OTI and PK Submit Joint Comments on the Use of Spectrum Bands Above 24 GHz for Mobile Broadband Services

New America’s Open Technology Institute (“OTI”) and Public Knowledge (“PK”) submit these Comments in response to the Commission’s Notice of Proposed Rulemaking concerning the use and appropriate allocation of spectrum in the bands above 24 GHz. OTI & PK appreciate the Commission’s initiative to anticipate the development of future technologies that will make these millimeter wave (mmW) bands useful for the provision of high-capacity mobile device data services. As consumer advocates, our groups believe that the public interest goals of promoting innovation, market entry, competition, intensive spectrum reuse, and diverse uses and users are best served by extending the three tier spectrum access framework the Commission has adopted for the 3.5 GHz Citizens’ Broadband Radio Service to ensure that there is an appropriate mix of licensed, unlicensed and dynamic shared access to what will otherwise be grossly-underutilized mmW spectrum.