Spectrum Use NOI Sees Calls to Leave No Band Unexamined
When trying to gauge how fully utilized nonfederal spectrum is, no commercial-use band should be off limits, multiple trade groups said Friday in FCC docket 23-232 reply comments. Numerous comments argued that the fact that a band is licensed for exclusive use doesn't mean it's automatically being used to maximum efficiency. Commissioners unanimously approved the spectrum usage notice of inquiry at their August meeting (see 2308030075).
Arguments against evaluating certain bands may reflect fears the FCC will determine that a party's spectrum band isn't fully occupied and could become subject to spectrum sharing or an allocation change, the Wireless ISP Association said. A less-than-comprehensive evaluation of the use of nonfederal spectrum bands "will be of limited use," it said. WISPA said competition and the costs of deployment in some areas can be reasons why a licensee might not fully use licensed spectrum. It also disagreed with the idea that the price paid at auction should carry heavy weight in analyzing spectrum use.
Exclusive licenses result in high barriers to entry and opportunities for companies to prevent competition, "both of which result in less efficiency," NCTA said. It also pushed back against the idea that unlicensed and licensed-shared bands lack incentives for efficient use and criticized a CTIA-commissioned study that indicated the citizens broadband radio service band is underused. The record shows ample support for not treating received power or channel occupancy as a proxy for a band's overall public utility, it said.
Nonfederal licensees wanting access to additional spectrum bands should have to offer evidence of the extent to which they are currently maximizing spectrum usage in their existing assignments, Aviation Spectrum Resources said. Instead of the fact that a band has been the subject of an auction, look instead at such metrics as frequency reuse and tower location optimization to gauge the efficiency of the band's use, ASR said. Aeronautical bands need to have continuous availability and thus should be considered fully utilized, it said.
That the FCC has rules and policies to ensure more deployment of and continued usage of auctioned and non-auctioned wireless services shows auction winners are able and incentivized to underutilize auctioned spectrum, the Satellite Industry Association said. There's no reason to presume that particular portions of nonlicensed spectrum are being any less used than auctioned spectrum, SIA said. It cautioned against using crowdsourced and sensing data in its spectrum usage data collection, as "data hygiene concerns can plague" those methods.
Be sure to look at established government programs and nonprofit research organizations already gathering spectrum usage data when trying to establish ongoing real-time spectrum usage data, said the Association of Federal Communications Consulting Engineers. The group also urged the FCC to work with NTIA, National Science Foundation and National Institute of Standards and Technology on spectrum usage monitoring.