What is going on at the FCC? The agency established the rules for the upcoming 700MHz spectrum auction back in August, but it turns out that these were not so much "rules" as "suggestions for discussion."

Verizon, AT&T, and Frontline Wireless have all since petitioned the FCC to change the rules in different ways. AT&T wants more clarity around the "public/private partnership" part of the auction, while Frontline wants a lower reserve price. Verizon, however, is directly targeting the most innovative part of the auction, the "open access" requirements on some of the new spectrum. It has filed a federal lawsuit asking that this part of the rules be struck down by a judge, and it also appears to be lobbying the FCC directly to water them down.

Google, which fought hard for those rules (and actually wanted more "open" conditions applied), is now attacking Verizon both in public and at the FCC.

While Verizon's court case proceeds through the legal system, the company's competitors have grown unhappy with the way that Verizon has handled its FCC lobbying. Frontline Wireless has gone so far as to ask the FCC to bar Verizon from the auction because Verizon has allegedly not disclosed some of its lobbying contacts with the agency quickly enough or in enough detail.

Despite Verizon's reticence to spell out exactly what it has been talking about with FCC Chairman Kevin Martin in private meetings, Google believes that it has pieced the conversation together. Google's understanding is that Verizon wants the FCC to impose the open access requirements only on the network, not on the devices. That is, Verizon could still sell handsets that are locked and controlled by the company, but its network would have to be open to unlocked handsets from any operator.

According to Google's new public statement on the issue, "From our perspective, this view ignores the realities of the U.S. wireless market, where some 95 percent of handsets are sold in retail stores run by the large carriers. More to the point, it is simply contrary to what the FCC's new rules actually say." Those rules focus on customer freedom to access content and applications from any device.

In a filing with the FCC, Google asks the agency to stick to its original plan. The company points out that while the open access rules might make the spectrum less attractive to Verizon (and thus might bring in less money at auction), the rules actually make it "more attractive, not less" to Google.

Such arguments, both in FCC filings and in public, are coming thick and fast. The FCC has set a January date for the 700MHz auction, so we should know quite soon if any changes will be made to the auction rules. Google continues to shield itself in a strategic cloud of uncertainty, but the vigor with which it addresses these issues certainly suggests, at the least, that the company hasn't ruled out a bid.