Comments Divided on Best Approach for Making Inventory Spectrum Available

CTIA said there's no suitable alternative to making additional licensed, full-power spectrum available for 5G. “A temporary halt of auction authority should not derail” a “commitment to the benefits of licensing the Inventory Spectrum,” CTIA said. The grant of STAs is a “reasonable interim solution,” the group said, noting the FCC’s success in making some spectrum available that way during the COVID-19 pandemic.

“STAs can be beneficial for niche and temporary use cases and might present a framework for enabling near-term access to otherwise fallow Inventory Spectrum while the Commission awaits authority to auction these frequencies,” CTIA said. Spectrum sharing isn’t the answer, the group said: “Currently available complex sharing frameworks have not proven effective in promoting investment or deployment.”

The FCC should rely on STAs to enable the use of inventory spectrum until auctions can again occur, said AT&T. STAs are “a win-win: not only will the Commission retain the ability to auction this spectrum down the road, but a temporary use framework will provide interim access to entities that are able and motivated to rapidly put the spectrum to use for the benefit of wireless users,” AT&T said. The carrier also opposed relying on dynamic spectrum sharing or non-exclusive site-based licensing. Those alternatives "would be complicated and time-consuming to put in place and would not enable the highest and best use of the Inventory Spectrum in the short or long term.”

The Dynamic Spectrum Alliance called for sharing, similar to the general access tier of the citizens broadband radio service band, coordinated by a dynamic spectrum management system (DSMS). Nonexclusive licensing supported by automated DSMS is “the best path” to increase spectrum access and intensive use by a wide range of new users, the alliance said. “At its core, an automated DSMS is a software-based embodiment of the Commission’s rules for protecting incumbents and facilitating coordination among users while enabling broader access and more intensive use.”

“A light-touch DSMS tool can be readily adapted from existing, proven solutions to address challenges such as the protection of other co- and adjacent channel licensed users in a variety of frequency bands, and to facilitate co-existence amongst new users,” said Federated Wireless. The company urged the FCC to build on models adopted in CBRS and in the 6 GHz band. Use of a DSMS would provide “modernized frequency coordination and band access management while leveraging a high degree of automation to enable efficient and intensive sharing among users, minimize barriers to entry, and accelerate deployments,” Federated said.

The Open Technology Institute at New America and Public Knowledge noted that modern wireless communications rely more on unlicensed spectrum than exclusively licensed bands. More than 90% of data and calls are carried on spectrum that’s “either shared or, in a few cases (e.g., broadcasting channels), assigned before the advent of auctions,” the public interest groups said. The share of data offloaded on Wi-Fi is “likely to increase further as new high-bandwidth applications, such as augmented and virtual reality (AR/VR) are used most frequently at home, work and other indoor locations,” they said.

The Wireless ISP Association called for dynamic sharing in the 12.2-12.7 GHz band and creating an application window for unused 2.5 GHz licenses. WISPA said the FCC should view the alternatives approaches not as a “stop-gap,” but “rather as long-term alternatives for enabling access to spectrum that would otherwise likely continue to lie fallow even after the Commission’s auction authority is restored.”

In some bands used by its members, assignments could be coordinated on an exclusive, county-by-county basis by current FCC-certified frequency advisory committees, the Enterprise Wireless Alliance said. “The migration of many users from conventional to trunked systems and from analog to digital technology has made exclusive spectrum assignments as important for narrowband/wideband systems as they are for commercial broadband operations,” EWA said.

T-Mobile countered that the FCC should view the expiration of auction authority as temporary and focus on STAs. “Avoid implementing complex spectrum access regimes such as dynamic spectrum sharing, non-exclusive site-based licensing, and spectrum leasing for the temporary use of Inventory Spectrum,” T-Mobile said. Verizon agreed: “Acquiring commercial wireless licenses at auction comes with a high-dollar price tag that creates incentives to make full use of those frequencies and to invest heavily in highly efficient wireless network technologies that make the most of them.”