T-Mobile US is urging the FCC to take a different approach to several big issues announced in a recent Fact Sheet the commission released. The company said that for 28 GHz in particular, the commission should continue to license satellite operations on a secondary basis only.
The Fact Sheet that Chairman Tom Wheeler circulated last month said the Spectrum Frontiers proposal would create a path for continued and expanded satellite operations in the 28, 37 and 39 GHz bands, and plans called for adopting several mechanisms to provide flexibility to satellite operators and predictability to terrestrial operators.
The "uncarrier" said it is has supported an approach that allows satellite operations to continue and expand in the band while ensuring that terrestrial operators are able to aggressively deploy service, particularly in the major urban areas. "It is critical that the commission not undermine the utility of the terrestrial licensed spectrum by granting satellite operators extensive rights, particularly in major markets, to deploy systems that will interfere with or add uncertainty to the terrestrial operations," T-Mobile said in a recent filing (PDF).
For 28 GHz in particular, T-Mobile said there are no grounds for changing the current approach, and increased protection for satellites can be acquired through auction or the second market. In addition, "there should be no spectrum access system or similar database-driven access to the band by satellite or other operations," it said.
T-Mobile also said it's important that the commission not impose aggregate power flux density (PFD) limits to protect reception by satellite space stations in the 28 GHz band. Ericsson (NASDAQ: ERIC) has pointed out in a separate filing with the commission that there would need to be 9.55 million end-user transmitters within the spot beam to impact satellite use. Terrestrial transmissions will be directional and would not generally be pointed at the sky in any case.
T-Mobile added that there have been no credible submissions contradicting the Ericsson study, and accordingly, the commission should address this issue in the upcoming Report and Order and not, as some suggest, consider the issue in an anticipated Further Notice of Proposed Rulemaking (FNPRM).
T-Mobile also opposed making the 37-37.6 GHz band available for licensing by rule. The operator said it appreciates the need to share with federal operations in the band, but asserted that accommodating federal systems need not result in a licensed-by-rule scheme. The most successful spectrum auction in the commission's history – for AWS-3 spectrum – involved frequencies in which federal users may in some cases continue to share with commercial providers, the company said.
Yet the FCC was able to auction the AWS-3 spectrum with exclusively licensed spectrum. "It should take the same approach here," T-Mobile said. "A license-by-rule approach, in contrast, will effectively make this an unlicensed band under a yet to be determined approach to sharing. This approach is unnecessarily complicated, will introduce uncertainty that will greatly reduce interest in the band, will significantly reduce the amount of spectrum for licensed 5G services, and will result in limited use of the spectrum."
The Fact Sheet the commission put out also suggested that it is contemplating making the 64-71 GHz band available for unlicensed use. T-Mobile said that 7000 megahertz of spectrum, combined with the 600 megahertz at 37.-37.6 GHz, will create 7600 megahertz of spectrum designated for unlicensed or essentially unlicensed use, as compared with the only 3250 megahertz of spectrum that the commission would make available for exclusive licensed services.
"The commission should re-evaluate the division of spectrum between licensed and unlicensed use," T-Mobile said. "Licensed operations are at the core of the 5G vision. The leadership that the commission has demonstrated in making spectrum for 5G available will be undermined by missing this opportunity to make a portion of the 64-71 GHz band available for licensed use. Making spectrum available for licensed services in the 64-71 GHz band will provide the certainty necessary to promote the investment in equipment development and device innovation that will benefit users of both licensed and unlicensed segments of the band."
- see this T-Mobile filing (PDF)
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