FiberTower’s industry-leading investments and spectrum development
activities, even in the absence of universal construction and transmission, are sufficient to demonstrate that it “responsibly develop[ed] the spectrum [it] ha[d] been assigned.”66
As the record reflects, FiberTower blazed the trail for service in these high-frequency bands, investing hundreds of millions of dollars in the infrastructure and technology necessary to successfully
deploy this spectrum, in addition to making its spectrum available for lease.67
Accordingly,
all 689 of FiberTower’s licenses should be renewed under the substantial service regulations.
