COMMENTS: Unlicensed White Space Device Operations in the Television Bands

“Broadband Connects America (“BCA”), a coalition of nonprofit groups dedicated to closing the rural broadband divide, submits these comments in response to the Commission’s Notice of Proposed Rulemaking (“NPRM”) in the above-captioned proceeding.1 BCA is a diverse group of organizations representing the voice of rural America in the fight for affordable broadband and connectivity.2 BCA’s goal is to close today’s unjust digital divide by ensuring reliable, consistent access to the internet and the economic opportunities it provides. BCA generally supports the TV White Space (“TVWS”) rule changes proposed in the NPRM, but we also urge the Commission to go further to update and strengthen the utility of TVWS technology to help narrow the digital divide in rural, tribal and other hard-to-serve areas.”