More than two-dozen station groups and owners representing more than 200 TV stations across the country have banded together to tell the FCC that its approach to freeing up spectrum is illegal, and in comments to the FCC said, essentially, they can't comment fully on it because of the FCC's piecemeal approach to the issue...
..."Adoption of the proposals set forth in the NPRM [notice of proposed rulemaking] would result in Commission action based on inadequate study, unsupported speculation, and insufficient process, all in violation of the Commission's obligations under the Administrative Procedure Act and established administrative law principles," they argue.
