COMMENTS OF FIBERTOWER SPECTRUM HOLDINGS, LLC
FiberTower Spectrum Holdings, LLC (FiberTower) hereby submits comments in response to the Notice of Proposed Rulemaking of the Federal Communications Commission (Commission) in the above-captioned proceeding. FiberTower firmly supports the Commission’s “aim to facilitate access to spectrum, develop a flexible spectrum policy, and encourage wireless innovation.” Flexible use in the millimeter wave (mmWave) bands will drive innovation and is paramount to U.S. competiveness as momentum grows toward the launch of 5G services, particularly on the high-frequency bands at issue in this proceeding. Providing incumbent mmWave licensees with the ability to flexibly develop backhaul and broadband wireless access solutions will enhance global competitiveness and provide U.S. consumers with a key platform for ultimately receiving 5G services.
It is thus imperative that the Commission use this proceeding to accord Upper Microwave Flexible Use Service (UMFUS) licensees the flexibility to respond to developments in technology, industry standards, and business cases for 5G in order that the U.S. wireless industry maintain its leadership role in the global market. To accomplish this goal, the Commission should: (1) Adopt its proposal to launch the UMFUS and allow for innovative, flexible use in the mmWave bands; (2) include the 24 GHz band in the UMFUS, as it is empirically proven as more than capable of supporting vital 5G services and would leverage the global development work already undertaken and available in that band, which can be applied to 5G; (3) adopt UMFUS service rules that appropriately balance the protection needs of incumbent licensees with the flexibility needed to continue development and innovation of mmWave technologies and services; and (4) take steps necessary to ensure the security, resiliency, and marketability of services in the UMFUS.
To read the entire comment filed January 27th 2016, click HERE.
 Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, et al., GN Docket No. 14-177, et al., Notice of Proposed Rulemaking, 81 Fed. Reg. 1802 (2015) (NPRM). All citations contained herein are to the January 13, 2016 Federal Register publication of the NPRM.
 Id. at para. 3.