FiberTower Reply Comments in the Above 24Ghz Spectrum Bands Notice of Proposed Rulemaking

REPLY COMMENTS OF FIBERTOWER SPECTRUM HOLDINGS, LLC

 

FiberTower Spectrum Holdings, LLC (FiberTower) hereby replies to the comments filed in response to the Notice of Proposed Rulemaking of the Federal Communications Commission (Commission) in the above-captioned proceeding.[1]  FiberTower urges the Commission to:

1)      Harmonize the wide-area, exclusively licensed millimeter wave (mmW) bands at 24 GHz, 28 GHz, and 39 GHz for flexible use[2];

2)      Make clear that flexible use licenses will allow the licensees to use TDD, FDD, or other technologies as equipment development and market demands dictate;

3)      Expand the established wide-area, exclusively licensed bands at 24 GHz, 28 GHz and 39 GHz into larger channel blocks.

4)      Avoid any delay from the creation of larger channel blocks to the ongoing flexible use of existing wide-area licenses in the 24 and 39 GHz bands.  Those bands already support gigabit and multi-gigabit fixed services under the current channel block scheme and can be used today for more robust portable and mobile applications;

5)      Allow incumbent and new licensees to work with each other to migrate, partition or disaggregate spectrum so that the market can dictate the most efficient  license sizes;

6)      Maintain the established, effective protections for terrestrial licenses from satellite interference to ensure that flexible use licensees are able to exploit the full reach of their licenses;

7)      Promote mmW backhaul as a policy priority so that 5G and broadband access services are able todensify at a rate that responds to market developments;

8)      Mandate long-established core network security protocols that have been neither widely nor uniformly implemented; and

9)      Finalize license area sizes, confirming that counties will be either the license size or the building blocks upon which larger license areas are based. 

Ample support exists in the record for all the above positions and the Commissions should adopt them quickly to provide the United States with a platform for establishing global leadership in the fast developing, inextricably intertwined, and economically critical mmW and 5G industries.

To read the entire comment filed February 26th 2016 Click HERE

 

[1] 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.

[2] The Upper Microwave Flexible Use Service (UMFUS or flexible use) has been identified as a license authorization that allows the terrestrial licensee to operate fixed, portable and/or mobile services within the service area.