Wireless, Satellite Commenters Urge Caution on Proposal for Mid-Band Spectrum
Some commenters asked the FCC to delay deciding on a proposal for the 3.7-4.2 GHz band by the Broadband Access Coalition (BAC) in light of the now-pending notice of inquiry on mid-band spectrum. The coalition, led by Mimosa Networks, the Wireless ISP Association and New America’s Open Technology Institute, offered its proposal in June (see 1706210044). Since the spectrum is mainly used by fixed satellite services (FSS) operators, satellite operators raised a red flag. The FCC also has before it a rival plan offered by an Intel-led coalition (see 1707120043). Comments are in RM-11791.
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The West Michigan Wireless ISP was among WISPs asking the FCC to adopt the proposal. "We are always in need of spectrum to increase end user performance,” the WISP commented. “With the rise of direct video streaming, clients need higher throughput. … There is limited spectrum to provide ‘last mile’ service to our clients, especially at power levels that have reasonable foliage penetration.”
“Grant of the request will offer consumers and businesses badly-needed options for broadband delivery, particularly in areas that current providers choose not to serve, while preserving the utility of the band for its present applications,” said the Fixed Wireless Communications Coalition. "We concur with the BAC that any efficient use of the band is predicated on eliminating the extreme inefficiencies of FSS full-band, full-arc coordination.”
The Competitive Carriers Association said the FCC should look closely at both major proposals for the mid-band that have been suggested so far. “CCA supports the Commission’s efforts through the NOI to explore all avenues for potential use of the band,” the group said. “In light of the existing and potential future proposals the Commission may receive in response to the NOI, CCA notes the importance of gathering all relevant information before acting on the important mid-band spectrum.” CTIA offered a similar take: “Given that the underlying spectrum issues raised in the Petition are subsumed in the Mid- Band NOI, the Petition should only be considered, at most, in the context of that proceeding."
T-Mobile also asked the FCC to look at the petition as part of the broader NOI. “T-Mobile and others continue to evaluate how the 3.7-4.2 GHz band can be used as part of a 5G mid-band solution, and T-Mobile consequently applauds the Commission’s recent release of the NOI,” said a filing. “Grant of the Petition, however, may limit the opportunity to fully explore use of the band.”
Having accurate data on population and area that would be affected by a proposed fixed satellite service earth station in the 28 GHz and 37/39 GHz bands in an upper microwave fixed use service license area is the key to letting FSS use those bands, Hughes, Inmarsat, OneWeb, SES/O3b and Telesat said. They said such data would facilitate multiple earth stations in an UMFUS service area and give UMFUS licensees a better picture of where they can expect 28 GHz band interference or need to protect an earth station receiving in the 37/39 GHz band. The operators backed applying actual area method to census block data to calculate populations affected by an antenna, but census block data might not be granular enough and applicants should be allowed to provide additional, verifiable data such as satellite imagery. They said any apportionment of a population limit among earth station operators in an UMFUS license ara would unnecessarily limit potential earth station operations.
ViaSat said most commenters agree with using census block level data for population coverage calculations, but a proposal to work with the Census Bureau to develop a new population calculation tool raises the specter of delay and uncertainty in earth station license processing while not making clear why such new tools are needed when others exist. It said market forces should motivate collocation of earth stations.