On June 2, 2020, Next Century Cities signed on to reply comments submitted by the Public Interest Spectrum Coalition, a coalition of consumer and rural digital equity advocates, technology companies, rural wireless internet service providers, and free market groups. The filing highlighted how changes to the rules governing TV White Spaces could help promote broadband access. Advocates emphasized the following points:

• There is strong support for authorizing or requiring white space databases to employ Terrain-Based and Other Real-World Propagation Models to expand service to additional areas where doing so would otherwise be precluded by outdated models and assumptions.
• The Record strongly reflects support for higher power, a higher HAAT limit of 500 meters, and an easing of the “Less Congested Areas” rules. 
• There is wide support for authorizing higher-power WSDs on moveable platforms that can operate within a geofence. 
• The record reflects support to permit higher power levels for fixed devices in adjacent channels to increase the efficiency of TVWS spectrum.
• The Commission should authorize directional antennas for fixed point to multipoint deployment strategies. 
• Commenters support the creation of a New Class of Narrowband White Space Devices. 

TVWS spectrum allows for communities, anchor institutions, schools, libraries, and individuals to expand connectivity to individuals in rural, Tribal, low-income, and other hard-to-serve areas. Next Century Cities will continue to work towards widespread connectivity with a specific focus on developing ways to bring the nation’s most vulnerable populations online. TVWS solutions can provide meaningful access at a reasonable cost in areas that are still waiting for solutions.