FCC Urged to Use Interference Limits in 3.5 GHz Rules

The 3.5 GHz band provides an opportunity for the FCC to make use of an “interference limits” policy, with harm claim thresholds, as proposed in a February paper by the FCC’s Technological Advisory Council, said TAC member Pierre de Vries in comments filed at the FCC. De Vries said the FCC can demonstrate that interference limits as proposed by TAC (http://bit.ly/14Zs7nc) work in practice.

"I do think this is a place where one can apply those ideas,” de Vries said in an interview Monday. “Even though the terms are new, the ideas have been used before. There is precedent.” The way the paper approaches interference is new, he said. “It essentially says that the criterion for claiming harm is that interference exceeds this number and actually putting a number to what harmful interference means as an initial matter, that hasn’t been done before.”

The Wireless ISP Association said the FCC shouldn’t dedicate the band to small cell technologies alone. “There is strong support in the record for including higher powered services in the 3.5 GHz Band along with small cells,” WISPA said (http://bit.ly/17mP9ny). “Higher power uses would not be at the expense of small cells, but rather would co-exist subject to spectrum separation and sharing principles.” The systems could co-exist through use of a three-tiered spectrum access system (SAS) that protects incumbents with a combination of geographic zones, spectral separation and dynamic frequency selection technologies that create an environment for efficient spectrum utilization,” the group said.

The Edison Electric Institute said the FCC should steer clear of any proposals that the FCC adopt something other than the three-tiered proposal in the NPRM. “Unfortunately, some commenting parties, arguing that the spectrum was better used by commercial services, have sought modifications of the FCC’s proposal so that commercial carriers, and not governments, hospitals and utilities, would either have access to or a preference in the spectrum,” EEI said (http://bit.ly/XnYlnx). “For example, it has been urged that the FCC ... scrap the three tiered approach and instead adopt a two tiered approach under which commercial carriers would have assigned spectrum.” Electric utilities need better access to spectrum like the 3.5 GHz band “because they rely on mission critical communications to support the safe, reliable, and efficient delivery of electric service,” EEI said.

If the FCC adopts a multi-tiered model for the 3.5 GHz spectrum “it should not disregard the spectrum lessons of the past decades,” Verizon and Verizon Wireless said (http://bit.ly/16zqc6Q). “One is that wireless operators require quality-of-service assurances if they are to make substantial investments in reliance on spectrum. Another is that assigning licenses to entities based on open eligibility rules, not subjective eligibility criteria, ensures that the spectrum is put to its highest and best use and avoids unnecessary economic distortions and inefficiencies."

The NPRM “is a critical first step in a long-term effort to reorient the nation’s spectrum policy toward use rather than exclusively reserved non-use of capacity on the public’s infinitely-renewable spectrum resource,” the Public Interest Spectrum Coalition said (http://bit.ly/16zqc6Q). “PISC strongly supports the Commission’s effort to convert this very substantial but grossly underutilized swath of spectrum into an intensively-used small cell band in a manner that not only protects military and other incumbent systems from interference, but also builds a foundation for more extensive private sector sharing of underutilized bands with an automated governing mechanism.” PISC represents the Open Technology Institute at the New America Foundation, Consumer Federation of America, Public Knowledge and Free Press.