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Congress should consider improving the CSEA to ensure that a full range of costs are covered to provide federal agencies adequate incentives and assistance, including up-front planning, technology development and staffing to support the relocation effort. Further, agencies should be compensated for using commercial services and non-spectrum-based operations, in addition to dedicated spectrum-based system deployments. In particular, Congress should revise the CSEA to provide for payments of relocation funds to federal users that vacate spectrum and make use of commercial networks instead of alternative dedicated federal spectrum. Expanding the definition of reimbursable costs to include a federal incumbent’s costs incurred to obtain telecommunications services from another existing network will promote agency use of shared commercial infrastructure, thereby freeing federal spectrum to be licensed for broadband deployment.

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The second newly emerging business model, mobile DTV, could serve as a potential evolution path for broadcasters to fixed/mobile and broadcast/broadband convergence. In particular, broadcasting popular video content to mobile devices may help offload growing video streaming traffic from mobile point-to-point broadband networks. As of July 2009, approximately 70 broadcast stations serving 28 markets had announced plans to begin mobile broadcasting through the Open Mobile Video Coalition. The business model for mobile DTV is uncertain, with forecasts and comparisons to domestic and international examples representing varying points of view. Many entities are pursuing the delivery of television content to mobile devices, but the method of delivery that will be favored by consumers and be successful in the market has yet to be determined.


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Achieving this vision will not happen automatically. Indeed, significant changes to the existing regulatory structure will need to be made, including adjustments to existing USF support mechanisms to redirect funding away from supporting single-purpose voice telephone networks and toward supporting integrated, multifunctional broadband platforms in a more efficient manner. Additional capital must be directed toward broadband infrastructure. The plan sets forth a pathway to shift up to $15.5 billion (present value in 2010 dollars) over the next decade from the existing USF High-Cost program to broadband, with up to $11.5 billion specifically focused on broadband deployment in unserved areas. By implementing this plan as written, broadband will be available to more than 99% of the people in the United States by 2020.

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Flexibility for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L-band, and the 1.6/2.4 GHz Band; Review of the Spectrum Sharing Plan Among Non-Geostationary Satellite Orbit Mobile Satellite Service Systems in the 1.6/2.4 GHz Bands, IB Docket No. 01-185, Report and Order and Notice of Proposed Rulemaking, 18 FCC Rcd 1962, 1964–65, para. 1 (2003).

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Clearwire states that 120 megahertz of contiguous spectrum is needed for true mobile broadband. John Saw, Senior Vice President and Chief Technology Officer, Clearwire, Remarks at FCC Spectrum Workshop (Sept. 17, 2009), available at . Fibertower argues that 100 megahertz or more of spectrum will be needed for wireless backhaul in the next few years. Tarun Gupta, Vice President of Strategic Development, FiberTower, Remarks at FCC Spectrum Workshop (Sept. 17, 2009). T-Mobile’s smartphone customers use 50 times more data than its average non-smartphone customers. T-Mobile Comments in re NBP PN #26 (Data Sought on Uses of Spectrum—NBP Public Notice #26, GN Docket Nos. 09-47, 09-51, 09-137, Public Notice, 24 FCC Rcd 14275 (OBI 2009) (NBP PN #26), filed Dec. 22, 2009, at 4. Verizon Wireless states that it might acquire more than 100 megahertz of spectrum within the next five years, if it were available. Bill Stone, Executive Director, National Strategy, Verizon Wireless, Remarks at FCC Spectrum Workshop (Sept. 17, 2009), available at . WCAI states that 100 megahertz of new spectrum would be a substantial beginning for mobile broadband wireless providers to meet future needs. Wireless Communications Association International Reply in re NBP PN #6, filed Nov. 13, 2009, at 4.

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See, e.g., Letter from Ken Pfister, Vice Pres.–Strategic Pol’y, Great Plains Communications, Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 09-51 (Dec. 8, 2009) Attach. at 6 (arguing that the United States cannot afford to support more than one network; support should be targeted to where the market will not work); California Public Utility Commission Comments in re NBP PN #19, filed Dec. 7, 2009, at 6 (arguing that USF should provide support to only one provider in a given geographic area); Qwest Communications International Inc. Comments in re NBP PN #19, filed Dec. 7, 2009, at 3 (arguing that only a single provider of broadband, regardless of technology, should receive support);Maine Public Utility Commission and Vermont Public Service Board Comments in re NBP PN #19, filed Dec. 7, 2009, at 4; Charter Communications, Inc. Comments in re NBP PN #19, filed Dec. 7, 2009, at 5; see also Comprehensive Reform Recommended Decision, 22 FCC Rcd at 20481–82, para. 15 (recommending that Broadband Fund provide funding for "only one provider in any geographic area").