Arguing that FCC plans calling for the reauction of the 700 MHz D-block on a nationwide or regional basis are “unworkable for large municipalities,” six major cities urged the FCC to abandon the reauction in favor of allocating the spectrum directly to “locally-controlled public safety networks that are tied together on the basis of interoperable national standards.” The ex parte letter, filed jointly by the cities of New York, Boston, Denver, San Francisco, Seattle, and San Jose, California, addresses a further rulemaking notice issued by the FCC in September, that concerns the disposition of the 700 MHz D-block license that failed to sell during the 700 MHz auction last spring. Under rules in force during that auction, the D-block license had been earmarked for a hybrid nationwide wireless broadband network to be shared by commercial and public safety users. In addition to seeking comment on the possibility of a regional licensing scheme, the FCC is soliciting input on other proposed rules that are intended to encourage commercial bids for the D-block license, such as a 50% reduction in the reserve price, less stringent coverage requirements, and an extension of the build-out period from ten years to fifteen. In their joint filing, the cities warned the FCC that, “by sharing the spectrum that was allocated to public safety with the proposed D-block bidders . . . while also lowering the performance/coverage requirements of the system, you are designing a system that fails to serve the critical performance needs of public safety.” Characterizing the proposals contained in the further rulemaking notice as “critically flawed,” the cities therefore called on the FCC to “stop plans to auction the D-block and return the public safety spectrum to those charged with protecting the safety of our constituents.”