Before the
                FEDERAL COMMUNICATIONS COMMISSION
                     Washington, D.C.  20554
In the Matter of
Petition of SBC Communications Inc. for the
Waiver of the Eligibility Requirements of
47 CFR Section 24.709 for the PCS
Frequency Blocks C and F Auction to
Begin on July 26, 2000
Reauction of Certain C and F Block Broadband
PCS Licenses; Petition by Nextel Communications,
Inc. for  Expedited Rulemaking or, in the
Alternative, Waiver of the Commission's Rules
DA 00-191
                     Comments in Opposition
     The Office of Advocacy of the United States Small Business
Administration ("Advocacy") (1)files these comments in opposition
to a petition for waiver filed by SBC Communications Inc.
("SBC") and a petition for expedited rulemaking or waiver filed
by Nextel Communications, Inc. ("Nextel"), each seeking big
business participation in the upcoming re-auction of Personal
Communications Services ("PCS") C-Block licenses, which have been
set aside for the exclusive use of small business.
1.   Summary and introduction.
     For years, Nextel has been circling the C-Block, attempting
to sink its teeth into this valuable spectrum.  Now, as the
Federal Communications Commission ("Commission") prepares to re-
auction a large number of C-Block licenses cancelled for non-
timely payment, Nextel is trying again.  Nextel and SBC asks the
Commission to reverse its well-reasoned and thoughtful prior
rulings so that they can expand their spectrum and services.
Nextel and SBC hope to persuade the Commission that small
business has no place competing with big business in the
provision of broadband PCS.
     Nextel and SBC regurgitate arguments that have been raised
in the past, arguments the Commission has repeatedly and rightly
rejected, to persuade the Commission essentially that failure by
NextWave Personal Telecommunications, Inc. ("NextWave") to pay
for its licenses demonstrates that small business cannot
compete.(2) But NextWave's failure to pay for its licenses on
time does not mean, as Nextel argues, that small business has
been afforded a realistic opportunity to provide broadband PCS
services or that small business should no longer be granted
exclusive access to the C-Block.  Nor does it indicate that other
small businesses, upon re-auction, would bid sums they cannot
afford.  In fact, the Commission's experience from past spectrum
re-auctions belies this.  Since eliminating installment payments,
C-Block licensees have paid for their licenses and many are
providing competitive services to customers.
     SBC and Nextel argue that their participation in the re-
auction will spur competition.  This is incorrect.  Quite the
opposite will occur.  SBC is one of the largest PCS operators in
the country.  Permitting large players to expand their spectrum,
or expand their service offerings, at the expense of small
business participation, will effectively reduce the opportunity
to promote diversity in the marketplace.  This is a realistic
danger as large companies like SBC continue to merge with other
communications service providers.
     Increasing the variety of market participants, by including
small business, will increase competition on the supply side of
the equation.  Increasing competition will bring innovative
products to the marketplace.  As for small businesses as
customers, when they have but a few large service providers to
choose from, their product and service choices are limited and
the cost of service is high.  High cost and poor service choice
have a significant negative affect on small businesses as
customers.  Small businesses represent ninety-five percent of all
American businesses, and small businesses tend to have limited
resources, which renders them vulnerable to high prices.  Thus,
small business customers are in particular need of the benefits
of competition in telecommunications, to lower prices and
increase choice.
     Small businesses play a crucial role in experimentation and
innovation, which lead to the development of new technologies and
the growth of economic productivity.  Small businesses create
virtually all new jobs and serve as an essential mechanism for
entry by millions of people, including minorities, women, and
immigrants, into the American economy.  Given the tremendous rate
of mergers and alliances between large companies, small
businesses are the best hope to provide competition and choice of
under-served areas.  Congress has recognized this.  Congress saw
that disseminating spectrum licenses among a variety of
applicants, notably small, minority, and women owned businesses,
would increase competition and bring innovative technologies to
the American consumer.  Congress also saw that small businesses
(including minority and women owned businesses) do not have ready
access to capital or the resources to acquire telecommunications
licenses, for reasons unrelated to their ability to provide
competitive services.  Therefore, Congress directed the
Commission to consider special incentives to promote economic
opportunities to address financial market imperfections and to
compensate for the lack of ready access to capital.  With the
passage of the Telecommunications Act of 1996, Congress began to
unlock doors to telecommunications markets that had long been
dominated by one or two large firms.
     The Commission should continue to promote Congress's mandate
that small business be ensured a realistic opportunity to compete
for broadband customers.  The Commission has concluded that only
insulating small businesses from large business bidding resources
will afford small businesses an opportunity to compete in PCS.
Nothing that has occurred since 1994, or since last year's C-
Block re-auction, has changed this fundamental fact.  And the
Commission's public policy goal of promoting a competitive
marketplace, a premise of the Entrepreneurs' Block, remains
valid.
     The Commission should not be swayed by argument that re-
auction to small business entrepreneurs will not yield the $8
billion that Nextel would pay for NextWave's licenses.  It is
unclear what price these licenses will bring upon re-auction, but
maximizing revenue is not the goal of the C-Block.  Excluding
unlimited large business resources is precisely the point of
insulating the C-Block.  Small business is bringing competition
to broadband PCS markets.  This trend can and will continue, as
existing systems grow their customer base, as new licensees
launch systems, and as the Commission re-auctions additional
licenses to small businesses.  But this trend will stop, and
broadband PCS will become the sole domain of large companies, if
the Commission pits small business against large business in
bidding competition.  The Commission should preserve the
integrity of its auction processes by offering the subject
licenses to small business in accord with its existing rules.
     To summarize, small business is the lifeblood of the
American economy.  Small business telecommunications providers
are the ones which can bring innovation to the marketplace, and
small business customers are the ones who benefit from
competition.  Thus, it is vital to the development of an
innovative marketplace that the Commission foster the
participation of a variety of service providers, not just a
handful of national operators.  It has been an important public
policy objective of the Commission and of Congress to promote
diversity of product and service offerings and to create an
atmosphere where many players, including small businesses, women-
owned businesses, and minority-owned businesses, can participate
in the competitive marketplace.
2.   Small business needs exclusive access to spectrum to compete
     in PCS.
     Nextel and SBC argue that small business has difficulty
attracting capital.  Advocacy agrees, as do Congress and the
Commission:  "Congress has recognized that "small business
concerns, which represent higher degrees of risk in financial
markets than do large businesses, are experiencing increased
difficulties in obtaining credit.""(3) In fact, it is for this
very reason that Congress mandates that the Commission afford
small business the opportunity to participate in the provision of
wireless services.(4)
     The Commission interpreted this congressional mandate to
require it to take steps "necessary to ensure that designated
entities have a realistic opportunity to obtain broadband PCS
licenses."(5) The Commission also recognized that while "auctions
have many beneficial aspects, they threaten to erect another
barrier to participation by small businesses and businesses owned
by minorities and women by raising the cost of entry into
spectrum-based services."(6)
     Thus, the Commission set aside the C- and F-Blocks for
exclusive participation by small businesses.(7) In past auctions,
the Commission had used other methods, like bidding credits, to
ensure small business participation.  But it recognized that
bidding credits would not be enough to ensure participation by
small business in the provision of broadband PCS, "because
broadband PCS licenses in many cases are expected to be auctioned
for large sums of money in the competitive bidding process, and
because build-out costs are likely to be high."(8) The Commission
did "not think bidding credits in an uninsulated block would have
a meaningful effect."(9) The Commission found that "small
entities stand little chance of acquiring licenses in these
broadband auctions if required to bid against existing large
companies, particularly large telephone, cellular and cable
television companies.  If one or more of these big firms targets
a market for strategic reasons, there is almost no likelihood
that it could be outbid by a small business."(10) And permitting
large companies to outbid small businesses would "frustrate
Congress's goal of disseminating licenses among a diversity of
licenses."(11) Thus, the Commission set a specific asset cap that
it judged would exclude companies that could outbid smaller
companies, but still permit participation by companies likely to
have the "financial ability to provide sustained competition for
the PCS licenses".(12)
3.   The Commission should not deviate from its small business
public interest goals.
     Nextel and SBC argue the Commission should abandon its
policy reserving the PCS C-Block for small business.  They argue
that market changes since 1994 have altered the Commission's
fundamental assumptions about small business competitiveness.
But on multiple occasions in the past, the Commission has
rejected similar arguments and has repeatedly reaffirmed the C-
Block set-aside.(13) In 1994, the Commission stated,
          We do not accept . . . that we should do away with the
          entrepreneurs' blocks and instead offer bidding credits
          . . ..  [I]n our judgment we do not anticipate
          designated entities to realize meaningful opportunities
          for participation in broadband PCS unless we supplement
          bidding credits and other special provisions with a
          limitation on the size of the entities designated
          entities will bid against.  Without the insulation of
          the entrepreneurs' block, the record strongly supports
          the conclusion that measures such as bidding credits
          will prove ineffective for broadband PCS.(14)
Three years later, the Commission determined that "no party has
provided a convincing rationale for deviating from the public
interest goals articulated by the Commission [and] the Commission
affirms its ruling . . . to limit eligibility . . . to applicants
meeting the current definition of "entrepreneur"."(15) In August,
1998, the Commission again affirmed its commitment to the
entrepreneur's block, again rejecting the arguments Nextel and
SBC raise in this proceeding:
          Nextel argues that a restricted auction skews the
          marketplace and that the increasing level of
          competition in the wireless arena makes it less likely
          that small business entrepreneurs can survive.
          According to Nextel, the Commission could enable small
          businesses to bid competitively by providing them
          bidding credits . . ..  No other commenter supports
          Nextel's views, and several parties oppose them.  As
          stated, we recently denied Nextel's request . . . and
          the record in this proceeding provides us with no basis
          to alter our decision.(16)
     Nextel and SBC again argue that the Commission's original
assumptions about small business have changed.  But the
Commission did not think so in 1994, nor in 1997, nor in 1998.
Instead, it has consistently rejected this argument, and nothing
relevant has changed in the last two years.  The only factors
that have changed are these: successful C-Block re-auction to
small businesses, increasingly contentious bankruptcy
developments, and Nextel's offer to pay $8 billion for NextWave's
licenses.  Only the first of these factors would seem to bear on
the Commission's public policy conclusions regarding
entrepreneur's use of the C-Block, and this factor supports the
continued insulation from big business bidding competition.
     Nextel and SBC argue that the experience with NextWave shows
that small business cannot compete against large business in the
provision of services such as broadband PCS.  But NextWave's
failure to satisfy the Commission's payment requirements is no
reason to abandon Congress's goal that small business be afforded
the opportunity to compete for wireless telephone customers.  The
failure of one or a few companies to pay for spectrum for which
they had bid too high does not equal a failure of all small
businesses to compete in the wireless marketplace.  Small
businesses bring competition and innovation to markets they
enter, and small business customers are a chief beneficiary of
the increased choices and decreased prices that competition and
innovation brings.  Today, small businesses are bringing
competitive PCS services to the marketplace.
     SBC states, "Allowing a non-designated entity like SBC to
participate will encourage successful entry of smaller companies
because it will increase the likelihood that they will only
attempt to enter the markets where they can be competitive."(17)
SBC also claims that "[o]pening up the auction will not
compromise the Commission's policy of encouraging - on a viable
basis - participation by smaller companies."(18) On the contrary,
SBC's participation would destroy the Commission's policy of
encouraging participation by smaller companies, except for
confining them to markets of no interest to larger companies.
Indeed, SBC indicates that large carriers might "focus on larger
markets, which will require very substantial outlays of capital,
while smaller companies might choose to focus on smaller markets
that they can afford to enter".(19) Large businesses will secure
all the spectrum they want because, as the Commission has
correctly found, a small business cannot outbid a large
business.(20)
     SBC argues that the C-Block set-aside caused small bidders
to choose to enter markets where they could not compete.  But
SBC's evidence for this view is not that these small bidders
entered the market and failed to succeed against larger
companies.  Rather, the small bidders could not afford their
licenses, because the ready availability of installment financing
encouraged too-high bidding, or because the market price of the C-
Block licenses plummeted soon after the auction, or because they
simply overbid.  In any event, now that installment payments are
gone and C-Block licenses have been selling on re-auction to
small bidders who can afford them, the upcoming re-auction is
unlikely to see above-market bids or a new generation of
NextWaves.
     The results of previous re-auctions demonstrate that small
business is interested in providing broadband PCS and is capable
of competing with large business to do so.  The licensing process
has been slow, and PCS is still in its early stages of
development, but a number of small operators have launched
service in the last year and a half,(21) and a dozen more plan to
begin service in the coming months.  Many of these companies will
provide service to rural communities, despite Nextel's assertion
that smaller companies will not serve these areas.(22) And these
licenses are all paid in full.  Much of what went wrong on the C-
Block can be attributed to installment payments.  Since the
Commission eliminated these, C-Block licensing has proceeded much
more smoothly, and re-auction participants have bid amounts well
within their means.  Even SBC concedes that the Commission's
small business policy has been working,(23) but it is important
to note that this success has occurred within the context of C-
Block exclusivity, not in an atmosphere of big-business bidding
competition.
     While many PCS markets still have but one or two operating
PCS systems, issuing licenses to small businesses will bring
competition to these markets as well.  The Commission prepares to
re-auction licenses for the nation's top markets, and it has a
real opportunity to assure that small business has the chance to
compete in these markets.  To give these PCS licenses to big
business, however, will forever drive small business from the
largest cities.  Thus, it is just as important as ever to provide
opportunity for small business, and women and minority-owned
business, to compete in the market by guaranteeing their access
to spectrum.
4.   Maximizing auction revenue is no valid reason to exclude
small business from PCS.
     Advocacy trusts that the Commission will not be swayed by
Nextel's and SBC's deep pockets.  Permitting big business onto
the C-Block to maximize revenue would constitute the greatest
imaginable violation of C-Block auction integrity, and would be a
tortured interpretation of Congress's will.
     But Chairman Kennard recently testified to the U.S. Senate
Budget Committee that taxpayers might lose billions of dollars if
the Commission accepted NextWave's offer to pay its entire debt
of $4.3 billion, instead of re-auctioning the spectrum.(24) In
this regard, Chairman Kennard testified that the Commission is
still considering Nextel's offer to pay twice this amount for the
licenses;(25) he also judged the worth of the licenses to be as
high as $10 billion. There also have been reports of staff
discussions with Nextel regarding how much money Nextel would pay
for NextWave's licenses and whether the spectrum should be
transferred to Nextel.(27)
     Indeed, one benefit of the Commission's auction program is
that it tends to put licenses in the hands of those who value
them most highly.  Revenue generation is a fortunate by-product
of auctioning valued spectrum, and it remains to be seen what
price these licenses may bring upon re-auction to designated
entities.
     But as the Commission realizes, increasing federal revenue
is not Congress's goal.  Rather, the Telecommunications Act seeks
to bring competition,  innovation, and diversity to the nation's
communications marketplace.(28) Issues of auction revenue
generation are irrelevant to this objective.  Congress directed
the Commission to provide competitive opportunities for women,
minorities, and small business.  The commission decided that the
way to do this for PCS (which it expected would involve high
capital costs) was to guarantee access to spectrum for small
businesses, women-owned businesses, and minority-owned
businesses.
     Maximizing short-term revenue for the federal treasury
should not be the prime goal of the Commission's C-Block re-
auction.  Providing licenses to "deep pocket" bidders who can pay
the most should not be elevated above the public policy goal of
assuring opportunity for small business to compete and laying the
groundwork for competition in a developing service.  Congress
never intended that revenue be the prime goal of spectrum
auctions.  And the Commission did not set aside the C-Block in
order to maximize revenue but to permit small business
participation in PCS service.  Advocacy therefore urges the
Commission to reject SBC's and Nextel's bankroll as a reason to
abandon its still-valid small business goals.
5.   Conclusion
     Nextel and SBC offer no sound public policy reason for the
Commission to deviate from its C-Block rules in order to permit
big business participation in the upcoming re-auction. NextWave's
failure to pay for its licenses does not impugn the ability of
other small businesses to compete.  Nor does it invalidate
Congress's and the Commission's legitimate policy of affording
small businesses the access to spectrum that will promote
competition.
     Market shifts and other factors have greatly complicated the
fulfillment of Congress's and the Commission's goals for the C-
Block, but the underlying rationale is even more strongly
justified now.  Large businesses so dominate the use of wireless
spectrum that the C-Block is the only opportunity small
businesses will ever have to compete in broadband PCS.  Selling
the licenses to Nextel or SBC will increase concentration,
decrease competition, and further complete large business
dominance of wireless telecommunications.  Customers, including
small business, will suffer.  This will be the last opportunity
for the Commission to help structure competition in this emerging
service market.  This is no time for the Commission to throw up
its hands and permit Nextel and SBC to push small business from
the broadband PCS market. The Commission should not let its
desire to achieve full value for its spectrum licenses blind it
to the fact that small business and the marketplace need this
spectrum in 2000 as much as they did in 1994.  Entrepreneurial
spirit is alive in this country, and small businesses are
prepared to compete with Nextel, SBC, and other
telecommunications giants.
Respectfully submitted,
Jere W. Glover
Chief Counsel for Advocacy
R. Bradley Koerner
Assistant Chief Counsel
for Telecommunications
February 22, 2000
                     Certificate of Service
     A copy of the foregoing Request for Additional Time to File
Comments was served by first class mail upon the following
individuals:
     Magalie R. Salas
     Secretary
     Federal Communications Commission
     445 12th Street, S.W.
     Washington, DC 20554
     William E. Kennard
     Chairman
     Federal Communications Commission
     445 12th Street, S.W., Room 8-B201
     Washington, DC 20554
     Susan Ness
     Commissioner
     Federal Communications Commission
     445 12th Street, S.W., Room 8-B115
     Washington, DC 20554
     Harold Furchtgott-Roth
     Commissioner
     Federal Communications Commission
     445 12th Street, S.W., Room 8-A302
     Washington, DC 20554
     Michael K. Powell
     Commissioner
     Federal Communications Commission
     445 12th Street, S.W., Room 8-A204
     Washington, DC 20554
     Gloria Tristani
     Commissioner
     Federal Communications Commission
     445 12th Street, S.W., Room 8-C302
     Washington, DC 20554
     Kathleen O'Brien Ham
     Wireless Telecommunications Bureau
     Federal Communications Commission
     445 12th Street, S.W., Room 3-C255
     Washington, DC 20554
     Amy Zoslov
     Auctions and Industry Analysis Division
     Wireless Telecommunications Bureau
     Federal Communications Commission
     445 12th Street, S.W., Room 4-A624
     Washington, DC 20554
     Robert S. Foosaner
     Nextel Communications, Inc.
     2001 Edmund Haley Drive
     Reston, VA 20191
     Leonard J. Kennedy
     Dow, Lohnes & Albertson, PLLC
     1200 New Hampshire Avenue, NW, Suite 800
     Washington, DC 20036
     James D. Ellis
     SBC Communications Inc.
     175 E. Houston
     San Antonio, TX 78205
     L. Marie Guillory, Jill Canfield
     National Telephone Cooperative Association
     4121 Wilson Boulevard, 10th Floor
     Arlington, VA 22203
     Mary Madigan Jones
     Personal Communications Industry Association
     500 Montgomery Street, Suite 700
     Alexandria, VA 22314
     ITS
     1231 20th Street, NW
     Washington, DC 20036
                                    R. Bradley Koerner
     February 22, 2000
ENDNOTES
1.   Congress established the Office of Advocacy in 1976 by Pub.
L. No. 94-305 to represent the interests of small business within
the Federal government.  See 15 U.S.C.  634 (a)-(g), 637.
Advocacy serves as a focal point for concerns regarding the
government policy as it affects small business.  Advocacy
develops proposals for changes in Federal policy and communicates
proposals to the Federal agencies.  See 15 U.S.C.  634(c)(1)-
(4).  Advocacy also has a statutory duty to monitor and report to
Congress on the Commission's compliance with the RFA.
2.   NextWave's licenses constitute the bulk of the spectrum that
the Commission plans to re-auction this summer.
3.   Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Report and Order, PP Docket No. 93-253
(1994), paragraph 11.
4.   Congress also requires the Commission to "promot[e] economic
opportunity and competition and ensur[e] that new and innovative
technologies are readily accessible to the American people by
avoiding excessive concentration of licenses and by disseminating
licenses among a wide variety of applicants, including small
business, rural telephone companies, and businesses owned by
members of minority groups and women."  Implementation of Section
309(j) of the Communications Act - Competitive Bidding, Fifth
Report and Order, PP Docket No. 93-253 (1994), paragraph 11.
5.   Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Report and Order, PP Docket No. 93-253
(1994), paragraph 9.
6.   Id., paragraph 10.
7.   Id., paragraph 12.
8.   Id., paragraph 96.
9.   Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Report and Order, PP Docket No. 93-253
(1994), paragraph 131.
10. Id., paragraph 121.
11. Id., paragraph 123.  At least twice in the past, Nextel has
asserted that the Commission can provide adequate opportunity to
small business through bidding credits.  This "would allow [small
business] to compete with larger entities that may choose to bid
on these returned licenses and would further the public interest
by assigning the returned C Block licenses to those who value
them most highly and can expeditiously put them to the highest
and best use."  Comments of Nextel Communications, Inc, WT Docket
No. 97-82, November 13, 1997, page 5.  The Commission disagrees.
12. Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Report and Order, PP Docket No. 93-253
(1994), paragraph 123.
13. See Installment Payment Financing for Personal Communications
Services (PCS) Licensees, Order on Reconsideration of the Second
Report and Order, WT Docket No. 97-82 (1998), Installment Payment
Financing for Personal Communications Services (PCS) Licensees,
Second Report and Order, WT Docket No. 97-82 (1997), and
Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Memorandum Opinion and Order, PP
Docket No. 93-253 (1994).
14. Implementation of Section 309(j) of the Communications Act -
Competitive Bidding, Fifth Memorandum Opinion and Order, PP
Docket No. 93-253 (1994), paragraph 16.
15. Installment Payment Financing for Personal Communications
Services (PCS) Licensees, Order on Reconsideration of the Second
Report and Order, WT Docket No. 97-82 (1998), paragraph 56.
16. Amendment of the Commission's Rules Regarding Installment
Payment Financing for Personal Communications Services (PCS)
Licensees, Fourth Report and Order, WT Docket No. 97-82 (1998),
paragraph 16.
17. Petition of SBC Communications Inc. for Waiver of the
Eligibility Requirements of 47 C.F. R.  24.709 for the PCS
Frequency Blocks C and F Auction to Begin on July 26, 2000 ("SBC
Petition"), DA 00-191, January 21, 2000, page ii.  Nextel agrees
with this outrageous proposition:  "expanding participation . . .
to companies other than designated entities will in no way
undermine their opportunity to participate in the reauction."
Petition for Expedited Rulemaking or, in the Alternative, Waiver
of the Commission's Rules ("Nextel Petition"), DA 00-191, January
31, 2000, page 16.  In fact, Nextel argues it "enhances" the
ability of small business to participate.  Nextel Petition, page
17.  Nextel offers no real explanation how this is possible.  In
fact, Nextel's proposed $2 billion upfront payment and minimum
opening bid for bulk bidding underscores how different a Big
Business C-Block Auction would be from the successful C-Block re-
auctions the Commission has conducted to date.  See Nextel
Petition, page 21.  Nextel continues to urge that bidding credits
are sufficient to ensure small business participation, but as
noted, the Commission has repeatedly disagreed.  See, e.g.
Amendment of the Commission's Rules Regarding Installment Payment
Financing for Personal Communications Services (PCS) Licensees,
Fourth Report and Order, WT Docket No. 97-82 (1998), paragraph
16.
18. SBC Petition, page 5.
19. SBC Petition, pages 16-17.
20. See Implementation of Section 309(j) of the Communications
Act - Competitive Bidding, Fifth Report and Order, PP Docket No.
93-253 (1994), paragraph 121.
21. See Implementation of Section 6002(b) of the Omnibus Budget
Reconciliation Act of 19993, Fourth Report, FCC 99-136 (rel. June
24, 1999), page 31.
22. See Nextel Petition, page 10.  Nextel pledges to provide
service to Native American tribal lands (see Nextel Petition,
page 11), but large businesses have traditionally ignored service
to low income and sparsely populated areas.  In Advocacy's
experience, local companies, with strong personal ties to the
communities, are the ones who will provide telecommunications
services, including wireless services, to tribal lands.  See
Comments of Advocacy, WT Docket No. 99-266, November 9, 1999.
23. SBC states, "Of course, some designated entities . . . have
fared better than NextWave, so [the Commission's policy of
encouraging viable small business participation] has already
borne fruit."  SBC Petition, page 5.
24. Communications Daily, February 14, 2000, vol. 20, number 29.
25. Id.
26. Id.
27. Communications Daily, September 30, 1999, vol. 19, number
189.
28. See Implementation of Section 309(j) of the Communications
Act - Competitive Bidding, Fifth Report and Order, PP Docket No.
93-253 (1994), paragraph 11.