11/16 FCC Reply Comments on Spectrum Policy to Benefit the Internet of Things

New America's Open Technology Institute wrote and filed reply comments alongside Public Knowledge with the Federal Communications Commission ("Commission") reiterating arguments for flexible-use and unlicensed spectrum allocations of spectrum bands to benefit the burgeoning Internet of Things (IoT). Unlicensed spectrum and innovative dynamic spectrum sharing frameworks such as the Citizens Broadband Radio Service Band in the 3.5 GHz band that catalyze competition and a diverse set of use cases and entities building their own enterprise networks offer the most robust foundation through which IoT networks can flourish. Ensuring the Commission continues with precedent of technology-neutral spectrum band allocations would benefit the development of IoT networks as well. An introduction and summary is available below:

New America’s Open Technology Institute and Public Knowledge (“OTI and PK”) respectfully submit the following reply comments in the above-captioned proceeding to highlight the importance of open access to unlicensed and dynamically shared spectrum in fueling the future of the Internet of Things (“IoT”). The record shows strong support for an expansion of direct access to shared spectrum in more bands to support IoT innovation and deployment by an increasingly diverse range of local users. Extending dynamic spectrum sharing frameworks to additional bands in low-, mid- and high-frequency spectrum clearly benefits the public interest as it promotes the most efficient and effective use of the airwaves while simultaneously stimulating competitive access to a resource traditionally dominated by the largest mobile carriers.

The record also demonstrates widespread support for the view that technical rules adopted with the intention of supporting IoT applications should be as technology-neutral as possible to ensure maximum flexibility. Open access to flexible use of shared spectrum benefits the broadest set of stakeholders, including community anchor institutions, individual enterprises and venues, small rural and tribal broadband providers, and satellite companies. OTI and PK agree with the many parties proposing that the Commission expand sharing frameworks such as the Citizens Broadband Radio Service (CBRS) with new allocations—most urgently in the lower 3 GHz band—to support IoT applications.

The record also shows broad agreement, including among mobile carriers and the technology industry, that unlicensed spectrum will play a critical role in the success of the Internet of Things. Unlicensed spectrum is especially relevant to smart home and enterprise networks where most of the applications will be used by consumers indoors. In addition, the benefits of unlicensed spectrum extend to IoT services for many higher-power and outdoor applications, such as precision agriculture and system monitoring. To this end, the Commission has the opportunity to make an immediate impact on the development and efficiency of IoT networks by expeditiously completing the agency’s historic expansion of unlicensed spectrum access in the 5.9 and 6 GHz bands. Wide and contiguous bands of open, unlicensed spectrum will continue to be the workhorse of the internet ecosystem, and this will be more true than ever for the Internet of Things. PK and OTI encourage the Commission to resolve the remaining issues in the 6 GHz FNPRM issues and certify AFC systems for outdoor unlicensed use as rapidly as possible.