AT&T commended the FCC’s “innovative proposals” for spectrum...

of the 3.5 GHz band as spectrum sharing laboratory (CD July 16 p4). Comments were posted Monday and Tuesday in docket 12-354, but were unavailable part of Tuesday because of Electronic Comment Filing System problems at the FCC as it was inundated with net neutrality comments (CD July 16 p1). “Given that the SAS structure is the first of its kind, the model will presumably need to undergo extensive testing and refinement prior to deployment, a process that could be time-intensive given the documented technical challenges,” AT&T said (http://bit.ly/1r3XruL). The carrier warned it’s impractical to rely on the SAS to make “dynamic -- as opposed to static” spectrum assignments for companies that pay to use the spectrum through a Priority Access License (PAL). T-Mobile said the FCC should use SAS, but only for General Authorized Access (GAA) users, who unlike PAL licensees would not pay for licenses through competitive bidding (http://bit.ly/1oYfxN4). T-Mobile also urged the FCC to set aside at least 40 percent of the spectrum for priority access users and utilize more traditional licensing mechanisms “using areas larger than census tracts, at fixed frequencies, and for terms greater than one year.” Google stressed the importance of reducing the size of the proposed exclusion zones to protect federal users of the spectrum in parts of the U.S. “As currently structured, these zones would deny six out of every ten Americans access to the 3.5 GHz band,” Google said (http://bit.ly/1narEbl). Because the band will be used primarily by small cells, the FCC can cut the size of the zones without potentially causing problems for incumbents, said the company. Google also urged the FCC to base Priority Access licenses on “interference protection requirements” rather than the census tracts proposed by the agency. “In the context of small cell deployments, census tract boundaries are not designed to set boundaries for small cell deployments and are not suited for that application; their use for this purpose would waste valuable spectrum resources,” Google said. First and foremost, the FCC should guarantee that use of the spectrum doesn’t pose problems for cable companies, which depend on the 3.7-4.2 GHz band for the delivery of video, NCTA said. NCTA also urged the FCC to reduce the size of the exclusion zones established to protect federal users. “Because these exclusion zones assume that commercial operations would take the form of traditional macrocell deployments rather than small cell networks, the Commission should work quickly to determine appropriately sized exclusion zones for this band instead of codifying severe operating restrictions,” NCTA said (http://bit.ly/1l3iCqQ).