Commenters Urge FCC to Develop Sharing Rules for Lower 37 GHz Based on Other Bands
Groups and companies urged the FCC to move forward to complete rules for the lower 37 GHz band, including adopting a dynamic spectrum management system (DSMS) based on experience in other shared bands. Reply comments were due Monday and mostly posted Tuesday in docket 24-283. In a 4-0 vote in April, FCC commissioners approved an item aimed at spurring greater use of the 37 GHz band, which the Biden administration had targeted for repurposing (see 2504280032).
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The FCC should “state its intention” to adopt DSMS in the lower 37 GHz and other bands, said Federated Wireless. The company disagreed with some commenters' recommendation to delay DSMS implementation, “citing concerns about complexity and timing,” it said. “A DSMS is neither overly complex nor rigid” and offers “a generalized, modular architecture that can be tailored to the specific needs of any band,” the company said. In the case of the lower 37 GHz, “the absence of incumbent users removes a major source of technical complexity.”
SpaceX said there was unanimous support in initial comments for extending “the proven light-licensing framework used in the 70/80/90 GHz bands to streamline licensing” in the lower 37 GHz band. “The Commission should expeditiously implement this consensus approach to unleash the full spectrum of benefits the band can support as soon as possible.” Adding the lower 37 GHz band to the existing light-licensing framework “would enable the Commission to more quickly put the Lower 37 GHz band to productive use rather than delaying while it designs a new licensing portal, coordination rules, and dispute resolution regime,” SpaceX said.
Starry, which uses the band for its fixed-wireless service, agreed that consensus was building for making the spectrum available quickly, using the already-adopted two-phase coordination process. "In addition, commenters support the use of third-party coordinators to run the … process, with development of any dynamic sharing capability happening in parallel and not displacing the two-phase process,” Starry said.
In implementing a transparent, third-party database portal for Phase 1 interference coordination, the commission “should ensure that the portal be as robust as possible because it may take some time before DSMS is implemented for the band,” WISPA said. "DSMS will provide more accurate and efficient coordination among users of the band and allow for more intensive use of the band, including greater access by new users. As DSMS represents a long-term solution, the Commission should adopt a transition process that includes overlap between the initial two-phase coordination process and DSMS before a later migration to DSMS.”
Verizon opposed more stringent out-of-band emission limits, as proposed by the National Academy of Sciences’ Committee on Radio Frequencies (see 2507150060). “The record here is near unanimous that the current limit remains sufficient, and no sound evidence supports a contrary view,” Verizon said. “The sole advocate for a more restrictive limit has failed to produce any evidence of actual harm to passive sensors operating below 37 GHz despite significant commercial wireless deployments above 37 GHz, and its technical analysis relies on faulty assumptions in modeling expected interference.”