10/2 FCC Comments on Mid-Band Spectrum Notice of Inquiry on Behalf of Broadband Access Coalition

The Open Technology Institute at New America filed comments with the Federal Communications Commission (FCC) on behalf of the Broadband Access Coalition on a Notice of Inquiry about the use of mid-band spectrum. In the comments, OTI urges the FCC to issue a rulemaking to authorize a new, licensed, point-to-multipoint fixed wireless service in the underutilized 3700 - 4200 MHz spectrum band that is currently occupied primarily by fixed satellite services. OTI called for the FCC to implement a spectrum sharing framework in this band in a petition with the Broadband Access Coalition in June. A summary of the comments is below:

As a critical first step to achieve the over-arching objectives of the Mid-Band NOI, the Coalition urges the Commission to expeditiously issue a Notice of Proposed Rulemaking (“NPRM”) to authorize the deployment of high-throughput, licensed, point-to-multipoint (“P2MP”) fixed wireless broadband services in the 3700 – 4200 MHz band.  These P2MP links can facilitate the rapid deployment of much-needed gigabit and near-gigabit fixed broadband service to rural and other underserved areas.

On June 21, 2017, the Coalition filed a Petition for Rulemaking (the “Petition”) proposing to amend and modernize Parts 25 and 101 of the Commission’s Rules to enable deployment of high-throughput, licensed P2MP fixed wireless broadband services in the 3700 – 4200 MHz band in a spectrally efficient manner, while protecting Fixed-Satellite Service (“FSS”) and Fixed Service (“FS”) incumbents from harmful interference through frequency coordination.  The vast majority of the hundreds of Comments filed enthusiastically supported the Petition, recognizing that the availability of a significant amount of mid-band spectrum can help satisfy the urgent need to make better broadband available to rural and other underserved Americans.

 In its Reply Comments, Alphabet Access offered further support for the Petition:

[The Coalition] has proposed a straightforward set of modifications to the Part 101 rules that would allow [P2MP] broadband access in the 3700 – 4200 MHz band.  Because these modifications do not represent fundamental changes to Part 101, and would produce a well-understood service that is similar to operations in other bands, the Commission can and should adopt them quickly, as a first step in the process of more widespread reform across the larger mid-band frequency range. 

The Petition proposes specific and concrete rule changes that would enable the immediate introduction of P2MP fixed wireless broadband service into the 3700 – 4200 MHz band without disrupting incumbent operations.  As the Petition explains, implementing P2MP services can be done rapidly and simply, using existing Part 101 frequency coordination procedures.  The Petition also explains that the Commission can implement rules now for the immediate deployment of P2MP broadband that will not preclude later entry into the band by mobile services. 

In less densely populated areas, fixed wireless technology is an efficient and cost-effective way for consumers to receive broadband services in their homes and at their businesses and community anchor institutions.  In a growing number of rural areas, fixed wireless technology is being combined with optical fiber to form a hybrid fiber-wireless architecture.