10/29 FCC Broadband Connects America 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 Connects America Coalition, including Center for Rural Strategies, South Carolina Office of Rural Health, Tribal Digital Village Network, Akaku Maui Community Media, South Central Alabama Broadband Cooperative District, Maine Broadband Coalition, Access Humboldt, School Health & Libraries Broadband (SHLB) Coalition, Citizens Connectivity Committee, American Library Association, Next Century Cities, Public Knowledge, Benton Foundation, and xLab. The comments urged the Commission to use the 3.7-4.2 GHz for an authorized, licensed, point-to-multipoint fixed wireless service to bring high-speed broadband access to rural and underserved areas of the United States. In the comments, the BCA Coalition highlights how rural areas lack high-speed broadband at much higher rates than urban areas, how this lack of access hurts rural economies, and how the introduction of high-speed broadband can catalyze rural areas. The Coalition further highlights how the proposal to utilize the 3.7-4.2 GHz band for fixed wireless service is particularly well-suited to help bridge this digital divide.

Executive Summary:

The Broadband Connects America coalition strongly agrees with the Commission‘s proposal to open unused spectrum in the 3.7-4.2 GHz band for a licensed, point-to-multipoint (P2MP) fixed wireless service that empowers providers to extend high-speed broadband to rural, tribal, small town and other underserved areas. The Commission‘s proposal to authorize coordinated, shared use of the 3.7 GHz band can achieve a win-win-win trifecta of critical public policy goals: first, to enable fixed wireless providers to bring high-speed broadband access to rural areas; second, to reallocate a substantial portion of the band for mobile 5G networks; and third, to protect incumbent Fixed Satellite Services (FSS) licensees from undue disruption or harmful interference.

The Commission should allow P2MP providers to coordinate shared use across the upper 300 megahertz of the band (3880-4200 MHz), on a first-in licensed basis. In addition, the Commission should authorize opportunistic access (e.g., license by rule) to any vacant frequencies in the lower portion of the band until such time as future ―flexible use‖ licensees notify the Commission or a frequency coordinator that they are deployed and ready to commence service in a local area. Unlocking every megahertz of the grossly underutilized C-band can help to remedy America‘s digital connectivity divide and serve as part of the foundation for a more inclusive and robust 5G wireless ecosystem.

High-speed broadband is increasingly central to most Americans as the gateway to education, employment services, entertainment, news, communication, health and financial services, as well as for e-commerce in the broader economy. However, rural Americans disproportionately lack access to high-speed broadband compared to people living in urban and suburban areas. The Commission‘s data shows a staggering divide—one that leaves nearly a third of rural Americans with no access to high-speed broadband. That data, alarming as it is, understates just how many rural Americans lack access to high-speed broadband services. Studies also show that rural Americans enjoy far less choice and competition in the broadband marketplace. They pay more for worse service than those who live in urban and suburban areas. Both of these gaps – connectivity and competitive choice – are likely to worsen if emerging 5G technologies are deployed only in more densely-populated and higher-revenue areas.

This high-speed broadband gap imposes distinct social and economic harms on small town and rural communities. The divide harms educational attainment, deepening the ―homework gap‖ between students in rural areas and those in urban and suburban areas. Studies suggest that poor or nonexistent broadband access in rural areas has played a central role in the trend of young Americans in particular to move away from rural and small town areas.

Conversely, the introduction of high-speed broadband in rural areas and smaller towns has been shown to boost economic prosperity. Studies show that high-speed and affordable broadband networks can improve local economies as well as the broader U.S. economy, enabling more business creation and better jobs. High-speed broadband is also increasingly integral to efficient and high-productivity farming. Modern-day agriculture is reliant on high-speed broadband, and bringing improved access to rural areas is critical to precision farming.

The Commission should address this digital divide by expeditiously moving to make unused spectrum capacity across the entire 3.7-4.2 GHz band available to providers ready to deploy fixed wireless broadband in underserved and high-cost areas. By authorizing coordinated, shared access to the 3.7 GHz band, the Commission can make available public ‗spectrum as infrastructure,‘ at no cost to taxpayers, to enable high-speed broadband to rural and other areas that are currently unserved or plagued by poor service. P2MP fixed wireless can bring highspeed services to rural areas at a much lower cost than trenching fiber, reducing costs for providers and prices for consumers. The Commission should rapidly authorize the coordinated sharing of all unused spectrum capacity in the 3.7-4.2 band for a new, licensed, point-tomultipoint (P2MP) fixed wireless service targeted at unserved and hard-to-serve areas.

Finally, the Commission can facilitate sharing within the band by authorizing an automated frequency coordination system that ensures no harmful interference for incumbent fixed satellite services, as well as the enforcement of temporary, opportunistic access to the lower portion of the band cleared for ―flexible use‖ licensing until such time as mobile carriers actually deploy and commence service in rural and tribal communities.