Verizon is urging the FCC to move quickly to make the 28 GHz and 37-40 GHz bands available for licensed use and to promote 5G by slating the entire 28 GHz band for flexible use. It also took the opportunity to once again warn against adopting “use it or share it” rules for the 24, 32 and 42 GHz bands.
Verizon, along with other stakeholders, submitted comments on Friday, the deadline the FCC set for comments after it adopted the report and order on the use of spectrum bands above 24 GHz back in July. The commission at that time also set a deadline for reply comments of Oct. 31.
The commission should move forward with all the bands identified for repurposing in its Further Notice and in particular, it should open up the 24, 32 and 42 GHz bands to mobile use under traditional licensing models known to promote investment and innovation, Verizon said in its filing. These bands are attractive for prompt deployment of 5G services because their proximity to the 28 GHz and 37-40 GHz bands presents opportunities for synergies and economies of scale, the operator said.
“To the extent the Commission decides to experiment with a novel ‘use it or share it’ model in mmW bands, it should not permit such sharing in the 28 GHz and 37-40 GHz licensed bands or the nearby 24 GHz, 32 GHz, and 42 GHz bands,” Verizon argued. “‘Use it or share it’ experiments will take time to put in place and will subject licensees to substantial uncertainty.”
If, however, the commission does move forward with “use it or share it” or other sharing frameworks in other bands, it should stay faithful to the principles that are known to support innovation and investment.
“One important principle is that licensees, even in a sharing framework, need clarity about their ability to exclude other uses of particular frequencies at points in time and/or in particular places,” Verizon said. “Any sharing arrangement thus needs clear procedures and mechanisms for promptly clearing opportunistic users from licensed spectrum once the licensee invokes its right to begin using the spectrum.”
Mobile Future, an organization whose members include Verizon Communications and AT&T, also filed comments last week urging the commission to move forward to make additional spectrum above 24 GHz available for flexible use. It said the FCC should not extend the 3.5 GHz framework to the 71-76 GHz band and the 81-86 GHz band, arguing that the three-tiered sharing framework in the 3.5 GHz band has not yet been tested and “extending the use of a SAS to the mmW bands would be premature."
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