7/15 Joint FCC Comments Supporting Sharing Lower 37 GHz Spectrum Using an Automated Coordination Database

The Open Technology Institute and Public Knowledge have long maintained that mmWave spectrum is “well-suited for a sharing framework that is open, non-rivalrous, and that borrows elements from both CBRS and the 70/80/90 GHz bands,” relying on a light-licensing coordination approach where operators first obtain a nationwide, non-exclusive license and then register and coordinate their site-by-site deployments through an automated spectrum management system. We support making the Lower 37 GHz band immediately available to operators ready to deploy, but urge the Federal Communications Commission to begin a rapid transition to an automated database coordination system. Such an automated system would be more cost-effective, promote innovation, and lead to far more efficient use of spectrum in the long run.

An automated database coordination mechanism can be modeled on the 70/80/90 GHz system, which is simple, fast, fully transparent, and also incorporates automated coordination with federal users through an interface with NTIA. Initially, we suggest that the certification of a single database provider, coupled with a requirement of reasonable and uniform coordination fees, would be most likely to result in a sustainable model until such time as stakeholders demonstrate more extensive use of the band.