Information Technology & Innovation Foundation Comments to the FCC In Re: Delete, Delete, Delete

The Information Technology & Innovation Foundation submitted remarks to the Federal Communications Commission in response to the In Re: Delete, Delete, Delete request for comments. Some of ITIF's recommendations:

• The FCC should delete barriers to secondary market transactions for spectrum licenses: While some transaction costs are unavoidable, others are creations of the Commission. Since productive spectrum use is the core of the Commission’s public interest functions, it should declare that all leases, transfers, partitions and disaggregations of spectrum licenses are presumptively allowed and require a strong showing of public interest harm before stepping in to review such a transaction.
• The Commission should sunset the High-Cost Fund: The High-Cost Fund is a legacy program in need of dramatic distribution reform. Even since it transitioned to funding rural broadband, the broadband ecosystem itself has outrun the High-Cost Fund’s purpose. With the advent of the Broadband Equity, Access, and Deployment program and other recent federal funding efforts, the landscape of rural broadband has fundamentally changed.
• The FCC should evaluate the necessity of the Wireline Competition Bureau: The Wireline Competition Bureau is the largest of the Commission's Bureaus, but the communications marketplace is dramatically different today than during the heyday of the Commission’s management of a wireline telephone monopoly and its aftermath. Today, the broadband marketplace has grown into a vibrant and competitive market as extensive private investment drives increases in consumers’ quantity of and quality of broadband services.