Bruce Mehlman points out in recent blog post that the FCC cannot have it both ways. It cannot label an auction process as competitive and then support an egregious barrier to entry by allowing some companies to bid on spectrum and leaving others on the sideline.
A participant in a free market enters with a willingness and ability to sell or buy goods and services.
Should spectrum go to the entity indicating through the highest bid, that they have the capacity to purchase and use spectrum?