Spectrum For The Future Submits Public Comment On White House’s National Spectrum Strategy

Washington, D.C. – Spectrum for the Future (SFTF), a diverse coalition of innovators, anchor institutions, and technology companies, today submitted public comment to the National Telecommunications and Information Administration (NTIA) on its implementation of the White House’s National Spectrum Strategy.

The National Spectrum Strategy (NSS), announced in November, acknowledges that a shared and locally licensed spectrum model is feasible in the 3.1-3.45 GHz band if advanced interference-mitigation and coordination frameworks are adopted. SFTF’s comment emphasizes the importance of focusing additional study on improving the conditions for sharing rather than exploring unrealistic options for commercialization, and it urges NTIA to conclude study of the lower 3 GHz band well before the NSS’s prescribed two-year timeline.

“Dynamic, locally licensed sharing in the 3.1-3.45 GHz band is the most effective path forward to open this vital spectrum to diverse groups of commercial users, which will help position the U.S. as the global leader in wireless innovation and 5G deployment. Using the full two-year timeline to recognize this reality – or diverting resources toward studying unrealistic commercialization options like segmentation, compression or relocation – would only undermine U.S. leadership in advanced and emerging technologies,” said Tamara Smith, spokesperson for Spectrum for the Future.

In the global race to 5G, a shared, locally licensed option with power levels similar to the Citizens Broadband Radio Service (CBRS) would provide a stark contrast to China’s approach, as well as an important counterweight to Huawei dominating the market for equipment in the 3.1-3.45 GHz band.  

“Unlike a high-power, exclusive licensing approach, which would only benefit a few wireless companies, sharing in the lower 3 GHz band will not force DoD to vacate the band, protecting our national security interests and saving hundreds of billions of dollars. As nations like China seek to export their top-down, exclusive licensing approach to rest of the world, the U.S. should demonstrate what real innovation looks like by putting proven spectrum sharing technologies like CBRS into action in additional bands,” Smith concluded.   

Highlights from the coalition’s letter include:

• A shared spectrum model for low-power, local licensing in the 3.1-3.45 GHz band can bolster U.S. leadership in 5G deployment, among other benefits to innovation and national security.
• The Department of Defense (DoD) completed its multi-year Partnering to Advance Trusted and Holistic Spectrum Solutions (PATHSS) process, co-chaired by NTIA. That process produced the Emerging Mid-band Radar Spectrum Study (EMBRSS) study, which determined that sharing is feasible in the 3.1-3.45 GHz band assuming advanced interference-mitigation and coordination frameworks are adopted.
• Exclusive, high-power licensing would force the DoD to vacate the band, costing taxpayers hundreds of billions of dollars and taking decades to complete.
• CBRS offers a proven model for success in driving more 5G options for consumers, more competition between carriers, and more innovation in wireless technology.
• The NTIA should prioritize further study on improving the conditions for sharing in the 3.1-3.45 GHz band, utilize completed studies such as EMBRSS to conclude the process well before the prescribed two-year timeline, and to the extent possible, engage with the public to ensure non-federal uses can be rapidly deployed after re-allocation.
• Given commercial and federal spectrum needs, spectrum sharing should not be limited to only the 3.1-3.45 GHz band. Although not a substitute for lower 3 GHz spectrum, a licensed sharing regime is ripe for quick deployment in the 37 GHz band.

Click here to read the full letter.

About Us: Spectrum for the Future represents a diverse coalition of innovators, anchor institutions, and technology companies who agree that an inclusive approach to wireless spectrum policy is essential to America’s future technology leadership, industrial might, and global competitiveness.