Abstract-Spectrum policy in the US (and throughout most of the world) consists generally of a set of nationally determined policies that apply uniformly to all localities. However, it is also true that there is considerable variation in the features (e.g., traffic demand or population density), requirements and constraints of spectrum use on a local basis. Global spectrum policies designed to resolve a situation in New York City could well be overly restrictive for communities in rural areas (such as central Wyoming). At the same time, it is necessary to ensure that more permissive policies of central Wyoming would not create problems for NYC (by ensuring, for example, that relocated radios adapt to local policies). Notions of polycentric governance that have been articulated by the late E. Ostrom [16] argue that greater good can be achieved by allowing for local autonomy in resource allocation.Shared access to spectrum is generally mediated through one of several technologies. As shown in [21], approaches mediated by geolocation databases are the most cost effective in today's technology. In the database oriented Spectrum Access System, or SAS, proposed by the FCC, users are granted (renewable) usage rights based on their location for a limited period of time. Because this system grants usage rights on a case-bycase basis, it may also allow for greater local autonomy while still maintaining global coordination. For example, it would be technically feasible for the database to include parameters such as transmit power, protocol, and bandwidth. Thus, they may provide the platform by which polycentric governance might come to spectrum management. In this paper, we explore, through some case examples, what polycentric governance of spectrum might look like and how this could be implemented in a database-driven spectrum management system. In many ways this paper is a complement to [20], which evaluted emerging SAS architectures using Ostrom's socioeconomic theory. This paper explores how a SAS-based system could be constructed that is consistent with Ostrom's polycentric governance ideas. Our approach is to address spectrum management as an emergent phenomenon rather than a top down system. This paper will describe the key details of this system and present some initial modeling results in comparison with the traditional global model of spectrum regulation. It will also discuss some of the concerns associated with this approach.