RTG, The Rural Wireless Advocate, filed these comments today with the FCC.

Congress has instructed the FCC to structure spectrum auctions that promote the dissemination of licenses to small businesses and rural telephone companies. Rural telephone companies, including members of RTG, know what it means to provide service to rural areas, and are ready and willing to do so. By proposing to license AWS H Block spectrum on an EA (or even nationwide) basis, the FCC risks the wholesale exclusion of access to AWS H Block spectrum by small and rural telephone companies, which would harm rural consumers. To meet its statutory obligation, the FCC should license the AWS H Block on an MSA and RSA basis. The FCC can further promote economic opportunity for small rural telephone companies and further promote competition by offering bidding credits to an additional category of small businesses.