Dish opposed incentive auctions and shifting the AWS-4 uplink band,...

auctions in bands that lack competing licensees, Dish said. Even if incentive auctions were available for the 2 GHz band under the Communications Act, such an auction for Dish’s 2 GHz spectrum wouldn’t be truly voluntary because “Dish would be coerced into this course of action on pain of not securing expanded terrestrial rights,” it said. Shifting the AWS-4 uplink band would cause delay and reduce spectrum efficiency, Dish said. The move isn’t necessary because “the combination of reasonable constraints on S-Band and H Block operations proposed by Dish provides sufficient protection for both operations,” Dish said. It also reiterated its recommendation of building out over a four-year timeframe to serve 60 million people and a seven-year timeframe to provide coverage to 200 million people (CD May 18 p6). The National Rural Telecommunications Cooperative opposed MetroPCS’s opposition to granting Dish the authority. MetroPCS opposes it “on the erroneous assumption that the sharing of spectrum by separate terrestrial and satellite licensees is technically feasible,” NRTC said. The bigger risk is the interference the terrestrial use would cause to the satellite signal, it said. NRTC said it supports harmonizing the 2 GHz band rules with other bands and relevant standards organizations and establishing interference protection. The Rural Telecommunications Group is concerned about Dish, a large wireless carrier, “entering the marketplace without the FCC adoption rules and regulations to promote competition and to protect rural consumers.” RTG urged the FCC to require Dish to count a rural carrier’s population toward its buildout requirements “to encourage Dish to effectively partner with rural carriers.” U.S. Cellular urged the commission to ensure that the AWS-4 technical and service rules “do not impair or delay other spectrum bands urgently needed by wireless carriers.” It agrees with the public interest organizations that “unjust enrichment penalties would mitigate incentives for Dish to ‘flip’ the spectrum,” to Verizon or AT&T, “which would lead to a much more heavily consolidated mobile broadband environment,” it said. Without auctioning 20 MHz and/or imposing strict wholesale access and roaming conditions, “Dish could monopolize this significant swath of spectrum, a result the commission has previously sought to avoid.” LightSquared opposed suggestions of Deere and the U.S. GPS Industry Council for more stringent out-of-band emission limits on terrestrial operators: The FCC should reject these proposals and “focus future efforts to protect GPS on examining GPS receiver reliability standards."