Spectrum Strategy Commenters Disagree on Licensed vs. Unlicensed Use Benefits

“To secure America’s economic competitiveness and our 5G leadership, it is critical that NTIA take the leading role in completing timely studies of the lower 3 GHz and 7/8 GHz bands and establish a specific timeline for auctions of full power, exclusive use mid-band spectrum within the next ten years,” CTIA said. NTIA should define the study process and responsibilities, “including ensuring all options for commercial access are studied” and incorporate lessons from previous spectrum analyses, the group said.

“NTIA’s Implementation Plan must now provide a blueprint for delivering on the Strategy’s promises,” CTIA President Meredith Baker added: “To secure America’s economic competitiveness and our 5G leadership, it is critical that NTIA take the leading role in completing timely studies of the lower 3 GHz and 7/8 GHz bands and establish a specific timeline for auctions of full power, exclusive use mid-band spectrum.”

AT&T also stressed the importance of making more spectrum available for carriers' full-power licensed use. “A study is not a spectrum strategy, nor is it a pipeline,” AT&T reminded NTIA: “While opportunistic, interruptible spectrum uses under low power and unlicensed-like sharing regimes might avoid tough choices, they will not serve the national imperative to make more spectrum available for full-power, wide area network use.”

The Information Technology and Innovation Foundation said the spectrum strategy would be a failure to the extent federal agencies can resist giving up any access to the spectrum they are using. “Require the cooperation of federal incumbents in identifying actual capacity needs, technological upgrades that could reduce capacity needs, and alternative spectrum that agencies could use,” the group said. ITIF also advised focusing on receiver performance, which the FCC is doing (see 2304050046): “In some cases, higher-performing receivers can reduce interference conflicts and, therefore, facilitate both commercial use and the resiliency of federal missions.”

Dynamic Sharing

Dynamic spectrum sharing is key to spectrum's future in the U.S., NCTA said. The 3.1 GHz band is ripe for sharing similar to that in the citizens broadband radio service band, the cablers said. NCTA also suggested targeting the 7.125-8.4 GHz range and 37.0-37.6 GHz band.

NCTA said the U.S. wireless market is highly concentrated, with major carriers owning most spectrum licenses. “NTIA can best enable participation by new and innovative entrants by working with the FCC to expand the number of shared-licensed and unlicensed bands,” it said: “Shared spectrum is the key for growth in the private wireless networks that are the future for manufacturing, automotive, agriculture, energy, retail, commercial real estate, communications, media, and supply chain industries -- as well as schools, libraries, and civil society.”

Public interest groups called on policymakers to set aside 7125-7250 MHz for unlicensed low-power indoor use, focus on shared use of the lower 37 GHz band and develop a sharing framework for the lower 3 GHz band. “Our primary recommendation is that NTIA prioritize and fast track” the bands “for shared Federal and non-Federal use in a far shorter period than the two years the Strategy deems necessary for its study overall,” said the Open Technology Institute at New America, Public Knowledge and the Schools, Health & Libraries Broadband Coalition.

The OnGoAlliance, focused on CBRS, saying that a sharing model would make sense for other bands NTIA is examining. “While each band will have unique challenges, and while sharing techniques may be optimized to maximize commercial access without jeopardizing incumbent operations, the fundamental principles and capabilities that make the CBRS sharing framework a success can be ported to new bands,” the alliance said.

“Commercial access to a variety of spectrum is essential for the development and consumer use of innovative products and services,” said CTA. “CTA urges NTIA to use its leadership role to improve regulatory certainty for businesses by improving the process by which federal agencies reach consensus on and determine Federal spectrum policy.”

“Focusing on a shared framework with power levels akin to CBRS provides the most obvious and meaningful path for the Administration’s success in making spectrum available in the 3.1-3.45 GHz band,” said Spectrum for the Future, a pro-sharing interest group. The CBRS band’s proximity to lower 3 “and similar presence of federal incumbent users … means that much of the equipment, spectral properties, and sharing techniques can be appropriately modified for deployment in the 3.1-3.45 GHz band without the need to reinvent the wheel,” the group said.

The Wireless Infrastructure Association stressed the importance of eliminating barriers to wireless buildout. "We have seen numerous measures to delay, or even outright ban, wireless telecommunications,” WIA said: In some states “we routinely see ‘setback’ bills that limit where wireless infrastructure can be deployed either explicitly or implicitly due to concerns about RF emissions.”

The Wireless ISP Association offered a list of action items for the NTIA. It should work with the FCC to finalize the 5.9 GHz proceeding and to open 500 MHz in the 10 GHz band “for point-to-point secondary use on a shared basis with federal and amateur users,” WISPA said. “Schedule multiple public listening sessions and roundtables among stakeholders on the best approaches to implementing the near-term elements of the Strategy,” the group advised: “Solicit public comment on initial draft plans for spectrum transition in bands identified for near term reallocation or enhanced use.”