Proponents of MSS Use of 2 GHz Band Tout Wireless Service Growth, Capacity Needs
A handful of early comments mainly support the provision of terrestrial services in spectrum assigned to mobile satellite service in the 2 GHz band. If what the agency proposed in a notice of proposed rulemaking becomes a rule, Dish Network will be allowed to build a wireless network. Comments on the NPRM were due at the end of the day Thursday, and some were available by our deadline in docket 12-70.
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Modifying Dish’s existing authority is “the only reasonable means of promoting full terrestrial use of the S-band” and license modification is the most realistic, timely solution to rapid deployment and best serves the public interest, the company said. Modifying 2 GHz authorizations will promote the rapid deployment of the spectrum, and “it will do so without raising harmful interference problems or encountering legal pitfalls that would accompany any alternative method of facilitating terrestrial use of the S-band,” Dish said. The commission’s proposal is consistent with its 2003 determination “that MSS and ATC (ancillary terrestrial component) operations cannot coexist in the same band with separately licensed terrestrial operations,” it said: The FCC recognized that “same-band, separate operator sharing is impractical and ill-advised.” The commission also observed that “same-band satellite and terrestrial operations have created technical problems in other bands,” Dish said.
The proposed performance requirements should be adopted with targeted modifications, Dish said. The FCC’s proposal for a three-year interim buildout and overall seven-year buildout should be altered, it said. Dish supports a final, seven-year buildout deadline and an interim timeframe of four years. The FCC should revise the final milestone “to require coverage to 200 million people, consistent with the recommended national scope of the license,” it said.
The CEA wants a rapid completion of the proceeding. “Consumers’ insatiable demand for mobile services only continues,” CEA said: Prompt action will complement the goals in the National Broadband Plan and other initiatives of other government entities “to address the pressing demand for additional broadband spectrum.” CompTel also pointed to the explosive growth in mobile Internet traffic as a reason to find opportunities to create more network capacity and suitable spectrum. Allowing more flexible use of spectrum in the 2 GHz band “promotes a fifth nationwide provider of wireless services … that is independent of an incumbent local exchange carrier,” CompTel said.
U.S. Cellular urged the FCC to focus on a comprehensive band plan “that considers all the spectrum available for mobile broadband services” and the interactions between the various bands. The company supports the FCC’s efforts to increase terrestrial deployment, it said. However, the analysis of possible service and technical rules for the proposed deployment should not “delay, diminish or impair the other initiatives to allocate, auction and license additional spectrum that is urgently needed to support the expansion of commercial mobile broadband service,” U.S. Cellular said.
The Mobile Satellite Users Association supported flexible sharing of spectrum between satellite and terrestrial services: When terrestrial networks are rendered inoperable by a disaster situation, “additional spectrum can then potentially be made available to support satellite services for the duration of the emergency.” It would be “extremely disappointing and wasteful if … the DBSD and TerreStar satellites are unable to be utilized for the intended purpose of providing new, advanced MSS services,” the association said. MSUA cautioned against automatic termination of the 2 GHz MSS authorization if buildout criteria aren’t met: The association would be concerned if MSS users who had invested in equipment and were relying on the band for critical services “were … at some point left without these services.”