Missing the Boat?

EWA will be filing Reply Comments on June 11 in the EB/GB 800 MHz proceeding in which the LMCC has asked the FCC to provide a six-month period for incumbents in a market to request those channels prior to accepting applications from new entrants.  Virtually all of the Comments in opposition were filed by individuals and organizations that selected their positions from a Chinese-restaurant like menu of five potential arguments prepared by someone who appears highly motivated to stop this LMCC initiative. How do we know that?  Well the risk you run when orchestrating these kinds of “mass filings” is that someone won’t follow the directions or, as in this case, will follow them too carefully.  One person who filed in opposition also submitted the filing instructions themselves, including the five arguments from which they were to choose, which the FCC dutifully posted in its electronic database. Of note, a seemingly critical directive was that, “When you file comments too early, those that support the LMCC Petition will read your comments and reshape their comments in a way that will diminish the value of your comments. It is sort of like war … don’t let the enemy know your hand until you are ready to strike.”  And strike they have!  A few of our favorite salvos from the “opposing forces” include “it is apparent they (LMCC) are advocating a monopoly for current licensee (sic) holders.”  Another states “that the majority of its (LMCC) constituents and incumbent 800 MHz SMR operators failed to apply for 800 MHz EB/GB frequencies in the early round and now … have suddenly decided to change their point of view to achieve an advantageous position.” One complains, “If you (FCC) pass it, your actions are corrupt in favor of the incumbents.” (Accusing the FCC of potential corruption isn’t normally recommended as an effective advocacy approach, but who are we to judge?) And, of course, the enlightening observation was made that the “majority of its (LMCC) constituents … flat out missed the boat and did not care to apply but now they suddenly reverse.”  What boat was that? EWA will find a polite way to respond to these and other comments that border on the senseless