 There are also bios out there as a handout because so we won't spend much time giving you background on the speakers since you have them in the handout. And in case you're wondering, where is Deb Collier, Tom Schatz, the president of Citizens Against Government Waste, is filling in because Deb became ill this morning. So we have one substitute. So welcome to New America. I am Michael Calabres. I direct the wireless feature project here, which is part of New America's Open Technology Institute. And this is the Great Airwaves Robbery 2, and I'll tell you why I'm using the numeral 2 in a moment because people thought it was a typo. Well, I'm just going to give some background remarks so, you know, because we were part of comments filed by the Public Inter-Spectrum Coalition on this proceeding. And I want to, you know, tell you a bit about what we said as context, and then that way I can moderate without being too tempted to get back on my high horse about some of the issues. And then we'll have the panel discussion, I'll moderate some questions, and then at the end we'll have time for some, you know, audience questions or comments at which time, you know, please introduce yourself, tell us who you are with. I see there's some of the folks who are very directly involved in this, are present. That's great, as well as some press both here and we're on a live webcast. So welcome to all of you in the ether. So as you all no doubt know, more high-quality mid-band spectrum is needed for ultra-fast 5G wireless networks, both mobile and fixed. To meet this need, the FCC is seeking to reallocate underutilized satellite spectrum in the C-band the 500 megahertz that lies between 3,700 and 4,200 megahertz on the spectrum. The challenge is that C-band today carries virtually all live TV and radio programming from content producers to local stations and cable systems nationwide. So, of course, everyone from NPR to your cable company relies on that for almost all the, you know, the linear video programming and increasingly for more. In July, the FCC opened a rulemaking that proposes to reallocate at least the bottom 200 megahertz of the C-band for exclusive licensing, presumably to mobile carriers and potentially others for 5G wireless services. The NPRM also proposes that the upper portion of the band, which will remain in use for fixed satellite service for video and radio distribution, can be shared in local areas where rural broadband ISPs can deploy high-speed fixed wireless broadband on unused frequencies without causing interference to earth stations. A separate issue we had an event about last year and probably will again, but today's issue is focused on the lower portion to be cleared for exclusive licensing. The FCC in the NPRM is deciding whether the agency should conduct a public incentive auction as it did for 600 megahertz TV spectrum two years ago or instead to authorize a consortium of four incumbent satellite companies to sell the spectrum directly to mobile carriers. Under that proposal, the satellite companies could receive an estimated $15 to $40 billion or more for spectrum they licensed at no cost because under international law, in fact, the FCC cannot auction spectrum for satellite use. Part of the context for this discussion is what our public intraspectrum coalition described in comments we filed that strongly opposed a private sale or private auction of the spectrum. We emphasized that Congress not once but twice enacted legislation expressing clear intent to avoid precisely the sort of massive giveaway that the satellite companies propose here. In case you were wondering, this is why the event is titled The Great Airwives Robbery II. For me, this event, because I'm much older than most of you, this event represents a bit of deja vu. Back in 2002, I hosted an event titled The Great Airwives Robbery, the first policy program event ever held at New America, which was a pretty new org at the time. Senator John McCain, who was then ranking member of the Senate Commerce Committee, had agreed to speak, but he couldn't make it because of Senate votes. The president of CTIA did keynote a fellow named Tom Wheeler, who went on to better things. The event that day raised concerns about an order adopted by the FCC in September 2001, just after 9-11. The FCC adopted a proposal by PACS and Communications, which had organized a spectrum clearing alliance that included local TV stations willing to give up their analog TV channel early in exchange for a share of the auction proceeds. The Powell FCC decided that an immediate reallocation of the TV spectrum was important to speed up deployment of 3G mobile services, the race to 3G, and so it agreed to hold the public auction in which winning bidders would be required to make, quote, market-based side payments of billions of dollars more on top of what they bid in the public auction. They would pay billions more into Bud PACS and spectrum clearing alliance to be distributed on a megahertz pop basis among the broadcasters. Senate vote Bud PACS and bloated, quote, the broadcasters are going to be in for a big windfall. Congress thought otherwise. Senate Commerce Committee Chairman Fritz Hollings immediately sent the letter to Powell stating that paying broadcasters billions in public revenue was outrageous and amounted to an unlawful end-run around Section 309J, of course the Portion of Communications Act that requires auctions with competing bidders. He and McCain promised it would not stand, and it didn't. Within six months, Congress passed the Auction Reform Act of 2002, canceling the auction. Congress instead passed the DTV transition bill, setting a deadline to vacate upper UHF channels and mandating a public auction of that spectrum. Those 700 megahertz airwaves, the best beachrun spectrum, were auctioned a few years later for $20 billion. But here's the difference. Every penny of that 20 billion went to the Treasury or into a special fund to subsidize consumers who needed to purchase digital to analog converter boxes in order to hasten that DTV transition. First forward to 2010 and the FCC's national broadband plan, the FCC proposed an incentive auction to voluntarily clear and auction the 600 megahertz TV band, channels, as it turned out, channels 38 to 51 this time. Constrained by the Auction Reform Act, Chairman Genekowski saw an incentive auction authority from Congress. In 2012, Congress did just that. On a bipartisan basis, the law gave the FCC incentive auction authority, which is by the way good until 2022, that is designed specifically to compensate only as many TV stations as necessary, 175 as it turned out. The 2012 act had another limiting feature. It required incumbent licensees to bid against one another in a reverse auction designed to discover the lowest payment that incumbents would accept to give up their six megahertz channel and go off the air. As a result, in 2017, the incentive auction sent $10 billion to the Treasury, with only 175 stations receiving an incentive payment, and the vast majority of TV stations above channel 37, they were forced to relocate in exchange for reimbursement of costs. Finally, I should mention one other critical concern of PISC that hasn't gotten much attention. If the FCC allows four satellite companies to sell underutilized spectrum they never paid for, it will set a counterproductive policy precedent. Authorizing a private sale would not only nullify section 309J, it would send a message to dozens of other licensees that they should always wage maximum resistance to any clearing or consolidation of a band, or again sharing any unused spectrum, unless the FCC gives them all of the public revenue that until now has always gone entirely, or in the case of the 2017 incentive auction primarily, back to its owners, the American people. With that, as I promised, I'll get off my high horse now and move the conversation over to our distinguished panel, so join you. So we can go straight down the row, I'll introduce, rather than introduce everyone at once and then you'll forget, you know, one at a time and ask kind of, I guess, what's my top of my mind for each of you. So Tom Schatz, as I mentioned, is filling in for Deb Kauyer. Tom is the president of Citizens Against Government Waste, which has a storied history of fighting for taxpayers and fiscal conservatism. Tom, the satellite companies are proposing that the FCC give them the authority to sell the spectrum licenses, you know, as I just described, in the lower 200 megahertz of the C-band, if that would occur, I mean, do you see a rationale for that? You know, how does Citizens Against Government Waste view that sort of a private sale of spectrum? Well, I think even non-lawyers understand that a license is not a property right. A license is permission to use something that belongs to someone else. This is why the satellite companies would need to go to the FCC to get permission to conduct an auction, which the FCC has traditionally conducted. So right there it's complicated and certainly sounds like something unprecedented, which it would be. We need the spectrum to help deploy 5G. The proposal does not take into account incumbents who use the space, such as broadcasters, rig operators and others who would be forced to vacate channels. It also doesn't ensure that these terrestrial users are kept holds throughout the process. That's part of the job of the FCC. Private companies have different interests than the taxpayers and certainly than the agency. I know it's rare for Citizens Against Government Waste to say good things about a federal agency or federal activities, but in this case the FCC, regardless of whether they have been chaired by Democrats or Republicans, have done a great job of conducting these auctions, making sure the money is used as intended. And there's really no reason that this should not occur in this situation. And as Michael said, it would set a terrible precedent for the future. The money would go to these companies who again do not own the property that they would be auctioning rather than to the taxpayers. So not only did they raise $10 billion under the incentive auction in 2012, but they raised $47 billion from the AWAS-3 auction to help fund the First Net, First Responders Network, and whatever remains after that is done goes back to the taxpayers. The federal deficit is going to go beyond $1 trillion in 2022. It's already almost $900 billion. National debt is almost $22 trillion. Clearly this money should be used for the purposes of helping the taxpayers and also helping deploy 5G. We don't want to lose that race. So every penny that we can get from the spectrum that belongs to the taxpayers and not the satellite companies should be used for these purposes. So whether it's 5G, bridging the digital divide, using a furrow broadband, whatever Congress thinks is the appropriate purpose for the money that comes in from this auction should be done as it has been. So again, I think the process should be pretty simple and clear. There's plenty of precedent to do this. I actually recall Michael mentioned that first auction and the fact that Congress fixed that on a bipartisan basis. This is one of the few things that pretty much everybody in Congress seems to agree with, that auctions of spectrum should be done by the FCC and the money should go to whatever purpose Congress decides and certainly to help reduce the deficit and again in this case do something in relation to 5G. Now the general authority does expire in 2022 so hopefully this doesn't drag out. I don't think it will but this can be done under current authority. Again the only legislation that might be needed would be to say exactly where Congress wants the proceeds to go. We're happy to work with a lot of groups both sides of the aisle on these issues. As I said it's something that we strongly support and have always supported and there's nothing that says it should be done any differently than it has been done in the past. Thanks, Don. Ross Lieberman is Senior Vice President of Government Affairs at the American Cable Association. Ross, what concerns do small cable operators have with the CBA's proposed private sale? Thanks Michael and thanks for inviting me back to speak on this issue before your group. So all MVPDs across the country including hundreds of small and medium-sized cable operators rely on the CBA to pick up video programming via thousands of earth stations to deliver to more than 90 million subscribers. It's the highest used medium for backhaul delivery of video services and rural users in particular are highly dependent on the C-Band because of alternative ways of receiving this program are not available namely fiber to these systems. One of the things I take I'm pleased about is it seems that there is a nearly universal understanding that however the C-Band spectrum is reallocated that existing users should be protected. However, we do have some concerns with the degree upon which this would actually occur under various proposals. Now I'm going to focus primarily on this panel on the private sale of the satellite industry. I don't want that to be confused with our support for any other proposal. In fact we have very strong objections to the concept of allocating 300 megahertz or more that T-Mobile and others have made available that would cause great harm. Spectrum sharing we have great concerns about as well. But as the satellite industry itself says that the CBA proposal, the private sale proposal is in the pole position and that's why the focus is on if that's going to be a proposal that is going to be considered the harms of that should be fully understood. Now with regards to the some people call it a private sale or market-based approach it's actually two parts and maybe more parts to it. One part of it is just the private sale. How do you sell the spectrum to users that want to buy it? Another part of it that's a private decision that the satellite industry wants to preserve for itself is how do you identify and remediate the harms to existing users? So while there's been some on this panel and otherwise I've focused a lot on how it should be sold, users particularly small and medium-sized cable television operators are very much concerned about the private decisions that go to the identification remediation of the harms. And it's not a black and white issue. Whether or not full remediation occurs is a bit of a gray area and we have concerns with the satellite industry making those decisions exclusively by themselves given the impact it has on significant investments that smaller cable operators have made in their markets as well as consumers that highly depend on the service that they're delivering. As a party that seeks to profit from fully from the sale of the spectrum, we don't think that they're in the best position to be able to decide for users what is a harm and how to address it. And their proposal essentially says that they decided and users have no say in those decisions. And then so we look at the available information, based on available information and their decision to sell 200 megahertz of spectrum. We do see significant problems, some that have not been fully addressed by the private sale. Number one, we think that the reallocation of 200 megahertz of spectrum is going to lead to higher prices for those that lease the C-band spectrum. And those higher prices will end up having two types of harms. Number one, it's going to be prices that are going to be passed down to the cable operators ultimately to consumers. We're going to see higher prices as a result of the reduction in the supply that's available of C-band. Higher prices to programmers who I'm talking about would also mean that some of them may choose no longer to utilize the C-band. Or new programmers may say, I'm going to opt for a different option for delivering a video. And that's a big concern for rural operators who don't necessarily have access to fiber and may not therefore have access to that programming on a going forward basis. The other concern is interference. You know, the CBA proposal has said in their private sale that they'll make available filters in order to mitigate the interference. Obviously, they're defining what is full mitigation, how often it will work, when it won't work. And those concerns we think that we should have a seat at the table when it comes to deciding what is full mitigation. A couple last things then I'll stop is just, you know, we've asked for answers. We've put in ACA, NAB, NCTA put in a letter at the FCC in June of last year asking for answers to these questions. We said, if you're going to make these decisions, please fill us in exactly on how this is going to operate and why we should have comfort. We don't think those answers have been fully addressed in the record. And ultimately, if the satellite industry doesn't modify the proposal in order to fully address the concerns of users, then, you know, the FCC might be the best place in order to address those concerns. They are a fair arbiter. They have no financial interest in the outcome. They have a public interest outlook on things. And so, you know, they can make some of these decisions on what is a harm and how best to address it. So, all right. Thanks, Russ. Next on our panel, Colleen King is Vice President of Regulatory Affairs at Charter Communications. Colleen Charter is both an incumbent earth station operator in the C-band and a new entrant in the mobile market that may want to bid for mid-band spectrum. What are your concerns about the private sale approach and, you know, how does it affect your business? Thanks very much for the question. My short answer is that our biggest concern is that we think the private sale would block us from the ability to potentially get 5G spectrum, and that's a big concern. But if you'd let me provide some color on that, we always appreciate... Charter appreciates getting invited to these spectrum events because we see ourselves as much more than a cable company, we're a connectivity company. We've invested a lot in our network, provide ultra-fast, high-capacity broadband servers to our customers. We've invested over 27 billion in technology and infrastructure since 2014 to extend our network. And we're extending our network in a few ways. First, it's really to continue to spread of broadband for additional ultra-fast, ultra-high-capacity speed. But also, it's really to prepare the network for the bandwidth needs of 5G. So we see ourselves as a key part of the 5G solution. We've also long been a wireless company. We have an incredibly extensive Wi-Fi network. Over 80% of traffic in the home and office travels over a Wi-Fi network and over 300 million wireless devices are already connected to our network. And we see Wi-Fi as kind of the starting point for our mobile strategy. As hopefully you've all heard, we launched our Wi-Fi-first MBO last year. And how that works is we're working with Verizon in the home and office and near our Wi-Fi network, you'd use our Wi-Fi network and then extend it into the cellular network as we go out. But the next step in that strategy is really to look at spectrum. And so that's why we're interested in this proceeding. Mid-band spectrum, as everyone knows, is really important to the 5G solution. And we think that an FCC auction is really the fastest, fairest and most efficient way to get spectrum out and make it available to all different kinds of players, including Charger. Thanks. And then finally, Stacey Pies, Senior Policy Counsel at Google. Stacey, what is Google's interest in wireless use of C-band? Why are we here? Why are you here? So you've heard from each of the participants on the panel a little bit about their particular interests as well. Google, we are not a network operator. We aren't building networks like Colleen and Ross's companies other than Google Fiber. We do have Project Fi or Google Fi, as it's known now, as an NBNO. But for Google, it's critically important that there is sufficient spectrum available for 5G. I know that's a really surprising thing. You know, we kind of joke internally about how if you sprinkle the 5G magic pixie dust on your argument, you automatically win. And in this instance, we're all making the 5G argument. The best way to ensure that 5G services are deployed in the US is to have an orderly efficient process for getting the spectrum out there available to potential users. So to meet this rising demand that continues to go up every day, we think C-band is essential in going to Michael's introductory points. Just pointing out where we vary a little bit in our positions, one of the reasons why Google is very engaged in this particular proceeding is because we care a lot about sharing. And we are the makers of the spectrum access system used in the 3.5 band. And we are a company that has the capability and the technology to create various types of databases or functionalities for sharing. So what we would like to see happen as proposed by the FCC is to allow point-to-multipoint sharing in the band immediately. We don't think there needs to be any delay for that. The spectrum access system, something a little more simplified from the CBRS system, can manage interference between the services. And we think that's critically important. We believe that these fixed point-to-multipoint services can deliver broadband to over 100 million people across the country, particularly in rural areas. But as we know, that's just the first step of the process. And the second step is reallocating the lower portion of the band to enable mobile broadband. That's a little more complicated. Reallocating spectrum is more complicated than going in and sharing. But we believe it is an important objective. And our concern is the same as my other co-panelists today. We believe that the private sale option proposed by the C-band alliance, although interesting, is not the fastest way to ensure that the spectrum is reallocated and that the public interest objectives and criteria that the FCC is charged with protecting are met. We think there's significant risk if the commission foregoes. If the commission foregoes a public auction in favor of reliance on a private administrator. Some of our concerns include that a private administrator would not optimize spectrum availability for 5G. And you've heard that a little bit from my other panelists. We also think there isn't anything built into the private sale process that would safeguard or even promote competition. And we're very concerned about that. Our goal as Google is to ensure that there's a vibrant ecosystem. And competition is what drives a vibrant ecosystem. Limiting the availability of spectrum to just a couple participants does not do that. And finally, we are concerned that the private sale that is proposed would not treat existing FSS licensing, licensees, and prospective terrestrial licensees equitably. We think one of the reasons why we're concerned about the private sale option is the commission would be shifting its responsibility. The commission has a responsibility, as I said, to protect the public interest. By shifting that responsibility away to private parties, there is no telling whether the public interest would be protected. And we've mentioned this already today. But for closing the opportunity for the federal government to have the funds from an auction, to go towards important policy initiatives is one reason why the private sale is a bad idea. Those funds can be used for rural broadband. And if you talk to members of both the Democratic and Republican parties on the Hill, they will tell you rural broadband, the infrastructure that's necessary for rural broadband, is a critically important objective. And I think we're going to hear a little bit more about that from the administration in tomorrow's State of the Union. So that's a non, that there's no argument there, but we need the funds in order to be able to support rural broadband deployment. And I think someone else already mentioned this as well. But the precedent that this private sale would establish where a user of the spectrum, not the owner, but the user of the spectrum, would be able to reap the rewards of a private sale means that in the future, the FCC, the federal government, would essentially have to go to the users of the spectrum and say, hey, cooperate with us. We want to reallocate that spectrum. It's better utilized for another purpose. So hey, work with us and do that for us. And we shouldn't be flipping that the current regime on its head. We shouldn't be giving the users of spectrum the ability to hold the FCC hostage, essentially, in order to reallocate spectrum for a higher and better use. So we would just urge the FCC and interested parties, as you're thinking about this, for the FCC to stick with the time-tested practice of allocating spectrum through an auction. We know it works. The commission knows how to run auctions. You mentioned trusting federal agencies. This is an area where we can trust federal agencies. The commission knows how to do it. And they know how to manage and run very complicated auctions. And we have faith that they can do this quickly. If the private sale option were to be adopted by the FCC, there's certain to be litigation. And litigation will slow the availability of the spectrum. And that goes against the number one argument that the Seabound Alliance has made as to why the private sale auction is the best option. So slowing the rollout of 5G should not be our solution. And we're very concerned about that. OK, thanks, Stacy. So I have some questions that I think, in some cases, you may have touched lightly on. But maybe we can get bore down a little bit deeper. So Stacy mentioned the magic pixie dust argument about mentioning a race to 5G. Never mind what 5G is exactly. So I think there's been this assumption that what's necessarily true is that deployments for mobile 5G anyway, not putting fixed aside, for mobile, that it'll be somehow much faster if there's a private sale directly to AT&T and Verizon in particular, to the big mobile carriers. And so I guess I'd love to hear if you have anything more to say, and as they say, and anyone else, about is that necessarily the case? And how should we view the competition aspects? I see at least one person here from T-Mobile, for example, who's saying, hey, what about us? So what about the speed to deployment and the competition aspects of this? How did they come in? Thank you, Michael. It's a good question, and I'll go back, even though it's not the subject of the panel, to the initial ability to share the spectrum, the point to multi-point service on an opportunistic basis, that will be first. That will be the fastest if that is something that the FCC adopts, and it is something that Google supports. Then the FCC concoction the lower portion of the band. And that's complicated. I don't think there's anybody out there who believes that's easy. As a matter of fact, the C-Band Alliance acknowledged, and I'll quote in their comments, that clearing the spectrum for terrestrial mobile operations will be arduous, complex, and costly. I don't think anybody's going to argue with that. So acknowledging that the actual clearing and making the spectrum available is the difficult part, the auction is not the difficult part. Yes, it takes time. Yes, the FCC will have to put procedures in place. But the FCC will have to put those procedures in place if there's a private sale. And one of the things that has been a little difficult and frustrating, and Ross alluded to this a bit, is that all the facts are not out there. What exactly is the C-Band Alliance planning? How will the public interest be protected? And not knowing what those facts look like, not knowing what the answers are, it inevitably slows the process. And it also creates some hesitation. Do we trust that when the FCC puts a process in place to facilitate a private sale, that there will be a full transparency of how that private sale will occur? All of these reasons are not to say, we don't trust the proposal, but the facts are insufficient facts and there's insufficient transparency. And if there were, you could lay it all outside by side with what the FCC's process is for an auction and timing would probably look relatively similar. The big difference is that there will be litigation if there is a private sale. And litigation can take a very long time. And this resource, the mid-band spectrum that is critical for 5G services, should not be caught up in litigation. The fastest way to ensure deployment is through an auction, an FCC auction. With that completely, that the litigation risks of the private sale proposal are high. And that's just why we think that an FCC auction is really the fastest way to get this critical 5G spectrum out into the marketplace. We think that a private sale could result in years of litigation or backroom deals with private companies. And because the spectrum is being reallocated for a new use, the Communications Act requires the spectrum to use competitive bidding to sign new licenses. Using this new way of doing it that is not at all supported by the law, we think is really gonna end up in litigation. And that, like Stacy said, tying this up in litigation is not in anybody's best interest as far as winning the global race to 5G, which I think is the magic words for the... Oh, global race to 5G, so. Yes, FG is the whole phrase. Yes, exactly. If you want the magic dust. So, which is why we are supporting an FCC auction. And we really think that if an FCC prioritizes an auction, using all the resources they have, they could complete an auction in 12 to 18 months and get 5G deployed in 36 months. It's the reason that with all of the resources the FC has and the X or Cs it has, that we couldn't meet that deadline. So, a quick follow-up on the buy side of the auction. So Charter, if you just heard Charter is a potential bidder, it's entering the wireless market. Are there other bidders that, because as I kind of said a minute ago, conventional wisdom is that the spectrum in a private sale is destined for a few national mobile carriers, the usual suspects. But what other bidders, I think people are thinking, what other bidders are there out there potentially? I think if you look at the reply comments filed in this proceeding, you can see the wide array of interest in the spectrum. I mean, I think there's lots of, there's rural, there's smaller carriers, there's cable, there's all kinds of people. This is a critical 5G spectrum. So the idea that there wouldn't be interest, I don't think that's an issue. I think if you look at the wide array of people who have filed in this proceeding, you can see there's lots of interest in the spectrum. And there's near certainty they would be bidding for the same spectrum, which seems to create mutually exclusive applications. Yeah, because a mutually exclusive demand would trigger the auction requirement normally under section 309J unless you fit into an exception. Yeah, and I would think we don't have WISPA here, the Wireless Internet Service Providers Association, but I know I've heard them say, for example, another decision that apparently the FCC would not make, would not be able to make under the scenario is, or could make, but it's not clear they would, license areas, because the smaller the license area, particularly for 5G, the more likely it is, we saw this in the citizens ban debate, right? You had, not only the rural broadband providers, but also the WISPs, but even, you know, like General Electric and big property managers and universities and so on, say, hey, if the license areas are small enough, we'd like the bid too for these Internet of Things networks that have a little more licensing protection in addition to whatever they do with Wi-Fi. So it's all kind of a, I don't know if it's a cart and a horse exactly, but unless the FCC gets a chance to make notice and comment auction rules, we won't know how many more bidders would have been interested. So let me go on to ask about, I think something nobody's gotten into yet, I mentioned it at the top was that the FCC's NPRM proposes, you know, this private sale possibility is maybe being speedier, but it also describes a potential incentive auction involving, for example, a reverse auction of transponder capacity. In other words, that not only the four satellite companies, but perhaps others could, you know, meet the need for video distribution, whether it's through fiber, through launching additional satellites using a different satellite band and so on. So I'm wondering if, kind of ask the press panel, is an incentive auction a viable alternative? And would the potential revenue that would then be available in a public incentive auction draw in some of these alternative substitutes for, let's say, the bottom 100 or 200 megahertz of the band? Well, we've seen how incentive options work, bringing in billions of dollars. Again, the FCC has done this, private companies have never done this, I'm not sure how they could even come up with the idea or the expertise or the resources to do something like that. I think it's a good idea, it's something they should certainly explore, and they have the authority to do this for another three years. So I just think the whole idea of doing this the way it's always been done, in this case makes sense, because there's a proven track record of success, money is gone where it's supposed to go. I don't think anybody's really complaining that the money's going to purposes for which it's intended, first responders, then left over for the help with the deficit. That's pretty clear in the legislation, dating back to this first issue of protesting against the idea of a private sale 18 years ago at this point. But ideas never really die in DC, they just come back and they try to revive them, but we need to do exactly what was done then, and that's reject the idea of a private sale. Any other thoughts on this? I mean, we appreciate all the work that Timo was putting into the incentive auction. We don't necessarily think that's required, I think the FCC has lots of auction authority. There's definitely simpler ways we can do this, and we can do it fast. The FCC has lots of resources as a disposal, so we can find different ways to do this. We agree that there's a way that people should be made whole, and reserve recipes to be set aside, but also, as Ross pointed out, we also have lots of video customers, and we wanna make sure that they are protected. So, as part of this, we definitely are concerned with how everything would shake out, how we are gonna make sure that everyone can be served going forward, but we think the FCC should be in charge of this, and should look at all ways, in the fastest way potentially, to get an auction out there, to make sure that we can get 5G out there and protect kind of existing interest. It's an interesting concept. I mean, certainly users, if they're going to be displaced by the sale of the auction, should be compensated for that loss, and maybe a cent of auction may be a way of doing that. However, the problem with it in this market is that the satellite delivery of programming is done on a nationwide basis. And so, if there was clearing of spectrum in the largest markets, where 5G may be most likely to be made available and not done in smaller markets and rural areas, that means the cost of the remaining C-band would be borne exclusively on those markets that didn't clear, which would cause some disproportionate harm for users in those markets, and could actually mean the collapse of the market in its entirety, where programmers just say, well, we're not gonna use C-band at all to deliver it to the 25 remaining markets. Good luck to them using fiber that they can get. So, there are complications in using an incentive auction for a national market like the C-band. Could the FCC do, and I think Colleen may have been hinting at this, but just as an option, I mean, could the FCC do the same thing here that they did with the broadcasters in the 700 megahertz band, or at least what Congress did, which I described the FCC tried to have an incentive auction that Congress rescinded, but ultimately what they did is they said, you know, you guys are spread out over too much spectrum, so they pushed the broadcast stations down below channel 52, and the first go round, they weren't compensated at all. They just said, you know, you have so much time to kind of move. The incentive auction that we had two years ago did provide relocation costs. So, what I'm wondering is, could the FCC conceivably just say, hey, you know, the bottom 100 or 200 megahertz are just no longer going to be available for this purpose after a certain date, and we'll compensate out of the money that's raised incentive auction of the type that you had two years ago with the broadcasters where there's a relocation fund where all the earth, any of the earth stations or any of the satellite operators that incur costs, you know, are made whole, but there's not actually necessarily a windfall at all. It's an interesting question. I don't know that Google has an answer specifically, but what it points out to us is that there needs to be FCC management of the process. The FCC has the economists and the engineers and specialists in auctions who can make those decisions, who can do a complete analysis, who can make a determination about how the auction should proceed, what type of auction there should be in order to maximize the value of the spectrum to ensure that the utility of the C-band is maximized, and we won't know if any of that is happening with a private sale. So it doesn't directly answer your question, but I think it points to why we have an expert agency who manages these types of processes. They can publish those answers in a further notice, they can explain, and they will explain why they're proceeding with the type of auction that they've decided is the best. Keeping incumbents whole, however that may occur. Stacy said whether it's an incentive auction of some other manner, the FCC knows how to do this. Sometimes Congress has to step in and change the process. They passed the Reimbursement Expansion Act last year to help out with some of the costs for TV translators to relocate to another channel. So they have the capability to use the money from the spectrum auctions, not additional taxpayer money in order to get this done in a way that protects the people that need help. A lot of obviously Ross's small cable operatives and others. Ross would either, if Congress or the FCC promised full reimbursement of costs for some sort of switchover in the lower portion, would that give you any greater comfort than a private sale transition led by the satellite incumbents in terms of them accommodating you on different satellites or different transponders and covering your costs? Look, our primary concern is making sure we're made whole. I mean, we haven't opposed the private sale outright and we think that if adjustments were made that better protected incumbent users and fully protected their rights, that that could be a viable way to go. But they just haven't done that yet, despite requests for that to be done over many, many, many, many months. And we're just led to believe at this point that that's not gonna be done. And so it pushes us to a position where the FCC might be the best way of resolving this issue. Let them do the analysis to determine what the harms are. Let them determine the best way to address those harms and let it be decided that way. So we've been on the fence, but we're starting to be nudged over to one side just based on the lack of responsiveness to trying to get legitimate concerns addressed. So Tom, I'm not sure you have the answer to this, but when we start with you, where is Congress on this issue? So in the past, I mean, you mentioned it in the past, Congress has been pretty hungry for spectrum auction revenue, whether it was to, initially, I remember Senator Markey has joked about being in a room where they said, Clinton needed a little bit more revenue to meet his goal for a balanced budget and to say that Europe, the government was over and they looked at Markey and said, how much can spectrum give us, right? And then it was used to pay for DTV converter boxes. It was used to pay for public safety this last time around. So where is Congress? By the way, again, it's interesting that this is one of the few areas where the money goes where it's supposed to go. It's essentially a user fee in some ways. I mean, I paid by the broad group of taxpayers might use a national park and the money goes back in, but it is kept in the area where it's supposed to be kept and used for those purposes. Obviously we like to have great oversight on how the money's being spent, which again would be missing from a private sale. Where's the oversight? The FCC has to step in and conduct the oversight over something that the private companies have no expertise to conduct. And as Stacy said, it would take longer if the FCC didn't do it because there will be challenges, there will be problems with how it's being done. Even as it goes along, then Congress has to step in again, maybe undo the potential sale. I think it runs much more smoothly and much more quickly if it's done as it has been done. There will be less of a role for Congress. If the FCC is involved, they might have some ideas about potentially some compensation that may not be occurring, but I don't see a lot of complications in this particular auction if it's done by the FCC. Is there any necessarily any need for Congress to legislate or the FCC has the authority? I know you don't necessarily have to know this, but in case you have any ideas on it. We believe the FCC has authority. Some of the, I'm not gonna speak on behalf of any members of Congress, but we have heard concerns along the same lines that all of us have expressed about the proceeds of the sale going to for foreign satellite operators. We've heard concerns about the scoring process. There wouldn't be a scoring process if there was a private sale. We've heard concerns about, several of us mentioned, the notion that the users of the spectrum would be able to dictate the terms of any future reallocation of spectrum. So those are some of the issues that have come up. None of those, I think, require a legislative solution. They do require the FCC to put procedures in place to ensure that there's a healthy, fair auction process. Okay. I don't wanna look right on where you need additional and not additional authority for the various different ways to do this. I think the FCC has a lots of authority and has lots of expertise to do this, but we are concerned that the private sale does not have the required authority and wouldn't need to lots of litigation, which will tie the spectrum up. So on that side, we're more certain. Okay. So shifting gears, Ross, you mentioned that a private sale or perhaps clearing too much of the ban too fast could result in higher cable prices for consumers. So can you explain why? I mean, is that a function of capacity or how does that work? Sure. And primarily, what I'm talking about is higher prices for the C-Band delivery of it with those costs then passing down through the chain. But the C-Band proposal says that they would reallocate 200 megahertz of spectrum, which is a reduction in the amount of spectrum by 40%, which means there's 40% less capacity to make available existing services. And the problem is that there's really limited opportunities available to compensate for those reductions. There's a limited number of satellite orbital slots in the sky that are available for C-Band, approximately 25, and today all of those satellite slots are currently occupied. So you can't launch any more satellites into the existing fleet. Now, some of them are at the end of their life and will likely be, based on statements from the industry, would not otherwise be replaced. And they could continue at the same time, continue to offer all the programming that they otherwise would offer. So if we say what the status quo is, maybe it's 21 satellites, maybe 22 satellites, that would be in operation. They could launch additional satellites to fill those slots that they otherwise wouldn't do. And that actually would make available additional excess capacity that the industry wouldn't otherwise use. It's in the range of 40 megahertz to 60 megahertz. But the CBA proposal says we're gonna make available 200 megahertz, which is a significant increase. And as I just explained, there's no more satellite slots in order to offer to launch satellites. So you can't make up for that lost capacity. It is just obviously a reduction in the total amount of capacity that is available to continue to serve existing customers. Now, the CBA have said we can make it work with the existing programming that we have offered with only 300 megahertz. And they say they take into account the launching of additional satellites to fill up all of those slots. The problem with that is, is that they go to a state of the market where they're each at near full optimization of the capacity that they have available. So essentially, they can't compete against each other because they have no excess capacity left to steal any of their competitors' services. And no new entry can come into the marketplace because there's no more satellite orbital slots for anybody new to come in to launch these satellites. They're going to operate in that state as if they are monopolists because their customers can't go anywhere else and nobody can steal their customers. They will drive up prices as a result of that. Their only constraint is that they drive up prices so high that programmers decide just to go to terrestrial delivery. And this is an issue that has not been of a focus at the FCC thus far. I think it's not been fully understood. But this is going to drive this, the remaining C-band marketplace, much, much higher than in prices than it currently is. And those are going to be born upon the users, earth station users and consumers. And going back to the private process that the CBA has proposed, they do not acknowledge this as being a problem. They offer no remedy for this whatsoever. And if they don't, then again, the FCC is in a much better position to evaluate the marketplace, identify the harms and come up with remedies to address them. Just to give Cohen a chance in a second, but just a quick follow-up on this. So what about these sort of, there's three other C-band satellite operators who don't currently, they filed in the docket. This is, I'm talking about Hispasat, ABS, there's a third one. They filed saying, oh, if there was an incentive auction for capacity that they could bring capacity, they could sell capacity that they could somehow repurpose or even launch more satellites. Is that, does that help? Or are they, or is it just really this fixed number of satellites orbital slots? Yeah, I'm not familiar with their specific proposal, but they're still only 25 orbital slots. They're currently, they're all gonna be occupied. You can't increase the amount to capacity that would be lost. I mean, physics just don't allow it to happen. So, they may have some other, I'm not sure exactly if they're planned, but you can increase giving away more than 40 megahertz of spectrum in this current marketplace is gonna lead to a reduction in capacity and there's no more additional satellites that can be launched to make up for that. Colleen, do you have anything to add? Like, for example, I'm thinking, what about as television moves to 4K and so on, is that take more capacity or? Our biggest issue with on the allocation side of the 200 megahertz, our really big issue is that why would we allow four private companies to decide kind of how much of this critical spectrum is needed for 5G and how much is it needed for existing services? And it seems to be a decision that relies solely in the FCC's realm and should be decided by them. There's lots of considerations on both sides, but the idea that we'd go through this multi-year process and have only 180 megahertz of usable 5G spectrum. We just wanna make sure the FCC is looking at all sides of this and really figuring out what is the best way to move forward. For all of the reasons Ross said, but also all of the 5G reasons. You know, this is an important spectrum. A lot of other countries are making much more of this, you know, we've gotten up to 500, I think other international countries are making much more. So, we don't know the answer, but I think it's something that the FCC should be deciding not for private satellite companies. Okay. We'll open it to the audience in just one minute because I have a feeling there'll be some lively discussion. But let me just say this one more thing because I think we went over this pretty quickly and hopefully, you know, Ross probably has some ideas, but what are, Ross, in your very first opening statement you mentioned that you thought the satellite incumbents, although, you know, they are really, you know, in a sense they're relaying the information, the video, radio, everything, from the content producers to your earth stations in the cable systems. So it would seem like they're part of the same industry chain. But, and their customers are the content companies, which is probably important to remember, you're not paying them. And that their interests would not, you mentioned that their interests would not align necessarily with earth stations if they stood to receive a net windfall that was equal to whatever, say, mobile providers would pay minus their costs. And you would be a cost in that equation. So, I mean, what are some of the kind of particular potential conflicts or uncertainties that concern earth station operators the most? I mean, I know you just mentioned, you know, capacity and cost, but is there anything else? Yeah, I mean, obviously one part of it, which I've already discussed, I won't go into again, is the remediation and their incentive to remediate fully our problems. I guess just more broadly, our concern in terms of incentives is just the finances of it. I mean, we have a satellite industry having 500 megahertz of spectrum that on the market to wireless carriers seems to be worth somewhere in the range of as much as $60 billion. And the existing business that's relying on that C-Ban amounts to about 320 million annually. And so if you kind of calculate what that means in terms of market value of using that spectrum for C-Ban uses is about $2 billion. So there is a strong incentive for the satellite industry to unload this spectrum today. They get a much better return on it. I think they are constrained in certain ways. They can obviously can't sell it and totally displace existing users. And so they are coming up with proposals to sell as much as they can. But, you know, long-term there are concerns about the future of this marketplace given those constraints and how existing users are compensated for it or transition to something else. And there's nothing about this plan and the sale and the amount of money that would be collected that takes any look at how we're going to manage existing users and what their future is going to be like in terms of delivering services today to 90 million consumers. I mean, it's an enormous amount of consumers that are dependent on this spectrum and there's not enough discussion over what it's going to mean to them. Anything else? End this? Okay. Well, let's open it up then and get some other perspectives here. We'll start with Preston. Please let us know. Go ahead. Oh, there's a mic. Colleen, you said you're worried you can't, you won't be able to get the spectrum because then Michael suggested it's wired for Verizon or something like that. We sent out 400 certified letters to prospective buyers, everybody who's filed in the last few proceedings. We flew six of our executives across the country to Denver to meet for half a day with your wireless people and we talked to them once a week as they assure us that notwithstanding your lobbying against the private sale, they definitely want to participate and we hope that they do. Several people mentioned incentive auctions and the TV incentive auction, they are of course voluntary. No TV station was obliged to participate in the auction. The unique feature here is that all of the C-band companies have equal access to all 500 megahertz. So for an incentive auction to work, you'd have to run the table. You'd have to have every carrier agree to participate and every carrier agree that they're happy with the price they're offering and the odds of that happening are essentially zero. Finally, there were several references to a government auction. I think people are kind of missing that in our proposal, we're gonna launch new satellites and install filters on up to 100,000 satellite dishes in the country because unless you do that, if you clear any portion of spectrum, you're gonna disenfranchise the current C-band users that folks were us is concerned about. And my question to everybody is if you think the government auction is a good idea, who in the government auction is gonna launch those new satellites and who in the government is gonna get in trucks with filters and wrenches and go around to 100,000 satellite dish locations? Thank you. Okay, so there's quite a few points there who wants to respond to parts of our overall personal UQ, so I think we'll let us go first. It's just a lie. We've never suggested any number in terms of what the harm we came in. We discussed with you what our concerns were. You weren't even in the room the last time we met. You said that there was no harm. That was the end of the discussion. I just have no idea what you're talking about. On behalf of Trotter, I'll say we have talked to you and continue to talk to you because we're interested in 5G and so with this as this process plays out, we think the best way for us to get access to Spectrum and for lots of people to get access to Spectrum is through an FCC auction. But we are business and so we need to continue to look at all options. So of course we continue to talk to you because as I said, we like 5G. So we'll continue to talk to everybody but we think that the best way and the fastest way and the quickest way and the way not to get this tied up in litigation is to go with an FCC auction. There's tried and true ways of doing it and we think that it's available here. So we're always happy to meet with you and we'll continue to meet with you, but... Pardon? Can I ask you a question? Can I jump in quickly? Oh, sure, sure. Just tell folks who you are, though. Elizabeth Andrea from Charter, I work with Colleen. Preston, to your point just to add on to what Colleen said, I was in those conversations with you by email with our executives who said we're very clear, we want an FCC auction. If that doesn't work and the FCC decides your way is the way to go, we want to play in 5G. We're very clear. We've spun it around to be something entirely different and said, okay, I understand you want to be part of our deal and our executive said that is not in fact true. I also think part of what's going on here and why we think an FCC auction is the best way to go is because exactly these kinds of misrepresentations. We hear that someone's conducting an FCC auction. That was what, 400 letters that were sent out when we expressed the interest, no specific details were given. So similar to Ross's point, we're not getting any specifics when we've asked for them. So again, we went to the point of an FCC auction is the best way to do this. But let's just be clear because I don't like the misrepresentations about what our company is doing. I would just note on one, I'm not even sure I remember all the points press me, but one is, I think this is really still unprecedented. I use the broadcasters as examples, but so for example, Spectrum Co, which was Time Warner Cable, Comcast, at least those two. I mean, they purchased that Spectrum at auction and then they sold the licenses to Verizon. It was no reallocation. They were flexible mobile licenses they purchased and then they transferred. And companies acquire other companies all the time that own Spectrum licenses and there's a license transfer, but there's never been the combination of a reallocation with an authorization for a private sale. I don't think so. Those were already terrestrial wireless licenses. Well, I don't think for that reason. I think it was because they had already defaulted on their build out requirements under those licenses and they thought it should be auctioned. So they were actually calling for a public auction. I know Steve has a question anyway, but he can clarify in this and ask a question, but go on, Steve. But tell us who you are because not everybody. Nobody else has had to. We've certainly disagree that this is like anything else that's been done before. All of those other transactions were, like Michael said, there were either four terrestrial licenses already that were sold. We had other problems with those deals. Use of and sale of other satellite Spectrum. You know, when ancillary terrestrial authority has been given to other satellite Spectrum, it's been under the assumption and promise that the satellite company is we're gonna do something with that Spectrum, not just given to a company to sell specifically for that reason. So, you know, it's not fair to say that this has ever been done before. You know, while I'm up here, you know, one of the things on an incentive auction and, you know, there, well, certainly, I mean, you said that everybody would have to agree on it. We've been working on a variation on our proposal for an incentive auction that would allow the earth stations to participate. So from our perspective, it doesn't matter if the earth stations stop receiving the transmission from the satellite where the satellite stops transmitting, we just don't have to protect them in that area. So you can certainly construct an incentive auction that would allow the earth stations to compete, to give up Spectrum, just like the satellite companies could. And then that would provide a return for some of the terrestrial users and give them some incentive and skin in the game and create a very robust incentive auction. Well, I'm also, well, I'm just curious in the private sale how much money is going to the taxpayers? What kind of check would be written by the CBN Alliance, $7 billion, $10 billion, $40 billion like the other sales? In this case, the FCC is gonna get, you know, the FCC and these other sales is collected billions of dollars used for public purposes, which is what should be done. Different situation. Totally different situation. Let's see first, I don't know if there's any reaction. I don't think we wanna give it of all secondary market sales because this is not a secondary market sale. They're different situations, so I don't see why it's true. Before we go on. So you've just admitted zero, we'll go to the taxpayers, thank you. That's what I was asking for. Yeah, well, yeah, and that's kind of a technicality of the Communications Act because it really, it was all or nothing until 2012 when Congress legislated the Incentive Auction Authority and under certain conditions, can the FCC share revenue? And that's why I think the Incentive Auction was put in the NPRM as a potential alternative, but as we've been discussing whether that's viable. So Steve mentioned, well, could earth stations participate in the Incentive Auction and compete with the satellite companies in effect to say, hey, we can all get together and stop using your satellites, and that would have the same effect of clearing this license area. So any reaction to that is one of the things that the FCC should be considering here. New idea, I don't think we thought about it. We're happy to look at everything, but we do think that the FCC should focus on finding the simplest way to get there. And so it could be something like that, but it also could be something, the FCC has, this is their spectrum. So there's lots of different ways for them to run this auction and they should look at all the different options and find the quickest and clearest way to do it so that we can all move on and get 5G deployed. Mm-hmm. Jim? Well, God, we thought that first we were. Jim Snyder, I wrote a book on the first spectrum robbery. My basic question is, anybody on the panel who believes that this mid-band satellite spectrum is gonna be repurposed without a multi-billion dollar giveaway to the industry to lubricate the deal. My reading of FCC is quite different than the general just here. The FCC is not this noble champion of taxpayers or the FCC, but the entire history is one of giveaways to facilitate any meaningful repurposing of spectrum. The case of auctions is highly misleading because the great cases are government auctions or guard ban auctions or deals where incumbents in an off-budget way get a huge increase in the spectrum rights and don't pay for it. And it's too complicated for the average person to understand perhaps many of the people even in the audience. But there are no cases of a heroic FCC in Congress championing the taxpayer and that actually to a remarkable degree includes industry which doesn't really give a damn whether the taxpayers get the money or industry as long as they can get it reasonably quickly and for their purposes they will always bend on giving the taxpayer a fair deal and of course the public is just not part of the picture. So the question is, is there anything different about this case? You can always parse the case very narrowly and suggest it is different in terms of the rights giveaway. But basically the FCC in Congress have no problem giving away rights to users in different ways. Is there something different about this case that will have a different outcome than that we had in the past? You know at the end that Congress and the FCC in industry will say there was no giveaway but I'm asking you, is there a way in reality we could end up without that same situation? I mean, what's different about this case meaningfully, politically? So Tom, we should, so I be honest I haven't read your book I'd be happy to do that but I think the point here is that whatever the FCC has or has not done it's still gonna be better than whatever is going to occur when a private company sells something that doesn't own and that's really the point. The license is not property and however it came out in your view whether it wasn't enough for the taxpayers or whether the companies got away with something the fact is the industry is leading the world in 4G we want to lead in 5G and while we prefer to get every single penny possible as I said I think the alternative is certainly gonna have a worse outcome and we have countries around the world that don't have to sit here and talk like this not that there's anything wrong with us being in a democracy and having these discussions but the Chinese are not sitting in this room arguing over who gets to sell it and who gets to use it and how it gets deployed and that's another point that we have to consider so you may not think it's perfect we may have issues here and there or other people may have issues but the fact is it's the best we've got and it's better than what they're proposing. I would note that and I said in my opening statement that I think the FCC given where they sit their purpose they're always looking for the way that they think is most expeditious for the telecom industry and which is why as I said for 3G they were willing to let Bud Paxton's Spectrum Clearing Alliance have a windfall and Congress disagreed so I think that when you read the NPRM that seems to be their inclination but one reason I mentioned that the FCC has the authority to simply consolidate the band to simply move the satellite operators up higher in the band without any payment at all is to sort of highlight that an incentive auction is actually sort of a middle ground that Congress has already authorized. In the UK for example, not long ago again this downlink C band 500 megahertz was across most of the world and in the UK what they did is with the lower 100 megahertz of the band so from 3700 to 3800 they just said you can't use it anymore. Sorry and so they don't after a certain date they don't have any interference protection and so what that means is that they're going to have they're gonna move up in the band just the way the broadcasters in 700 megahertz had to move down in the band because they were simply spread out too widely. Now I don't trust the FCC necessarily to come to that conclusion because they're looking as you said for the least friction what's the best lubricant, you know tax payers notwithstanding but you know Congress could very well get interested particularly if this is money to pay for rural broadband infrastructure. Yes Jane. Hello I'm Jane Lee with Public Knowledge and thank you for the informative conversation today. So I since Tom you mentioned China I kind of want to frame my question around the global race to 5G and I know Colleen you mentioned like we could the FCC could prioritize this particular auction and make it happen in 12 to 18 months. So what can we do to ensure that the FCC fully exercises the authority to prioritize this particular auction over other auctions that are in line given that other auctions have taken a long time and I feel like having the authority and exercising the authority are two different things so. I'll just start by saying I don't think this FCC has any problem with understanding the importance of the spectrum band. I think that you know they would like to move on this as my understanding as soon as possible as would most of us here. So I don't think that that's really that we'd have to be concerned that this wouldn't be prioritized. They have lots of resources at their disposal. I don't see why we would wait on this. Well yeah I just agree I mean it's nothing it's up to them to do it more quickly and it's up to groups that want them to do it more quickly to encourage them to do that and give them some a little push would be helpful. And you know the importance of mid band and the fact that it's at least between 3,400 and 3,800 is globally harmonized for 5G is gives them a really strong impetus to move this quickly no matter which way they go. Made extra complicated for them. I think that what it started as what seemed to be a simple way of going about it I think parties that have been involved in the process have made it incredibly difficult for the FCC to find a path forward. There has not been the coalescing of support for the private sale. I think largely because the satellite industry has not sought to find any compromise on any proposal that they've had. And so they put the FCC in a very difficult position of choosing between two different sides and I think as a result we've seen the chairman make statements more recently that has said this is a very complicated proposal and we don't really know where and so I don't wanna put words in his mouth but it just seems like this is gonna take a lot longer than anybody originally expected and I don't see that necessarily speeding up if parties are gonna continue to stay on their sides and not acknowledge reality of what this is going to mean for the public and for consumers. I think I have time for one or two more. So all the way right there and then we can come back up to the front. Hi, this is Kelsey Griffiths of Law 360. My question is for Colleen and Stacey. Did I hear a commitment that Google and potentially Comcast might sue if the private sale does go through? Or were you just saying that parties are likely to sue? No, you did not hear a commitment that Google would sue. Yeah, no, I didn't comment to anything. The observation that I made is that because this is a novel approach, because there are many parties who have interest here and because it doesn't seem clear under the law that a private sale that is a reallocation of spectrum for satellite spectrum for terrestrial use is permitted that inevitably there will be lawsuits. Thank you. I'm not usually allowed to speak, I'm gonna have a Comcast but they definitely, no, I can't answer for the charter but I would say that as Stacey noted, you know, everything has to be in place that people, there's gonna be mutually exclusive applications. I don't see how that doesn't happen. Everybody wants this spectrum. So there seems to be clear statutory problems. No, don't count out public interest advocates either. Since it's a lot of money at stake for the public and for rural broadband. Do you have a question here? So Joe Cain with the ArchVid Institute. It seems like one of the main things that people do agree on is that the spectrum is currently misallocated in some way and it seems that to me that like the main benefit of reallocating things in the marketplace is that it moves them to their more productive uses. So I worry that if you start diverting some of that revenue away we'll end up allocating less spectrum to these new uses that everyone agrees is what we need. Are you at all concerned about that that we'll end up with less spectrum getting reallocated if we go with one of these other methods? I think you made the opposite point in a way or that you're gonna go ahead and speak for yourself. Well, you kind of trailed off at the end that you said these other methods. I think if you're diverting revenue away to the government or something like that then. You're right, I did make the opposite point. That we believe that under an FCC auction where the rules of the road are made very clear that there's greater incentive for participation, widespread participation in the auction and greater incentive, greater opportunity for allocating the spectrum to its highest and best use. That's the purpose of an auction, right? So we think that we are concerned, we don't know what the outcome of a private sale would be but we are concerned that if you only have a couple parties sign up to negotiate the 400 letters that have been sent out I don't think 400 people are gonna sign up to participate but it's an interesting effort. That you just have a couple parties and there's different incentives and then you're not going to have robust competition. There won't be pressure nationwide and then the spectrum is not being used most efficiently. There's also the question of participate in what? Yes. Because if I was the incumbent trying to sell the spectrum I would do it on a kind of a wholesale basis, right? The easiest thing is go to the big companies and get, they'll pay the most if you give them a big contiguous block nationwide, for example, which is not what 90% of the potential bidders want, right? So it really is where the FCC, it's a point I made earlier, probably too vaguely, that we just had a huge debate over the past year in reference to the band immediately below this about whether the license areas should be smaller, particularly going into 5G, because 5G is not going to get, mobile 5G is not going to get built out for many years outside of the inner suburbs. It's urban, it's inner suburban and Verizon's announced plan, for example, Wall Street, says, thank God, they're not making a Fios mistake again, they're not going to go up beyond the middle suburbs into those ex-urbs, small towns, rural areas. So, and then there's all the enterprises and venues from sports stadiums to business campuses, colleges, everybody, ports, libraries that want to have their own internal 5G networks if they could with licensed spectrum. So, you know, there's still, I mean, who's going to decide whether the licenses are affordable enough, whether they're small enough, whether they're localized or they're national. If a private company's doing it, if I were them, I'd sell it wholesale to some big national providers, which kind of closes the door, which is, I think a couple of comments said that earlier. Yeah, no, I'll agree, that's our concern. You know, why we would let four private companies decide how much of the spectrum is available. We think the FCC should be in charge of deciding how much of it is made available for 5G, how much, how it's licensed. And then really the FCC auction is the tried and true way of figuring out how much it costs, it lets all companies kind of make decisions in the free market as to how much they want to pay for the spectrum. We don't think that that back room deals by four private companies allows that. So when we talk about putting it to its highest and best use, we think an FCC auction is the best way to do that. Okay, we're right at the ending time, so I think we will. And I'm sure probably most of the panelists will stay a couple of minutes if you have other thoughts for any of us. And I just wanted to thank, first thank the panel for doing this today, and to thank all of you for attending and hanging in for the whole thing. Thank you.