The Federal Communications Commission should adopt rules to allow practically all spectrum to be allocated flexibly in response to market conditions and to allow licensees to use their spectrum flexibly. This approach is consistent with the direction of FCC decisions to allow greater spectrum flexibility. Greater spectrum flexibility to licensees is economically superior to the FCC’s recent proposals for broadcast spectrum auctions. Greater spectrum flexibility would foster greater innovation in American spectrum markets and spectrum transactions as well as stimulate innovation in wireless service and product markets. The overall economic value of flexibility is likely orders of magnitude greater than the $15 billion in auction receipts over ten years projected from broadcast spectrum auctions.