Public Interest Groups Say 3.5 GHz Rules Offer Model for High-Frequency Spectrum
New America’s Open Technology Institute (OTI) and Public Knowledge told the FCC there's broad support in the record for extending sharing rules developed for the 3.5 GHz band to some of the spectrum the agency is examining in its spectrum frontiers rulemaking. NCTA pushed the FCC to allocate parts of the spectrum for unlicensed use. Federated Wireless, which said it plans to be a spectrum access system (SAS) administrator in the 3.5 GHz band, urged a similar approach for high frequency spectrum. The reply comments were posted in docket 14-177. In earlier comments, industry players, including CTIA, said the spectrum is key for 5G (see 1602290021).
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
OTI and PK said they were “pleased to see significant support among commenters for that approach and for a use-or-share obligation on licensees that facilitates opportunistic public access to unused millimeter-wave spectrum, and a strong consensus among commenters that the current unlicensed band at 57-64 GHz should be extended at least to 71 GHz.” There's a stronger case for opportunistic sharing of the high-band spectrum than there was for the 3.5 GHz band, the groups said.
OTI and PK said the FCC should reject arguments by carriers. “Unfortunately, mobile carriers and their suppliers repeat all the arguments against opportunistic access to unused spectrum capacity made during the 3.5 GHz proceeding,” the public interest groups replied. “The Commission should once again reject these make-weight complaints, as it did in the context of the 3.5 GHz proceeding.”
NCTA said the FCC should allocate part of the high-frequency spectrum, particularly the 64-71 MHz band, to unlicensed use. “Unlicensed spectrum bands have become our country’s most productive and innovative spectrum resource, and commenters agree that a central part of this proceeding should be to designate new unlicensed frequencies in the bands above 24 GHz,” NCTA said. “This will allow existing high-frequency unlicensed operations room to grow and will foster the development of new unlicensed technologies.” NCTA said innovative sharing systems “have great potential not only to protect incumbent users, but also to promote the most efficient and intensive use of the bands above 24 GHz by enabling opportunistic unlicensed access.”
SAS technology “represents the fusion and evolution of a number of time-tested technologies -- including propagation modeling, radio environment sensing, cloud computing, and cognitive radio -- and the Commission should thus use this proceeding to continue this evolution by fully exploiting these technological advancements,” Federated Wireless said. The approach would work in the bands looked at in the NPRM and also in other high-frequency bands, the company said.
TechFreedom said the FCC should use a mix of approaches in devising rules for the spectrum. At stake in the proceeding is the future of 5G in the U.S. and whether the U.S. emerges as the world’s 5G leader, TechFreedom said. The three-tiered licensing formula used in the 3.5 GHz is “as of yet, largely unproven,” the group said. The FCC should “heed basic actuarial principles: instead of putting all its eggs into a single regulatory basket, it should instead distribute risk by utilizing a healthy mix of old and new ideas,” TechFreedom said.
The Competitive Carriers Association said carriers need more spectrum to roll out 5G service. “CCA strongly supports the Commission’s efforts to identify and allocate additional spectrum for mobile broadband services, and stresses the importance of making this spectrum available on a fair and equal basis to competitive carriers,” the group said. The licensing rules are critical, CCA told the FCC. The agency should adopt a license period of at least 10 years for mobile licenses in the 28, 37 and 39 GHz bands with expectancy for renewal, relatively small license sizes, and “flexible performance and construction requirements,” the group said. Interoperability for devices operating within each high-frequency band is important and the new bands should be added to the FCC spectrum screen “on a by-band basis when considered suitable and available,” CCA said.