12/2 FCC Comments to Expand Sharing in the E-Band

New America's Open Technology Institute wrote and filed comments with Public Knowledge with the Federal Communications Commission (Commission) urging for an extension of the sharing framework for the 70/80/90 GHz band (the "E-Band"). Expanding existing sharing in the E-Band to allow as many users as possible on an equitable and open basis would help enable new use cases such as innovative connectivity solutions on moving platforms. An introduction and summary are available below:

New America’s Open Technology Institute and Public Knowledge (“OTI and PK”) respectfully file these comments in response to the above-captioned proceeding. The Commission should extend its sharing framework for the 70/80/90 GHz band to include as many new use cases and users as feasible, ensuring open and equal access to this spectrum through the existing database coordination mechanism. The open registration and database-managed coordination of sharing by a wide variety of use cases while protecting incumbents from harmful interference is feasible and enjoys broad support from a diverse set of interests. Expanding access to the E-Band for as many users as practicable is common sense spectrum policy that would improve innovative connectivity solutions that achieve key public interest goals.

Expanding access to the 70/80/90 GHz band (“E-Band”) for HAPs, point-to-point links to platforms in motion (as Aeronet has proposed), and fixed-satellite service gateways promotes the important public interest goal of enabling innovative wireless internet services that improve connectivity for consumers in the air, on land, and at sea. Given the well-established success of database coordination in this band—as well as the proven success of dynamic database management in the Citizens Broadband Radio Service band—the benefits of accommodating these new service offerings dwarf the costs. Database-coordinated sharing is feasible and supported by a wide range of stakeholders in the record.

OTI and PK urge the Commission to ensure the widest array of stakeholders are able to utilize 70/80/90 GHz spectrum to expand the quality and affordability of consumer broadband connectivity, particularly on airplanes, ships, and at other locations where service today is notably lacking, substandard or too expensive. The accommodation of High Altitude Platform Stations (HAPS), fixed backhaul on moving platforms, and fixed-satellite service gateways in a common light-licensing framework will offer innovators the infrastructure needed to seek solutions to connectivity challenges on modes of transportation as well as those posed by remoteness, extreme weather, and topographical obstacles. The ways in which consumers connect to internet has advanced steadily through forward-thinking and technology-neutral regulation, and the Commission should continue this legacy in the E-Band by expanding database-coordinated access to all services and users on an equal basis.