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The Ugliness of Privacy Notices
My concern is that the arguments favoring spectrum "efficiency" raise significant concerns. I can basically agree with your statement that: "As we have seen, the spectrum cannot be traded and it can only be used for public safety communications. This policy in effect insulates public safety agencies from the true opportunity cost of spectrum." However, it neglects the fact that the spectrum is already in private ownership, held in trust for the American people. By implication, it would appear that you are advocating that commercial interests have a right to expropriate property should they believe it is under utilized. For example, should a developer who constructs apartments have a right to expropriate property containing single family homes because the property is not being efficiently utilized? I think not.
The FCC is responsible for managing the radio spectrum. If spectrum is being underutilized, the FCC should, just as any corporation, maximize revenue by leasing that spectrum to commercial interests.
'Spectrum is held in trust for the American people.' "The FCC is responsible for managing the radio spectrum." You're making positive statements. I'm making a normative argument. Go read Peter Huber's Law and Disorder in Cyberspace before you make that same tired point yet again.