In November, the National Telecommunications and Information Administration (NTIA) published its draft national Spectrum Strategy (NSS) and asked for comments to be filed by January 2. Seventy three organizations submitted written comments by the deadline.
All three major national wireless carriers filed comments, which were remarkably similar to each other in their talking points. Perhaps their trade organization CTIA had a hand in the harmonization.
AT&T, Verizon and T-Mobile stressed their desire to put a rush on more mid-band spectrum. And they indicated their preference for exclusive, licensed high-power spectrum, while they also expressed a certain level of disdain for dynamic spectrum sharing.
AT&T
AT&T filed comments that noted the NSS identifies 2,786 MHz across five disparate bands for “in-depth, near-term study.” But it complained that studies are not the same as a spectrum pipeline. AT&T stated, “The Implementation Plan should therefore take the logical next step and establish a measure of effectiveness for the Plan of identifying 1,500 MHz of mid-band spectrum to be made available to auction for full-power commercial licensed use.”
AT&T also wants the FCC to prioritize the studies for the lower 3.1-3.45 GHz and 7.125-8.4 GHz bands in the next 18-24 months. It said this mid-band spectrum is the most important concern for wireless operators right now. “NTIA’s efforts in prioritizing its finite resources over the next 18-24 months of the Implementation Plan should be focused on these two mid-band studies. Crucial to the success of both studies in achieving the objectives of the NSS is that they must be studies of ‘how’ and not ‘whether’ to make the bands available for full-power, commercial licensed use.”
Verizon
Verizon said the NSS took an important step in identifying key bands for study, but it didn’t specify a pipeline for commercial licensed spectrum — in particular for key mid-band spectrum.
Verizon also called out the 3.1-3.45 GHz and 7.125-8.4 GHz bands. It said the NTIA should take the next, critical step and set benchmarks for the amount of spectrum to be identified in each band for licensed, full-power use.
Like AT&T, Verizon made clear that it wants more exclusive licensed spectrum, and it wants the NTIA to clear federal spectrum for commercial use.
In terms of dynamic spectrum sharing, Verizon said, “Where clearing is not possible, the Implementation Plan should encourage ‘proven’ sharing methodologies that have successfully enabled wireless deployments: static models across geographies, frequencies, and time.”
Verizon said dynamic spectrum sharing was “unproven,” or more precisely, not proven to serve wide-area deployments.
T-Mobile
T-Mobile wants the NTIA to ensure that at least 1,500 MHz of mid-band spectrum identified for evaluation is ultimately designated for licensed, high-power commercial use.
“NTIA should particularly consider whether the 3.3-3.4 GHz band can be made available for non-Federal use on an exclusive basis,” said T-Mobile. “The ITU World Radiocommunication Conference 2023 identified this band for International Mobile Telecommunications in the Americas region in addition to 57 countries across Africa and the Asia Pacific region, and harmonizing the 3.3-3.4 GHz band with the 3.6-3.8 GHz band would create 500 megahertz of contiguous spectrum for mobile broadband use, while also protecting Federal incumbent users from interference.”
And similar to AT&T and Verizon, T-Mobile said, “The Implementation Plan should not focus solely on dynamic spectrum sharing techniques that may be inappropriate to support nationwide commercial wireless networks. Instead, NTIA should first focus on making spectrum available for exclusive, high-power flexible use and only consider sharing if that is not feasible.”
CTIA
The trade organization CTIA kicked off its comments by saying, “To meet growing consumer and enterprise demand for 5G, close America’s widening 5G spectrum deficit, and counter China’s global ambitions, America’s wireless providers need 1,500 megahertz of additional licensed, full-power mid-band spectrum.”
It said the amount of mid-band spectrum designated for unlicensed and shared use eclipses licensed spectrum by four to one. In recent years, U.S. policy has committed 1,350 MHz of prime mid-band spectrum to unlicensed and dynamically shared use via CBRS in the 3.5 GHz band and all of the 6 GHz band. "The unlicensed disparity continues in the millimeter wave bands, where three times more spectrum has been dedicated to unlicensed, as compared to licensed use," said CTIA. “As a result, the United States leads the world in unlicensed and shared spectrum availability, particularly in the critical mid-band range."
NTIA
The NTIA is expected to publish its Implementation Plan for the National Spectrum Strategy sometime in March.