Wireless, GPS, Other Industries Support Flexible Use of 2 GHz Band with Some Added Suggestions

Major wireless providers claimed that widespread growth of mobile broadband underscores the need for more spectrum. Consumer demand for mobile broadband and smartphone and tablet adoption will continue to drive up data consumption and “carriers will increasingly require more spectrum to meet their customers’ needs,” said Verizon Wireless. Under either of the proposals, “additional spectrum could be added to make even more spectrum available if/when it becomes available,” Verizon Wireless said. Sprint Nextel supports an expedited licensing of the AWS-4 spectrum and the auctioning of the H-block spectrum located adjacent to core PCS operations. PCS licensees can use existing equipment for any H-block deployment, “resulting in cost savings to the industry and consumers,” Sprint said. Also, competitive national carriers would have a strong incentive “to enter into collaborative arrangements with regional and rural carriers to develop the auctioned H block quickly and efficiently."

T-Mobile suggested that the commission require the AWS-4 licensee to meet stricter network coverage milestones than it originally proposed in the NPRM. The FCC’s requirements aren’t sufficient to ensure prompt delivery of competitive mobile service in the AWS-4 band, it said. It recommends reassigning 20 MHz of the proposed AWS-4 spectrum through a competitive auction. Dish could surrender 20 MHz of its 2 GHz MSS allocation “in return for receiving flexible terrestrial use rights in the remaining 20 MHz.” Dish would receive full, flexible terrestrial use rights “if it chose to voluntarily return 20 MHz of the 2 GHz MSS spectrum for reassignment through a competitive auction,” T-Mobile said. The auction would serve the public interest by preventing a single licensee from receiving a substantial windfall “at the expense of other licensees that have invested billions of dollars in deploying and expanding competitive wireless broadband networks."

The U.S. GPS Industry Council commended the FCC for limiting the scope of the current proceeding to the 2 GHz MSS bands. Operation of the MSS and terrestrial AWS components in the 2 GHz band by the same licensee will help to avoid “harmful interference between and among facilities operating in the two services,” the group said. Assignment of terrestrial licenses to any entity other than the incumbent MSS licensee remains impractical, it said. While the council supports extending the FCC’s spectrum manager leasing rules to cover additional AWS spectrum at 2 GHz, “licensees should not be permitted to partition or disaggregate spectrum through sale or de facto transfer in a manner that separates operational oversight and implementation of the satellite and terrestrial elements.” It also urged the commission to codify in Part 27 of the FCC rules existing interference protections for radio navigation satellite service, including out-of-band emission (OOBE) limits that apply to MSS ancillary terrestrial component licenses. With the deployment of terrestrial base stations and handsets expected to increase exponentially if the rules are adopted, the FCC “needs to ensure that all OOBE limits from the authorizations that apply to terrestrial operations in these bands today continue to so apply,” it said.

Deere urged the commission to consider an update to the OOBE limit to facilitate “the successful introduction and co-existence of new terrestrial uses in the MSS bands with the widespread use of RNSS equipment and applications.” Effective management of OOBE levels will be essential “to ensure the successful en masse operation of terrestrial 2 GHz handsets and RNSS receivers in close proximity,” Deere said. The rules must provide adequate protection from interference with GPS, the company said.

The Satellite Industry Association opposed the proposal that calls for automatic termination of an MSS authorization where a terrestrial one is terminated for failure to meet AWS buildout requirements. Satellite licensees should be permitted to keep their system authorizations intact “so long as substantial MSS is being offered within the licensee’s overall service area.” It’s not practical for a nationwide MSS licensee “to constrain its operations over the limited geographic area encompassed by an individual AWS Economic Area license,” SIA said. Where a terrestrial component isn’t constructed in a timely manner, existing MSS operations should continue to be utilized, because these services are often used “to ensure essential ubiquitous connectivity for purposes such as disaster relief and critical infrastructure maintenance.” SIA cautioned against including any allocation changes in the big low earth orbit and L-band MSS in the proceeding. If the commission considers changes in the existing ATC framework in these other bands, the changes need “to be the subject of further proceedings that are geared to the specific issues presented by terrestrial fixed and mobile operations at those particular frequencies,” the association said.

It’s essential that the FCC adopt rules and policies to ensure that the licensee “will not adopt a near-exclusionary focus to serving urban consumers and shutting out smaller providers,” NTCA said. The licensee should be required to offer reciprocal roaming to small, wireless providers “with terms and conditions no less favorable than what are offered to other roaming partners.” This provision would help promote a more competitive market in which all consumers, including consumers in rural markets, have more practical choices among providers, NTCA said. The FCC also should encourage the licensee to partner with small providers “by permitting the licensee to include the population served by rural partners … to meet its buildout requirements."

While the spectrum management concepts in the NPRM and notice of inquiry are appropriate, a more comprehensive analysis of available spectrum resources and spectrum pairing scenarios should be conducted, LightSquared said. The commission’s approach to expanding mobile broadband capacity in the 2 GHz band should be applied to LightSquared’s planned 4G LTE wireless network, the company said. The agency should consider making some or all of the 1675-1695 MHz band available “to LightSquared for terrestrial downlinks,” or if the existing 2 GHz MSS licensee is relocated from 2000-2020 MHz to 1695-1710 MHz, “make the 2000-2020 MHz band available to LightSquared for terrestrial downlinks,” it said. With one or more of these alternatives, there will be suitable spectrum that would allow the company to deploy its network “fully using spectrum that is comparable to LightSquared’s current terrestrial downlink spectrum in the L band, a portion of which … may not be usable due to GPS issues,” the company said.