Google (NASDAQ: GOOG) wants the FCC to allow expanded use of millimeter wave spectrum on a lightly licensed or unlicensed basis and use sharing technologies to manage different types of users.
In comments filed with the FCC last week, Google notes that detailed proposals in the FCC's Notice of Proposed Rulemaking (NPRM) for the 28, 37 and 39 GHz bands – three of the four bands addressed in the NPRM – "appear to be designed specifically to provide supplemental capacity for current commercial mobile networks."
Providing additional capacity for today's mobile broadband providers is an important goal, but "continued implementation of a balanced spectrum policy, however, requires that the Commission ensure sufficient access to spectrum for innovative and emerging uses to thrive. Light licensing and unlicensed access are flexible frameworks that accommodate both traditional and new users."
Even if the commission were to determine that exclusive licenses, rather than light licensing or unlicensed approaches, provide superior benefits in some of the bands identified in the NPRM, it should not simply default to the county-wide exclusive licenses that are being proposed, according to Google.
Instead, the commission should "extend to these bands its Part 96 framework for intensive, three-tiered sharing." Last year, the FCC moved to adopt a three-tiered approach spanning 3550 MHz to 3700 MHz, for a service dubbed the "Citizens Broadband Radio Service." The FCC said use of advanced spectrum sharing technology will allow wireless broadband systems to share spectrum with military radars and other incumbent systems while protecting federal missions.
The three tiers include incumbents, Priority Access and GAA and require the use of a spectrum access system (SAS) to manage coexistence between the tiers. The approach requires Priority Access and GAA services to avoid interference to incumbent military and non-governmental users, while Priority Access users receive protection from interference from third-tier operations licensed by rule. If necessary, a similar approach can be successful in the millimeter wave bands, Google said.
It just so happens, Google has demonstrated the ability to use software running on Google infrastructure to dynamically manage spectrum among different tiers of users. Federated Wireless is another developer of shared spectrum management systems.
Meanwhile, Google also points out that the International Telecommunications Union (ITU) has an identification for high altitude platforms (HAPS) in the 27.9-28.2 GHz band, and its members agreed at the World Radio Conference to study the use of the 21.4-22; 24.25-27.5; and 38-39 GHz bands for HAPS. Google says the FCC should build on the ITU's efforts and consider whether any of the bands identified in the NPRM would be suitable for "innovative aerial applications."
The search giant also would like to see the commission authorize unlicensed use of the frequencies between 64 and 71 GHz, and allow fixed and mobile field disturbance sensors to operate alongside other communications services between 57 and 71 GHz. The sensors used in Google's Project Soli, for example, allow users to interact with devices a short distance away with a wave of their hand without the need to touch the device itself.
- see this Google filing
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