Windfalls—large, unexpected economic gains reaped by one member of a transaction—are often singled out by opponents as a reason to avoid certain methods of reallocating radio frequencies from restrictive licensing regimes to more flexible ones.

Objections to corporate license holders gaining windfalls in spectrum proceedings have come from prominent voices. In the recent reallocation of the lower C band, in which satellite companies were paid to clear space for flexible-use licenses, public interest groups and U.S. senators alike condemned the payments as windfalls.1 The ongoing reallocation of the 2.5 GHz band has been accompanied by accusations of windfalls reaped by holders of long-term leases at the time of liberalization.2 Likewise, a brewing proceeding on the 12 GHz band has prompted preemptive warnings not to allow the incumbent holder of more restrictive licenses to realize a windfall if licenses are liberalized.3