10/29 FCC Broadband Access Coalition Comments 3.7-4.2 GHz Band

OTI's Wireless Future Project wrote and submitted comments to the Federal Communications Commission ("Commission") on behalf of the Broadband Access Coalition ("BAC"), including All Points Broadband, American Library Association, Amplex Electric, Baicells Technologies, Cambium Networks, Consumer Federation of America, ConVergence Technologies, Inc., Cincinnati Bell Inc., Ethoplex, ITTA – The Voice of America’s Broadband Providers, Intelliwave, Intelpath, JAB Wireless, Inc. dba Rise Broadband, Mimosa Networks, Inc., NTCA – The Rural Broadband Association, Open Technology Institute at New America, Public Knowledge, Quantenna Communications, Red Spectrum Communications, LLC, Schools, Health & Libraries Broadband Coalition, Sho-Me Power Electric Cooperative, SpeedConnect, Wisper, ISP, Inc., Telrad Networks Ltd, US Internet, and WISPA. The comments urge the Commission to use the 3.7-4.2 GHz for an authorized, licensed, point-to-multipoint (P2MP) fixed wireless service to bring high-speed broadband access to rural and underserved areas of the United States.

The BAC comments, which support the proposal floated by the Coalition in a June 2017 petition, focus on how implementing fixed wireless service in the 3.7-4.2 GHz band will help bridge the digital divide and improve broadband access and availability in rural and other hard-to-serve areas. The BAC also highlight how authorization of a P2MP fixed wireless service in the band would not be harmful to the incumbent fixed satellite services that operate in the band currently. A summary is copy and pasted below:

The digital divide is real, and it is persistent. To enable next-generation broadband service in rural America, we need not just subsidies, but spectrum, infrastructure, and competition policy working together to enable rural Americans to have the same access to digital opportunities as urban Americans. While the Commission has worked hard to ensure that infrastructure and subsidy policies align in order to cost-effectively support rural broadband, this proceeding offers the opportunity to ensure that sufficient spectrum is available for all rural Americans to enjoy more robust digital opportunities. This proceeding is about more than 5G, video distribution, or who gets what spectrum: it is about taking a balanced approach that accounts for the needs of rural Americans and creates opportunities for all Americans. And, it is why a broad and diverse coalition of rural providers, equipment manufacturers, technology companies, and consumer groups have come together to propose a balanced approach.

The Broadband Access Coalition (“Coalition”) recognizes that winning the “race for 5G” is an important federal objective. However, critical as they are, mobile 5G networks will be just one component of the robust 5G ecosystem that is needed to connect every American home and business nationwide. Connecting the 24 million Americans that lack high-throughput broadband access in their homes is also a national priority – indeed, “closing the digital divide [is Chairman Pai’s] top policy priority as FCC Chairman.”1 With 500 megahertz of 3.7 – 4.2 GHz (“3.7 GHz band”) spectrum on the table and little more mid-band spectrum in the short-term pipeline, maintaining inefficient and antiquated “full-band, full-arc” protection for fixed satellite service (“FSS”) would foreclose realization of the myriad consumer benefits of P2MP – a poor policy choice and a wasted opportunity.

In an effort to find a balanced approach, the Coalition has devised and supports a “winwin-win” solution that: (1) protects incumbent FSS operators from harmful interference, (2) clears 200 megahertz in the lower portion of the band for exclusive flexible use licensing, and (3) makes available, on a shared, frequency-coordinated basis with FSS, 300 megahertz of spectrum in the upper portion of the band for fixed P2MP broadband providers to deploy much-needed high-throughput broadband to unserved and underserved customers, particularly in rural areas.

Making available 300 megahertz in the 3.7 GHz band for licensed fixed wireless access will enable service providers to quickly, cost-effectively and intensively deploy gigabit or neargigabit broadband service to rural Americans. By contrast, making available only 40 or 100 megahertz of spectrum for shared P2MP service will be wholly insufficient for vendors to invest in and develop equipment for the band and for operators to deploy broadband and other fixed wireless services in the band.

Importantly, intensive P2MP use can begin very soon after the new rules become effective. Development of equipment will benefit from equipment already being used in the adjacent 3650 – 3700 MHz band and soon to be widely deployed in the 3550 – 3700 MHz band. The existing Part 101 frequency coordination processes can easily incorporate the addition of P2MP at this time while a transition to more automated coordination procedures is implemented. That said, the Coalition sees no need for a coordination system as complex as the Spectrum Access System (“SAS”) developed for the CBRS band, which was conceived to dynamically reassign shared frequencies, to protect Federal shipborne and ground-based radar systems, and to accommodate two types of flexible use. Those dynamic spectrum management features are not applicable in the 3.7 GHz band. The SAS is far more complex than any automated system required for P2MP operations in the 3.7 GHz band where there are no Federal incumbents and operators will be transmitting from fixed points to other fixed points, and operating on specific pre-coordinated licensed channels.

Since the coordination process will work equally well for any unused portion of the 3.7 GHz band, P2MP should also be authorized on an opportunistic basis in the lower 200 megahertz of the band. P2MP operators would be required to vacate the spectrum upon deployment of licensed flexible use services in the relevant geographic area.

Fixed P2MP service remains the most cost-effective way to bring broadband service to millions of Americans, primarily in rural areas. Fiber-based solutions cannot be built without substantial public subsidies in areas where population density on a per-road-mile basis is low. Capital costs to deploy fixed wireless systems are a fraction – about one-seventh the cost – of fiber and are still able to provide high-throughput broadband service. Fixed wireless solutions are also far more cost-effective per gigabyte for this purpose than mobile systems.

The Coalition has repeatedly demonstrated that fixed P2MP broadband service can successfully share the 3.7 GHz band with FSS operators. Unlike mobile terrestrial deployments, fixed wireless operators have the ability to coordinate use of spectrum on a localized basis and by sector, taking advantage of various methods, including antenna directionality and terrain shielding, to avoid interference to earth stations.

At present, the 3.7 GHz band is severely underutilized, primarily as a result of the antiquated “full-band, full-arc” licensing policy that requires protection for every satellite earth station across the entire 500 megahertz of the 3.7 GHz band and thereby restricts frequency coordination. In fact, a typical FSS earth station uses far less spectrum, as little as 23 megahertz, and does not communicate with the full panoply of orbital locations. As a result, the Coalition strongly supports the Commission’s proposal to eliminate “full-band, full-arc” protection. The Coalition also strongly supports the Commission’s proposal to “develop a more complete record on existing FSS operations in [the 3.7 GHz] band [by requiring] earth station operators to file additional information on their existing facilities.”2 This information is absolutely critical to maximize sharing of the band by terrestrial users.