Showing they can still be friends despite Google's (NASDAQ:GOOG) recent usurping of AT&T (NYSE:T) as Starbucks' Wi-Fi provider, Google and AT&T this week submitted a joint letter to the FCC that lays out their ideas on how the commission should go about opening up 3.5 GHz spectrum for small cells.
Highlighting the fact that Internet and telecom companies can be partners as much competitors, the two companies outlined a handful of points they want the FCC to address as it sets rules for commercial operations in the 3550-3650 MHz band. Their joint letter was signed by Joan Marsh, AT&T's vice president of federal regulatory, and Austin Schlick, Google's director of communications law.
As outlined in a December 2012 Notice of Proposed Rulemaking (NPRM), the FCC's proposed 3.5 GHz Citizens Broadband Service will be covered by a three-tier authorization mechanism and managed by a geolocation-enabled dynamic spectrum access database modeled upon existing TV white spaces databases. The three proposed tiers of operation are: incumbent access (federal and grandfathered licensed FSS 3.5 GHz band users), priority access (hospitals, utilities and public-safety entities) and general authorized access (the general public).
Google and AT&T said they support the three-tiered, spectrum-sharing framework. However, they do not want to be relegated to the third tier, arguing that the commission "should establish broad eligibility for the secondary exclusive tier," opening it up to "any applicant that commits to a substantial service requirement."
The companies contend that current plans to limit access to the "priority access" tier would undermine the FCC's goal of bringing mass-market, commercial-scale technologies to the 3.5 GHz band, and would also restrict users' and service providers' flexibility to adapt to changing conditions and market opportunities.
Google and AT&T also pushed for the use of a spectrum access database to manage the three tiers of users. Though it has not signaled any intention to run a 3.5 GHz database, Google's TV white space (TVWS) database system in June won approval for operation from the FCC's Office of Engineering and Technology.
On another point, the companies argued that the FCC should calculate 3.5 GHz exclusion zones based on small-cell deployment scenarios rather than macrocell deployments, describing zones based on the latter as "overprotective in the small-cell context."
They also said geographic exclusion zones should protect incumbent users rather than new entrants. "If commercial users have an incentive to develop and deploy improved technologies that better withstand interference, they will do so," said the companies.
Google and AT&T also suggested that if auctions are planned for the band to resolve mutually exclusive demands for spectrum licenses, the commission should create "lightweight, fast, and flexible auction mechanisms" that are less costly and less complex than the current system.
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