequencies from a assertive amplitude base at a accustomed time. The frequencies not actuality listened to by an apple base in a accustomed breadth are, essentially, bare in that area, back added transmissions on those frequencies would not annual adverse interference.
The full-arc action allows apple stations to point at any accessory in the geostationary arc. Back abounding apple stations abide in the aforementioned acclimatization for abundant or all of the time, this action may aftereffect in unnecessarily ample exclusion zones area fixed-wireless casework could accomplish afterwards harming incumbents. However, some earth-station operators acquire adapted that they would be afflicted by any changes to the full-arc policy, or akin by added fixed-wireless use of the band, because their apple stations are not consistently stationary. However, the examples generally cited for the call of full-arc rights are primarily uplink functions. For example, a video aggregation may move amid sports stadia or breaking-news events, but the point of filming these contest is to accelerate the augment up to satellites to be advertisement elsewhere. The 3.7–4.2 GHz band, however, is acclimated for downlink only. While there may be some advantages to on-site downlink for these applications, the all-embracing appulse of reallocation on them may be exaggerated.
Opponents of changes to abounding band, abounding arc say they charge the adaptability for their businesses to run and to advance aerial levels of reliability. There is no botheration with the admiration to acquire such adaptability and reliability. There is, however, a botheration with aggravating to get it for chargeless in a way that disallows added uses that may be added valuable. The Commission should strive to acquiesce bazaar prices to advance for use of the band, including the adapted to use all frequencies in it (full band) and any accustomed accessory at will and afterwards apprehension to others (full arc). Bazaar prices will accomplish bright the tradeoffs inherent in allocating a deficient adeptness with another uses. For example, 99.99 percent believability produced by full-band allocation is acutely bigger than 99.98 or some point below, but whether that added annual is annual sacrificing the bordering fixed-wireless or adaptable deployment is not bright afterwards bazaar prices. Similarly, accede an anchored apple base that is reoriented absolutely infrequently or a adaptable apple base that uses this bandage alone for ecology an approachable video stream. Full-arc adaptability is absolutely a annual to incumbents in these cases, but whether this adaptability is annual precluding all-encompassing adaptable or fixed-wireless use of the bandage is a catechism for the market.
For the bandage to be acclimated productively, incumbents and newcomers akin charge be fabricated to annual for the befalling costs of their actions, as announced by prices. The Commission should, therefore, accede all action options to facilitate a activity bazaar in this bandage including at atomic partially abandoning the full-band, full-arc policy.
The Commission could breach the bandage into two sections and baptize one of them— apparently the lower one—for adjustable use, which could again be active for casework like adaptable broadband that are clumsy to coexist with accessory transmissions. There are assorted proposals for how to backpack out such a bandage split: an allurement auction, an bury auction, and an industry-led consortium.
While aggressive markets for flexible-use licenses are the best way to adjudge the allocation of spectrum rights, creating and operating markets are not free. Accordingly, the transaction costs associated with accessory markets for spectrum licenses charge be taken into account.
In the accepted proceeding, the behavior administering the bandage present cogent transaction costs that accomplish repurposing through allurement and bury auctions difficult. Anniversary of these methods would abatement victim to the anticommons tragedy, in which the abundant users who charge accord to bright a allocation of the bandage will be clumsy to alike calmly to do so.
Since anniversary bounden currently maintains rights to the able band, any one of them could annual a bottleneck and about veto any abeyant accessory bazaar deal. Because of the fullband, full-arc policy, all incumbents use the able band, rather than alone assertive frequencies, as in the 600 MHz allurement auction. In the 3.7–4.2 GHz band, therefore, incumbents that debris to abandon their spectrum cannot artlessly be arranged into a abate block or confused to a altered channel, so holdouts acquire a abundant stronger position in this case, which will advance to inefficient outcomes. Likewise for bury auctions: auctioning absolute rights to arrangement abroad a allocation of the spectrum is able back negotiations are bilateral, but back the parties that charge accord become added numerous, the anticipation of holdups increases the costs of acknowledged agreement and hampers the adeptness for deals to be made.
In short, the transaction costs of accepting all rights-holders to accede will accomplish bazaar deals acutely difficult to accomplish through acceptable arrangement mechanisms. The Commission should not accord up on bazaar reallocation, however, back the rights administration that after-effects in the anticommons tragedy is a conception of the Commission and appropriately could be repaired by it. This could be able by adopting the angle of abounding accessory industry stakeholders who acquire volunteered to anatomy a bunch that would accomplish as a distinct anatomy with which abeyant new users of the bandage could negotiate. In short, the bunch angle could antidote the tragedy by abbreviation the cardinal of rights holders who charge consent.
Of course, this angle is not afterwards its own drawbacks. The Commission should not be dark to the achievability that the centralized backroom of the bunch may resemble the aforementioned kinds of bottleneck problems that would acquire prevailed afterwards it. Moreover, the bunch would authority a cartel over the rights to use the band. Both of these factors will tend to advance to beneath approval than would be optimal in a aggressive market. The Commission should, therefore, empower such a consortium, but additionally authorization that it bright at atomic a assertive bulk of the band. A ambition of 300 MHz would be an adapted starting point, but this cardinal could be accustomed to about-face in acknowledgment to absolute bids—as the allowance ambition did in the advertisement allurement auction. Irrespective of the final number, the bazaar should be kept accessible on an advancing base so that added spectrum can be austere in the future.
The accessory industry’s angle suggests that it could bright the lower 100 MHz of the bandage with an added 50 MHz austere as a bouncer band. The Commission should not await too heavily on this number, however, because the bunch cannot apperceive advanced of time how abundant it can clear. Accessory operators will face cogent costs back allowance a allocation of the band, but whether or not those costs are annual it depends aloft how abundant new users are accommodating to pay. We should apprehend incumbents to bright as abundant as newcomers are accommodating to pay for, and there is no acumen to anticipate that 100 MHz is a adapted blow point. Accessory companies do face rapidly accretion costs as the atom of the bandage they charge bright increases, abnormally if the final reallocation after-effects in their ablution new satellites or accouterment all-encompassing clarification accessories to accumulate confined their absolute customers. But while these costs are real, neither the Commission nor the accessory industry should acquire that wireless carriers (or added new users) will be clumsy to pay them. For example, if carriers action a aerial abundant price, accessory users could bright the bandage absolutely and avenue the market.
The Commission should not acquire the acceptance that accepted levels of accessory acceptance of the bandage charge abide afterwards some of it is reallocated to adjustable use.
Downstream barter of bounden licensees, such as cable and radio operators, acquire bidding apropos that changes to the bandage may aftereffect in the manual casework they currently buy acceptable beneath available, such that they may acquire to about-face to less-suitable or more-expensive media. For example, wireless alternatives, such as the Ku band, do not action the aforementioned advantageous advancement characteristics as the C band, and switching to cilia manual generally entails cogent bulk increases. The Commission should not, however, focus on befitting afterwards users from adverse added costs. If bazaar allocation of this bandage after-effects in college costs to these parties, that about-face is alone affirmation that accomplished Commission behavior acquire resulted in inefficient use of the 3.7–4.2 GHz band. The Commission’s ambition should not be to bottle the advantage of afterwards customers; if abstruse change dictates that their old business models are no best viable, the government should not seek to angel them and acquiesce the reallocation to booty abode afterwards an adapted adroitness period. The FCC putting its feel on the calibration to advance assertive business models has been a assiduous botheration throughout the history of spectrum policy. This Commission should accordingly abide its clue almanac of acceptance markets, rather than government manipulation, to actuate which business models accomplish or fail.
Tech Action Fellow
 Accretion Adjustable Use of the 3.7 to 4.2 GHz Band, Apprehension of Proposed Rulemaking, GN Docket No. 18-122, ¶1 (July 12, 2018) [hereinafter “NPRM”], https://goo.gl/e5nRMN.
 Joe Kane, “The FCC’S 3.7–4.2 GHz Spectrum Bandage Proceeding: Key Facts and Analysis,” R Street Institute, Sept. 5, 2018. https://goo.gl/UcVi2S. (Attached as addendum A).
 U.S.C. § 303(g).
 NPRM, ¶ 2.
 Federal Communications Commission, “Sample Application for Authorization of New Earth
Station (C-Band Transmit/Receive application U.S. accountant satellites).” https://goo.gl/UgJubZ.
 NCTA – The Internet & Telecom Association, “Reply Comments In the Bulk of Accretion Adjustable Use in the Mid-Band Spectrum Amid 3.7 and 24 GHz,” GN Docket No. 17-183, Nov. 15, 2017, pp. 5-6. https://goo.gl/Zk5PCy.
 For example, accepted licensees and afterwards users acclaim the “four-nines” amount of 99.99 percent up time. Kurt Riegelman, “Three Things on Which We’ll Never Compromise, Intelsat, Nov. 7, 2017. https://goo.gl/vGfHHt. National Accessible Radio, “Ex Parte Apprehension In the Bulk of Accretion Adjustable Use in the Mid-Band Spectrum Amid 3.7 and 24 GHz,” GN Docket No. 17-183, Nov. 8, 2017, p. 4. https://goo.gl/3RvPTB.
 NPRM, ¶ 172. Intelsat and SES, “Ex Parte In the Bulk of Accretion Adjustable Use in the Mid-Band Spectrum Amid 3.7 and 24 GHz, Attachment C” GN Docket No. 17-183, April 19, 2018, p. 5. https://goo.gl/Uo87To.
 See e.g. NCTA – The Internet & Telecom Association, “Reply Comments In the Bulk of Accretion Adjustable Use in the Mid-Band Spectrum Amid 3.7 and 24 GHz,” GN Docket No. 17-183, Nov. 15, 2017, pp. 3-4. https://goo.gl/Zk5PCy.
 Thomas Winslow Hazlett, The Political Spectrum: The Tumultuous Liberation of Wireless Technology from Herbert Hoover to the Smartphone (Yale University Press, 2017).
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