6/15 Reply Comments on Shared Access to C-band at 3700-4200 MHz on behalf of the Broadband Access Coalition

The Open Technology Institute at New America filed reply comments as part of the Broadband Access Coalition urging the Federal Communications Commission to adopt flexible rules for fixed wireless services in the 3.7-4.2 GHz band. In the filing, the Broadband Access Coalition highlighted a compromise that would address the concerns of fixed satellite incumbents, while also opening up spectrum to improve rural broadband. An introduction and summary is copy and pasted below:

The Broadband Access Coalition (“BAC” or “Coalition”) hereby submits Reply Comments to address initial comments filed in response to the Public Notice seeking comment on the feasibility of allowing commercial wireless services to use or share the 3.7-4.2 GHz band. In sum, the record shows that there is strong support for the Commission to consider spectrally efficient sharing among existing and prospective users of the 3.7-4.2 GHz band to promote the public interest in providing high-speed fixed broadband service to consumers across the country, especially those in rural communities that lack access.

The BAC supports a “win-win-win” solution that: (1) protects incumbent Fixed-Satellite Service (“FSS”) providers from harmful interference; (2) clears a portion of the band (e.g., 3.7- 3.8 GHz) for exclusive licensing by mobile 5G providers in densely populated urban areas; and (3) enables fixed point-to-multipoint (“P2MP”) broadband wireless providers to deploy badly needed high-throughput broadband to unserved and underserved consumers, particularly in rural areas. The Coalition’s proposal for sharing among FSS and P2MP services, are not inconsistent with other proposals to clear a portion of the band for mobile licensing.

The Coalition has repeatedly demonstrated the feasibility of allowing commercial licensed P2MP fixed wireless broadband services to share use of the 3.7-4.2 GHz band while fully protecting FSS and Fixed Service (“FS”) incumbents from harmful interference through Part 101 frequency coordination. The BAC’s Petition for Rulemaking (“Petition”) proposed specific and concrete rule changes that would enable the immediate introduction of P2MP fixed wireless broadband service into the 3.7-4.2 GHz band.2 The diverse nature of the thirty-plus members of the Coalition manifests strong support for the flexible use opportunities that adopting the proposals in the Petition would foster.

In this same vein, the Commission should reject arguments that would only clear a portion of the band for 5G services without enabling sharing of the rest of the band for fixed P2MP services. Such an outcome would short-change millions of rural Americans that lack broadband access in their homes, farms and businesses. The Coalition’s approach serves the twin objectives of fostering 5G and P2MP services. The upcoming rulemaking proceeding presents a golden opportunity for the Commission to make a significant amount of spectrum available for connecting the unconnected – a policy priority for Congress and the Commission.