CLAIRE McCASKILL 
MISSOURI 
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WASHINGTON, DC 20510 
The Honorable Thomas Wheeler 
Chairman 
Federal Communications Commission 
445 12th Street SW 
Washington, DC 20554 
Dear Chairman Wheeler: 
February 26,2015 
The recent A WS-3 spectrum auction was a success for consumers and provided a critical boost 
for important federal policy priorities. Wireless providers will be able to make more wireless 
broadband available to more Americans, and important priorities such as first responder 
communications and deficit reduction will benefit from the more than $40 billion generated from 
the auction. The record-breaking total proceeds will undoubtedly increase interest within the 
wireless industry, at the Commission, and within Congress to put more spectrum in the hands of 
the private sector to grow our economy and ensure the United States remains the world leader in 
wireless technology. That is why I am especially troubled by reports of Dish Network's use of 
the Federal Communications Commission's (FCC) designated entity program to receive more 
than $3 billion in discounts to emerge as one of the auction's largest winners. 
Dish holds an 85 percent stake in two companies that appear to have been created for the sole 
purpose of participating in the A WS-3 auction and taking advantage of bidding credits that 
Congress intended only be made available to small businesses. Dish's two shell companies ­
Northstar Wireless and SNR Wireless - claim in filings that although Dish holds an 85 percent 
stake in each of the companies, Dish does not control the companies. 
Further illustrating Dish's abuse of the Commission's well-intentioned designated entity 
program, and the flaws with the Commission's rules governing the program, is the fact that an 
Alaska Native Corporation (ANC), Doyon Ltd., with revenue of more than $318 million in 2013, 
is listed as the controlling shareholder of Northstar Wireless. The fact that an ANC with 
hundreds of millions of dollars in revenue is considered a small business under FCC rules is 
insulting to the true small businesses that wish to compete for spectrum. Before spectrum 
licenses are awarded to the auction's winners, the Commission must thoroughly investigate the 
legitimacy of all designated entities that participated in the auction. 
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Wireless spectrum and federal resources are both far too scarce to allow multibillion-dollar 
corporations to abuse taxpayers this way. Dish was not the first multibillion dollar 
telecommunications provider to take advantage of the designated entity program but the 
Commission should act to ensure it is the last. The rules for the designated entity program need 
to be revised in a comprehensive manner so that no future auction is manipulated in the same 
way. In doing so the Commission should eliminate preferential treatment for ANCs that do not 
meet the standard for small businesses. While I believe Congress gave the Commission a great 
deal of flexibility to address these issues on its own, I stand ready to work with you, your fellow 
commissioners, and my colleagues on the Senate Commerce, Science, and Transportation 
Committee to address this problem legislatively if necessary. 
United States Senator