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Putting Together the Pieces of the Spectrum Act Puzzle

When you sit down to solve a puzzle, some look for the center piece, while others like to start from the edges.  When it comes to solving the spectrum puzzle, the Federal Communications Commission, Congress and the National Telecommunications and Information Administration (NTIA) have rightly focused on some of the most important – and central – pieces by implementing “headline” spectrum provisions of the 2012 Middle Class Tax Relief and Job Creation Act (Spectrum Act):  broadcast television incentive auctions, the “H Block,” and a pairing of FCC spectrum at 2155-2180 MHz with federal government spectrum at 1755-1780 MHz.  CTIA is an ardent supporter of those efforts and is committed to helping the FCC and NTIA bring these essential pieces of the spectrum puzzle to market for commercial mobile broadband services.  But we also want to highlight two lesser known, but critically important, pieces of the puzzle:  the requirements in Section 6401(b)(2)(C) and (E) of the Spectrum Act that NTIA and the FCC each identify 15 MHz of spectrum for reallocation to commercial mobile broadband use.  So, today, CTIA President and CEO Steve Largent sent a letter and White Paper to the FCC asking that it begin efforts as soon as possible to identify its 15 MHz of contiguous spectrum for reallocation to commercial mobile broadband use.

So what do these less celebrated pieces of the Spectrum Act puzzle actually call for?  First, the Spectrum Act calls on NTIA to identify 15 MHz of spectrum between 1675-1710 for reallocation from federal to non-federal use.  Kudos to NTIA, just last month it released a report identifying the upper 15 MHz of this band to be made available for commercial mobile broadband.  So now it is the FCC’s turn.  Under the Spectrum Act, the FCC must identify, allocate, auction and assign “fifteen megahertz of contiguous spectrum” by February 2015.  CTIA’s letter, sent to the FCC today, calls on the FCC to start its work to identify the 15 MHz of contiguous spectrum called for by the Spectrum Act.

We’ve also tried to give the FCC some guidance from the industry on where we think it should look for its 15 MHz.  We think that this spectrum could be most effectively put to use if it is: 1) suitable for mobile services, 2) adjacent to existing bands, and 3) readily available for pairing with other spectrum.  We also think it makes sense to pair the two bands of spectrum identified in the Act:  that is, to combine NTIA’s 15 MHz with the FCC’s 15 MHz.  Each of the other major pieces in the Spectrum Act has a natural pairing:  H block is paired, the 1755-1780 MHz band has been identified for pairing with 2155-2180 MHz, and the FCC and industry are actively working on a flexible and efficient band plan for the 600 MHz spectrum.  Similarly, pairing the FCC and NTIA’s 15 MHz blocks would maximize the utility of the spectrum to the wireless industry, leading to greater spectrum utilization and consumer benefits.  It will also maximize the revenues available to fund Congressional priorities identified in the Spectrum Act.

Looking at all those factors, we think that the natural place to look for the FCC’s 15 MHz is at the upper edge of the Broadcast Auxiliary Service (BAS) spectrum located at 2095-2110 MHz.  The upper 15 MHz of the 85 MHz BAS band fits the criteria that you typically look for in commercial mobile spectrum:  it is contiguous and adjacent to current allocations, it has the same duplex gap as existing Advanced Wireless Services (AWS) and it allows pairing in a readily achievable fashion.  As we said in our letter, we are not aware of any other spectrum bands as well-positioned as this band to meet all the key principles for mobile broadband spectrum that could be paired with the specific 15 MHz identified by NTIA and that could be put to timely use and generate significant revenues through a competitive bidding process.

Now, reallocating any band has challenges.  Here there are existing BAS users. There are also incumbent Federal operations, including Federal space operation, earth exploration-satellite service and space research services.  NTIA has also pointed to the broader BAS band as a potential home for services relocated from the 1755-1850 MHz band.  Addressing each of these considerations is important, but CTIA believes that the FCC should begin the process to examine and address those issues.  The BAS band is a comparatively large block of spectrum – 85 MHz in all.  To meet the requirements of the Spectrum Act, we believe that the time is ripe for the FCC to carefully investigate how to make the most efficient use of this band and whether the upper 15 MHz can be redeployed for much needed mobile broadband services.  So, today we call on the FCC to swiftly begin the process, required by Congress, to identify 15 MHz of much-needed spectrum to help complete the overall spectrum puzzle.

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