In a white paper filed in the FCC’s 700 MHz D-block proceeding, Verizon Wireless reiterated its support for licensing D-block spectrum directly to public safety entities. The company presented a plan calling for an interoperable “network of networks” that would give the public safety sector maximum flexibility to develop dedicated and/or shared systems that best fit local or regional needs. In the wake of last year’s D-block auction failure in which no bidder came forth to offer the FCC’s reserve price of $1.3 billion, the FCC is considering changes to the D-block rules that, instead of mandating a single, nationwide broadband network to be shared among public safety and commercial wireless entities, would re-auction D-block frequencies on a nationwide or regional basis. While admitting that the goals of public safety “could largely be met through the construction of a new national network,” Verizon told the FCC that, based on last year’s auction result, “the cost of such an approach is likely prohibitive.” Although the FCC has proposed lowering the reserve price and relaxing construction requirements in hopes of attracting a commercial bidder, Verizon added that, “based on the comments the FCC has received . . . another auction based on more economically realistic requirements may not satisfy all of public safety’s needs.” As such, Verizon recommended that the FCC abandon its auction plan and instead award D-block licenses directly to public safety on a regional basis to enable public safety to “control the use of the spectrum to meet its needs.” According to Verizon, these licenses should form a “network of networks” that could be dedicated or shared depending on regional needs. Emphasizing that “any effective public safety communications solution must ensure interoperability,” Verizon said the FCC and/or the Department of Homeland Security “could set a basic national framework . . . that would set parameters to ensure national interoperability and could condition spectrum licenses on compliance with those standards.” To leverage existing commercial infrastructure and to save time and money, Verizon also called for the establishment of public-private partnerships that could be pursued through requests for proposals or other competitive means. The company further urged authorization of public funding to “meet public safety’s reliability and other technical requirements in certain rural and high cost areas,” noting that “such funding would also advance the goal of providing broadband coverage to those communities that do not now have it.”