Dear Chairman Pai, and CommissionersO’Rielly, Rosenworcel, Carr, and Starks:

The undersigned taxpayer and free market groupsapplaud your efforts to free up the 3.7 to 4.2 GHz Band (mid-band, or “C-band”)for internet services. Repurposing C-band spectrum for mobile broadbanddeployment will help America win the race to 5G, as other countries studyrepurposing their own mid-band spectrum for internet use. A number of groups,including the C-band Alliance (CBA), claim that the FCC should allow for a“private-sale” of this critical segment of spectrum, instead of having the FCCrepurpose the spectrum to help close the digital divide.

While the CBA claims this isa market-based approach, this could not be further from the truth. In reality,the CBA wants the FCC to allow foreign interests to monetize taxpayer-ownedC-band spectrum through private sales that won’t benefit taxpayers. Not onlywould the CBA’s scheme deny billions – perhaps tens of billions ofdollars – in proceeds owed to the U.S. Treasury, but it would also inevitablyresult in years of litigation and endless delays in 5G deployment. We arealarmed by this proposal and unified in our opposition to the CBA’s egregiousprivate sale plan.

The C-band spectrum is a public asset ofenormous value. On the open market, it would command top dollar and interestfrom many parties. But the companies that comprise the CBA were givenpermission to use it free of charge, provided they would do so in the interestof the American public. And now, the CBA is trying to convince the governmentto abandon this obligation to taxpayers and the public, by allowing themonetization of the publicly-owned C-band spectrum through private sales.

The C-band spectrum is not just a valuableAmerican asset, it is a valuable strategic American asset with nationalsecurity implications that transcend even its commercial application. Given recentconcerns and allegations of spying by the Chinese government viatelecommunications equipment, the FCC should be especially careful in itsconsiderations.

Finally, the FCC’s recentderegulations and market-based reforms to close the digital divide show thatagency leadership is well-aware of   thechallenges faced by rural American communities. These citizens should not beleft behind, and that’s exactly what the CBA’s scheme would do by removing FCCoversight of spectrum allocation.  

We, as free marketorganizations, are committed to letting markets and incentives work in thisspace.  Free markets, private investment, and innovation areessential. 

We urge you to reject the CBA’s self-serving scheme, and instead, oversee a public auction that would allow for the most competitive allocation of licenses to best enable 5G deployment. This policy would result in billions of dollars for the U.S. Treasury – and the U.S taxpayer – maximizing its value for America, and facilitating a rapid, nationwide deployment of 5G that would serve everyone, especially rural Americans.