FCC Seeks Comment on 1755-1780 MHz band, Other ‘AWS-3’ Spectrum

The NPRM was released the day after the Department of Defense released its alternative proposal for 1755 MHz and other spectrum (CD July 23 p1) and on the eve of a key meeting of the Commerce Spectrum Management Advisory Committee (see related report in this issue).

Under the FCC proposal, all of the spectrum would be licensed in 5 MHz blocks “that can be aggregated using Economic Areas (EAs) as the area for geographic licensing,” which is the same configuration expected for the incentive auction of what is now broadcast spectrum, though small carriers want smaller licenses (http://bit.ly/18CN622). The NPRM asks whether and how the four bands should be paired in an eventual AWS-3 auction.

The NPRM proposed to license the 2155-2180 MHz band for downlink/base station operations and the 2020-2025 MHz band for uplink/mobile operations. Meanwhile, 1755-1780 MHz would be licensed for uplink/mobile operations “on a shared basis with Federal incumbents, if clearing is not feasible,” and 1695-1710 MHz would be allocated to uplink “on a shared basis with Federal incumbents within specified Protection Zones recommended by NTIA.”

The NPRM seeks comments on a March request by CTIA that the commission auction the 2095-2110 MHz band, now allocated for the broadcast auxiliary service, to satisfy a Spectrum Act requirement that the FCC identify 15 MHz of contiguous spectrum for commercial use. It noted, though, that NASA has raised objections, also in a report forwarded to the FCC by NTIA this week. NASA uses the spectrum for geostationary Tracking and Data Relay Satellite System (TDRSS) satellites. “NTIA states that the results of the study show that high-density terrestrial base stations or user equipment operating co-frequency in the 2025-2110 MHz band will exceed established protection criteria for the TDRSS spaceborne receivers by an average of 16.4dB to 40.7 dB and that analysis of sharing with satellite systems of other administrations will likely show similar results,” the NPRM said.

The notice recognizes many recent developments on the proposed AWS-3 spectrum -- the industry roadmap submitted by T-Mobile, the DOD alternative proposal, and the various reports on 1755-1850 MHz being prepared by CSMAC working groups. Many of the questions posed are technical, such as proper out-of-band emissions limits (OOBE), which the FCC proposed be consistent with limits in the AWS-1 band, how OOBE is to be measured, power limits and antenna height restrictions. “Our rules for the AWS-3 bands must take account of the potential for permissible operations to cause harmful interference to operations in other service areas, blocks or bands,” the NPRM notes. “Interference must therefore be considered between adjacent AWS-3 blocks, e.g., between 2155-2160 MHz and 2160-2165 MHz, as well as between AWS-3 operations in the 2155-2180 MHz band and services in the adjacent AWS-1 and AWS-4 bands. Similarly, AWS-3 mobiles could interfere with proximate Federal or non-Federal operations in the same or nearby bands."

The NPRM proposes buildout requirements consistent with its rules for other bands. Under the proposed rules, AWS-3 licensees would have to cover at least 40 percent of the population in each of its license areas in four years and 75 percent in 10. “We propose these performance requirements in an effort to foster deployment expeditiously in the AWS-3 band for the provision of wireless, terrestrial broadband service, and to enable the Commission to take appropriate corrective action should such deployment fail to occur,” the NPRM states.

"This item helps the Commission to meet Congress’s directive to auction and license certain frequency bands by February 2015,” said acting FCC Chairwoman Mignon Clyburn. “It is also consistent with the President’s encouragement to expand the availability of spectrum for innovative and flexible commercial uses by expediting the repurposing of spectrum, and where technically and economically feasible, utilizing spectrum sharing to enhance efficiency among all users. Included in today’s item are proposals for identifying spectrum that is free, clear, and available for exclusive use, as well as proposals for spectrum that could be shared with Federal users if clearing and reallocating is not possible in the near-term. It provides flexibility to accommodate any number of effective paths toward making additional spectrum available for wireless broadband."

Commissioner Jessica Rosenworcel said the AWS-3 spectrum is critical to get in play and, if all goes as planned, the NPRM will provide another 55 MHz of spectrum for commercial use. “I am hopeful that we will soon have a path to clear 1755-1780 MHz for commercial mobile broadband use,” she said. “Nonetheless, I think we need a plan in the event that this spectrum is not fully cleared and ready for pairing with 2155-2180 MHz. To this end, I am thankful that the Commission is asking about my proposal to auction the 2155-2180 MHz band along with the right to work with the federal incumbents in the 1755-1780 MHz band. This could be an elegant way forward.” Rosenworcel said she hopes the entire 55 MHz will be sold in a single auction. “That means one simple auction of the 65 megahertz described in the Middle Class Tax Relief and Job Creation Act -- combining the 55 megahertz described here with the 10 megahertz from the H-block,” she said.

"Although I cannot support every proposal in today’s Notice, I am especially pleased that my colleagues were willing to incorporate my proposals to ensure that if clearing the 1755-1780 MHz band is feasible, we can move forward with relocation and exclusive commercial use there,” Pai said. “Not only is clearing the bipartisan legislative preference, it just makes sense. The fewer impairments, exclusion zones, and complicated sharing arrangements there are, the more valuable the spectrum will be, especially for regional carriers that are unlikely to have the wherewithal to coordinate their use with potentially hundreds of federal users.” Pai said he was very pleased about the DOD’s recent proposal on 1755-1780 MHz. “This recognition -- that relocating some operations and compressing most others into existing federal spectrum is feasible at a total cost of only $3.5 billion -- is a tremendous step in the right direction,” he said. “I commend the Department of Defense for working towards a solution that will serve federal and consumer interests alike.”

"The spectrum blocks identified by Congress in the 2012 Spectrum Act can play a critical role in meeting demand for mobile broadband, and we are pleased that the Commission has set a goal of clearing and allocating these bands for exclusive commercial use,” said CTIA Vice President Scott Bergmann in a written statement. “We look forward to reviewing the FCC’s proposal details and working with the Commission and NTIA to ensure the timely action and appropriate pairings that are essential to maintaining the global leadership of ... the U.S. mobile broadband ecosystem and to achieving the goals of Congress."