Disagreements Continue on Best Way of Making Inventory Spectrum Available

CTIA sees “substantial record support” for relying on STAs to make unused licenses available. STAs have “proven effective” and “could be implemented quickly, so Inventory Spectrum can be put to use, consistent with the Commission’s objective in this proceeding,” CTIA said. Advocates of sharing don’t address the proceeding's fundamental goal: “to speed access to Inventory Spectrum while the Commission’s auction authority is lapsed,” the group said.

Moreover, CTIA said it would take years to develop dynamic sharing systems, such as those used in the citizens radio broadband service in other bands. Equipment would be a problem, CTIA said. The record also shows “limited investment and deployment in complex shared spectrum-based offerings” like CBRS. NCTA discusses the benefits of sharing “then focuses its filing on urging the Commission to adopt sharing models for spectrum bands that are wholly outside this proceeding and, indeed, currently not adapted for commercial wireless use,” CTIA said.

The FCC shouldn’t “introduce other spectrum access licensing frameworks -- such as dynamic spectrum sharing or site-based licensing -- into bands that are already licensed for exclusive, flexible-use,” Verizon said. STAs preserve “the opportunity to auction that spectrum at a later date to ensure that it is ultimately assigned to the party that values it most highly,” the carrier said.

T-Mobile agreed that granting STAs was the best way to get spectrum in play. Inventory spectrum was already offered in an auction. “Once Congress restores the Commission’s spectrum auction authority, the Commission will begin the process of making Inventory Spectrum available again on a permanent, licensed basis through spectrum auctions,” T-Mobile said.

As in the initial comment round, other comments disagreed with carrier promotion of STAs as the best alternative.

“Commenters agree … that coexistence-based spectrum access frameworks enable competition and innovation in the U.S. and globally,” NCTA said. The group said traditional spectrum auctions prompt “inefficient and inequitable” access to spectrum. “This proceeding arises in part because geographic-area based, licensed-exclusive spectrum either went unsold at auction or was returned to the Commission,” the cablers said. Traditional auctions “may enhance incumbent carriers’ nationwide coverage, but they do not create opportunities for new entrants and innovators.”

The Competitive Carriers Association said rules for how inventory licenses can be used must provide certainty if spectrum is to be useful to smaller carriers. To offer “a meaningful and useful alternative” to auctioned spectrum, “CCA members need a high degree of certainty that the spectrum will be available and useful for a sufficient duration to warrant the significant investment potentially needed to deploy service on the spectrum,” the group said. Making bands like 600 MHz and AWS-3 available will mostly “benefit carriers who already have those bands in their networks and can easily incorporate it without significant equipment investment,” CCA said.

The National Wireless Communications Council (NWCC) supported, for the most part, an Enterprise Wireless Alliance proposal that assignments in the primary bands used for private wireless be coordinated on an exclusive basis by current FCC-certified frequency advisory committees. The FCC will face a backlog of bands for auction once authority is restored, NWCC said. “It is uncertain when, if ever, the FCC will have an opportunity to auction inventory spectrum in the bands needed by NWCC members,” the group said: “It has been more than a decade since it has done so, and the demand for broadband spectrum continues to escalate.”