April 10, 2019

Chairman Ajit Pai                                                          
Federal Communications Commission                     
445 12th Street, SW                                                    
Washington, D.C. 20554                                            

Commissioner Jessica Rosenworcel
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554
 
Commissioner Michael O’Rielly                                         
Federal Communications Commission                               
445 12th Street, SW                                                                                        
Washington, D.C. 20554                                        

Commissioner Brendan Carr
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554                                        

Commissioner Geoffrey Starks
Federal Communications Commission                     
445 12th Street, SW 
Washington, D.C. 20554           

Dear Chairman Pai, and Commissioners O’Rielly, Rosenworcel, Carr, and Starks:

The undersigned taxpayer and free market groups applaud 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 broadband deployment will help America win the race to 5G, as other countries study repurposing 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 FCC repurpose the spectrum to help close the digital divide.

While the CBA claims this is a 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-owned C-band spectrum through private sales that won’t benefit taxpayers. Not only would the CBA’s scheme deny billions – perhaps tens of billions of dollars – in proceeds owed to the U.S. Treasury, but it would also inevitably result in years of litigation and endless delays in 5G deployment. We are alarmed by this proposal and unified in our opposition to the CBA’s egregious private sale plan.

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

The C-band spectrum is not just a valuable American asset, it is a valuable strategic American asset with national security implications that transcend even its commercial application. Given recent concerns and allegations of spying by the Chinese government via telecommunications equipment, the FCC should be especially careful in its considerations.

Finally, the FCC’s recent deregulations and market-based reforms to close the digital divide show that agency leadership is well-aware of   the challenges faced by rural American communities. These citizens should not be left behind, and that’s exactly what the CBA’s scheme would do by removing FCC oversight of spectrum allocation.  

We, as free market organizations, are committed to letting markets and incentives work in this space.  Free markets, private investment, and innovation are essential. 

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.

Respectfully,

David Williams
President
Taxpayers Protection Alliance

Tim Andrews
Executive Director
Taxpayers Protection Alliance Foundation

Steve Pociask
President / CEO
The American Consumer Institute

Grover Norquist
President
Americans for Tax Reform

Tom Schatz
President
Citizens Against Government Waste

Jeff Mazzella
President
Center for Individual Freedom

Andrew F. Quinlan
President
Center for Freedom and Prosperity

Matthew Kandrach
President
Consumer Action for a Strong Economy

Katie McAuliffe
Executive Director
Digital Liberty

Andrew Langer
President
Institute for Liberty

Charles Sauer
President
Market Institute

Karen Kerrigan
President & CEO
Small Business & Entrepreneurship Council

James L. Martin
Founder/Chairman
60 Plus Association

Saulius "Saul" Anuzis
President
60 Plus Association

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