PUBLIC INTEREST SPECTRUM COALITION

The Media Access Project, on behalf of the Public Interest Spectrum Coalition (PISC), hereby submits these comments with regard to the above captioned proceeding. The failure of the D Block license to attract a bidder presents the Commission with a unique opportunity to restructure this band of spectrum in a way that will both serve the needs of public safety and the broader goals of the Communications Act. To that end,

PISC makes two substantial recommendations. First, that the Commission rescind PSST’s license and require PSST to reapply, in competition with other applicants. This will ensure that the national public safety licensee – assuming the Commission determines it would serve the public interest to maintain a single national public interest licensee – fully complies with the determinations made in this proceeding. Second, that the Commission adopt the pro-competitive measures urged by PISC in the previous 700 MHZ proceeding: adoption of mandatory wholesale obligations, adoption of network neutrality and open device conditions, and adoption of spectrum caps or other eligibility requirements to enhance competition in the provision of wireless services. In addition, the Commission should move expeditiously to grant PISC’s pending Petition for Reconsideration. See Petition for Reconsideration of PISC, In re Service Rules for the 698-746, 747-762, 777-792 MHz Bands, WT Docket Nos. 06-150, et al. (Filed September 24, 2007).