Comments Stress Importance of Dynamic Sharing of Lower 37 GHz Band
Public Knowledge and New America’s Open Technology Institute urged the FCC to move to a modern spectrum-sharing framework, with an automated, third-party database, to manage the lower 37 GHz band. The groups this week filed joint comments in docket 24-243 on an April Further NPRM from the FCC (see 2507150060).
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The public interest groups support the framework adopted by the commission, “but only as an intermediary step toward an automated light-licensing coordination mechanism in the near future, with more dynamic features added later on as appropriate,” they told the FCC. “An automated database coordination mechanism can be modeled on the 70/80/90 GHz system, which is simple, fast, fully transparent, and also incorporates automated coordination with federal users through an interface with NTIA,” they said.
The Dynamic Spectrum Alliance agreed that the FCC should push for a dynamic spectrum management system (DSMS) to facilitate efficient sharing in the band. Alliance members “have extensive experience in the development and implementation of innovative, non-exclusive licensing frameworks, supported by automated DSMS tools,” the filing said. “We believe that the experience gained” in other shared bands “can be tailored to meet the specific opportunities and challenges of the Lower 37 GHz band.”
Adoption of a DSMS “is the proper long-term solution for managing access to and use of the Lower 37 GHz band,” WISPA said. “The experiences of the Commission and industry in developing spectrum sharing models in other bands can be leveraged to develop an effective DSMS for the Lower 37 GHz band,” WISPA said. The group said sharing software, technologies and protocols used in the 6 GHz and citizens broadband radio service band could be reused “to facilitate development.”
SpaceX said as an operator authorized to use part of the band for its next-generation satellite system, the company has “a strong interest in ensuring that the licensing framework” for the band “is as streamlined, transparent, and efficient as possible.” The FCC has “already found that the propagation characteristics of this band support a flexible, non-exclusive licensing approach, and the record broadly supports a model that extends the light-licensing framework adopted in the 70/80/90 GHz bands to the Lower 37 GHz band,” SpaceX said.