The Phoenix Center released a study entitled “Re-Auction of the D Block: A Review of the Arguments” that demonstrates the problems behind the plan to re-auction the D Block for commercial purposes, including that a re-auction of the D Block is unlikely to generate $3 billion in revenues as some believe. The report states that statistical analysis of auction data indicates that a 10 MHz block of spectrum in the 700 MHz band must be unencumbered to produce $3 billion in revenues. According to the Phoenix Center, the only formal proposal put forth to fund the public-safety network with auction revenue is a voluntary incentive auction for television broadcast spectrum proposal.