WISPs Urge Pilot Tests of Spectrum Usage

The Wireless ISP Association wants a pilot program as a next step in response to the FCC’s August notice of inquiry on understanding nonfederal spectrum use. The pilot should “study occupancy in a small number of bands with different characteristics, such as an exclusively licensed band, a Part 101 point-to-point band and a band in which multiple use cases are present,” WISPA said: “These bands should be reviewed to determine whether and to what extent they are ‘occupied’ or ‘fully occupied,’ taking into account geography, frequency and time and the particular licensing structure.” Among other comments filed this week in docket 23-232 (see 2310040056), the Aerospace and Flight Test Radio Coordinating Council reminded the commission of the importance of aeronautical mobile telemetry (AMT). “Bottom line, interference-free access to adequate and ‘always ready’ flight test spectrum in the AMT bands is a fundamental element of all flight tests,” the council said: “There is no Plan B if spectrum is unavailable for a flight test when it is scheduled.” For alarm radios “and other quasi-safety operations (as well as public safety operations) in the Part 90 spectrum, crowding the channels with the maximum amount of user traffic should not be the Commission’s spectrum management goal,” said the Alarm Industry Communications Committee. Any measurement approach “should be tailored to the Commission’s intended use of the data” and “avoid over or undervaluing a particular service or technology,” said NCTA. “The Commission should measure how much total data is carried by all users of a particular service in a particular spectrum range -- and should do so in a way that recognizes differences between technologies rather that designing a measurement system with one technology or service in mind,” the group said. “There is no one-size-fits-all in calculating spectrum utilization,” the Enterprise Wireless Alliance said. EWA noted most of its members rely on frequency-specific spectrum licensed under Parts 90 and 101 of FCC rule. “These are narrowband, non-contiguous frequencies with very limited bandwidth,” the group said: “Unlike systems authorized for broad swathes of spectrum over large geographic areas, these private internal systems are held accountable for each frequency and site authorized. Their license data is captured in the Universal Licensing System, which, when functioning, offers as detailed a description of utilization of this spectrum as any alternative system could provide.”