The FCC’s rules for shared use on the...

companies said they support the three-tiered framework proposed in the President’s Council of Advisors on Science and Technology’s (PCAST) July 2012 report. Government users would remain the primary incumbents; secondary exclusive users would be required to protect government users, while general access users would be allowed to use the band only when neither government nor secondary exclusive users were using it. A three-tiered framework “will protect incumbents, ensure secondary exclusive use for those with a need for especially reliable, uninterrupted access, and permit innovative unlicensed access where 3.5 GHz spectrum is not otherwise in use,” AT&T and Google said. The companies recommended the FCC establish broad eligibility for the secondary exclusive tier. The FCC’s NPRM proposes limiting the tier to “critical users.” The FCC should instead open the tier up to any applicant that “commits to a substantial service requirement,” AT&T and Google said. The companies said they backed using a spectrum access database to manage the three-tiered framework, saying “appropriate device certification and registration along with existing database technologies can be used to assign frequencies dynamically and mitigate interference where incumbent uses are geographically known.” The companies said they agree with the FCC that the exclusion zones calculated for the 3.5 GHz band should be based on small cell deployments rather than macrocells. NTIA had recommended calculating exclusion zones based on macrocell deployments, but the band is better suited to small-cell use, AT&T and Google said. “NTIA’s proposed zones are overprotective in the small-cell context, and the FCC can reduce exclusion zones dramatically if it designates the band for use by small cells rather than macrocells,” the companies said. The FCC should calculate protection zones “based only on the interference tolerance of incumbent operations, not the tolerance of potential new operations,” AT&T and Google said. Incumbents have a need for protection from harmful interference, while new entrants on the band have chosen to operate in an environment where harmful interference might occur, the companies said. The FCC should institute “lightweight, fast, and flexible auction mechanisms” when they are needed to resolve mutually exclusive demands for spectrum licenses, AT&T and Google said. Streamlined auction procedures would be appropriate for small cell deployments, they said ((http://bit.ly/13hYAAf). AT&T continues to support government efforts to clear and license spectrum below 3 GHz, particularly on the 1755-1780 MHz band, but the FCC’s proposal for use of the 3.5 GHz band provides “an interesting opportunity for mobile broadband operators to explore spectrum sharing models,” said Stacey Black, AT&T assistant vice president-federal regulatory, in a blog post. “Even on a shared basis, spectrum in this band could be critical to increasing capacity in high demand areas and improving coverage inside buildings or other difficult to cover areas, all without causing interference to incumbent government users” (http://bit.ly/13hYAAf).