7/14 FCC Ex Parte Letter Submitting 5.9 GHz Policy Paper

New America's Open Technology Institute filed an ex parte letter with the Federal Communications Commission ("Commission") to reiterate arguments made urging the agency to open up the 5.9 GHz band—currently largely unused—for unlicensed services to strengthen Wi-Fi. The letter submitted a policy paper written by the Wireless Future Project on the 5.9 GHz band, called "The 5.9 GHz Band Removing the Roadblock to Gigabit Wi-Fi." This follows sustained advocacy from OTI calling on the FCC to open the 5.9 GHz band, including comments and reply comments earlier this year and a report from 2016 on the same topic. Opening this spectrum is crucial to addressing the spectrum crunch unlicensed bands are experiencing due to the sheer volume—which is growing—of mobile data offload and an increasing number of connected devices in homes, schools, and businesses. Below is the text of the ex parte letter:

Dear Ms. Dortch:

With this letter the Open Technology Institute at New America (“OTI”) is submitting for the record a policy paper entitled The 5.9 GHz Band: Removing the Roadblock to Gigabit Wi-Fi, authored by myself and my colleague Amir Nasr.

The paper, which updates one we attached to Comments that OTI filed jointly with Public Knowledge on March 9, concludes that reallocating all 75 megahertz of the unused 5.9 GHz band for unlicensed use and authorizing V2X in a new public safety band can achieve the optimal win-win for consumers and the U.S. economy. The commission should consider moving at least the nascent Cellular V2X safety service to another band, particularly the 4.9 GHz band, to better harmonize V2X services with 5G networks and to ideally remove the current allocation of ITS as a roadblock to a contiguous and gigabit-fast Wi-Fi superhighway across the upper 5 GHz and 6 GHz bands. There is no need for a zero-sum trade-off between next generation Wi-Fi and auto safety. Consumers need both 5G-capable, next generation Wi-Fi and reliable auto safety communication.

Respectfully submitted,

/s/ Michael Calabrese

New America’s Open Technology Institute

740 15th Street, NW Suite 900

Washington, DC 20005