**Clarification: The NTIA had pointed to this site for comments on its new National Spectrum Strategy. But it subsequently also posted comments that were made prior to the publication of its NSS. The comments made by AT&T for this story were made in April 2023.
After the National Telecommunications and Information Administration (NTIA) published its proposed National Spectrum Strategy (NSS) on November 13, multiple groups immediately sent their “applause” of the strategy. But on the sidelines, there were mumblings and rumblings, indicating that many were not that happy with the strategy.
The NTIA is now taking comments on its proposed NSS until January 2, 2024.
AT&T has already filed its comments, and it’s clear that the carrier wants NTIA to focus on the needs of major wireless carriers and also to focus more on mid-band spectrum.
The carrier stressed that mobile wireless carriers need sufficient allocations of “network grade spectrum,” which it defines with these characteristics:
- Exclusive licensing, to provide certainty of interference-free access necessary to secure the infrastructure investment;
- Flexible use rights, to allow it to be refarmed for more advanced technologies over time;
- Full-power and good propagation characteristics (8.5 GHz and below), to allow wide coverage, macro network use, not just small cells;
- Large, contiguous channel sizes, to allow for higher data rates and TDD operations to increase efficiencies in 5G;
- Internationally harmonized to the greatest extent possible.
AT&T wants more mid-band focus
AT&T’s comments also stressed the importance of mid-band spectrum. As part of its spectrum strategy, NTIA identified five bands for near-term study. But AT&T seemed disappointed that two of these were for high-band spectrum.
It said, NTIA should focus on the “prime mid-band range (3-8.5 GHz)” and that spectrum in the 3-8.5 GHz range is the spectrum most crucial for 5G, and therefore what is needed first, allowing the U.S. to be at the forefront of the wireless ecosystem.
The 3.1-3.45 GHz was one of the mid-bands identified for study. The DoD and Department of Commerce will co-lead more studies on the use of the 3.1-3.45 GHz band. And they will also explore dynamic spectrum sharing in the band.
In its comments AT&T said it would like the government to reallocate and auction at least 150 MHz in the 3.1-3.45 GHz range within four to five years. But it said even if all of the 3.1-3.45 GHz were allocated to mobile for exclusive use, this would not close the mid-band spectrum gap with China, especially if the spectrum ends up having to be shared with DoD incumbents.
While the NSS did not say it would study the 6 GHz band, AT&T stated in its comments, “Policy makers should take another look at the 6 GHz band as a candidate. Notwithstanding the current allocation of 6 GHz for unlicensed in the U.S., there are no DoD systems in the 6 GHz band. Auctioning even half of the 1200 MHz for exclusive licensed, full power use for 5G networks would be easier to do in 6 GHz than clearing even half of that amount in the 3 GHz range.”
AT&T would also like the government to reallocate and auction at least 200 MHz in the 4.4-4.94; GHz range in the next five to seven years — another band of spectrum that the NSS did not identify for near-term study.
Ultimately, AT&T would like NTIA to focus its National Spectrum Strategy on more mid-band spectrum. But it’s not clear whether NTIA would completely change its strategy to focus on different spectrum bands than the five it’s already identified.