Last November, the White House released the National Spectrum Strategy and a Presidential Memorandum tasking NTIA with preparing a Strategy implementation plan. As a part of that process, NTIA welcomed public input on the Strategy through an opportunity to submit written comments. WifiForward was one of many groups to file comments, which you can read here. 

A broad range of public interest and industry players agree: Unlicensed spectrum is the key to future innovation, and NTIA must prioritize the lower 7 GHz band for unlicensed use. Here’s what they’re saying to NTIA ahead of the implementation plan rollout…

Broadcom

“Unlicensed use of the Lower 7 GHz band would complete a currently stranded 320-megahertz channel at the top of the 6 GHz band that Americans could use both in today’s Wi-Fi 6E and Wi-Fi 7 equipment (via software upgrades) and in next-generation Wi-Fi 8 equipment. While other parts of the 7.125-8.4 GHz range require additional work, the Lower 7 GHz band is poised for much quicker progress….

Access to the 6 GHz band has relieved pressure on previous Wi-Fi bands in the United States, but it is not sufficient to accommodate exploding consumer needs. Increasingly demanding applications and network designs require access to frequencies that facilitate wider channels. For Wi-Fi 7 and Wi-Fi 8 in particular, 320-megahertz channels will offer not just increased capacity, but also the improved energy efficiency, reliability, latency, and location capability required to meet consumer needs. But the high-reliability and extremely low-latency needs of next-generation applications will require network densification, particularly in environments with many users, such as multi-dwelling buildings, schools, universities, and healthcare institutions.”

Charter

“Unlicensed Wi-Fi adds about a trillion dollars to the U.S. economy annually, with projections for its economic contributions to reach $1.58 trillion by 2025. Wi-Fi’s economic success is driven by American consumers’ heavy demand for and reliance on it—supporting more than 85% of mobile traffic and a growing majority of all internet traffic today—and its low barriers to entry, which allow for essentially unlimited innovation and technological development. As total wireless data usage is projected to increase by five times from 2018-2026, Wi-Fi is expected to deliver 90% of that growth, mostly due to recent advances in Wi-Fi performance, reliability, and security that make it a viable and more cost-effective substitute for cellular. Wi-Fi is the key means by which consumers experience wireless technology.”

Comcast

“The Implementation Plan should direct the FCC to immediately open the Lower 7 GHz band (7125-7250 MHz) for unlicensed use, and NTIA should study making the remainder of the 7/8 GHz band available on a coexistence basis for unlicensed and shared-licensed use on an expedited timeframe. The 7/8 GHz band has been under consideration since 2018, when NTIA was directed to evaluate ‘spectrum-sharing tools and techniques that increase spectrum access, efficiency, and effectiveness.’ And just recently, in December 2023, the International Telecommunication Union World Radiocommunication Conference 2023 recommended further technical studies of the band for International Mobile Telecommunications use. Accordingly, NTIA should take the necessary next step of studying the full band and enabling its use promptly to solidify the U.S.’s role as a global spectrum policy leader.”

Consumer Technology Association

“The future connected world is jaw-dropping in its expanse and potential: multitudes of devices communicating with each other to improve quality of life across many metrics, with enormous promise to transform our lives and society. These devices are critical to our economy: a 2022 CTA report estimates that unlicensed spectrum alone generates $95.8 billion per year in incremental sales value based on a comprehensive review of available device sales data, conducted by examining more than 75 product categories and dozens of spectrum bands. As they have for years, unlicensed technologies, including devices using Wi-Fi and Bluetooth, will feature prominently across the show floor at CES 2024. This will include personal devices like connected health and fitness, pet technology as well as smart appliances, lightbulbs, doorbells, TVs, phones and watches. Going forward, additional unlicensed spectrum will empower innovations such as AR/VR, drones, connected vehicles, telehealth, precision agriculture and AI.”

NCTA

“Access to the Lower 7 GHz band would deliver enormous value for American consumers by completing a 320-megahertz channel currently stranded at the top of the 6 GHz band. Next, NTIA should study additional frequencies in the band to determine how the use of established unlicensed coexistence mechanisms or dynamic sharing techniques can permit a diverse group of commercial users and use cases to coexist with the range of different incumbent Federal agencies using these frequencies. As NTIA has recognized, unlicensed spectrum access is also an essential complement for wireless competition and innovation: It lowers barriers to entry for experimentation and innovation, and it carries the vast majority of internet traffic. Wi-Fi, using unlicensed spectrum, serves as a critically important wireless technology in homes, businesses, schools, and healthcare facilities, and carries more traffic for smartphones than the entire cellular network.”

Wi-Fi Alliance

“Wi-Fi delivers the majority of Americans’ broadband connectivity. In fact, over half of all Americans’ internet traffic transits a Wi-Fi connection and approximately 80% of mobile traffic is transmitted over Wi-Fi. Wi-Fi and other unlicensed technologies have changed the way people work, provide and receive healthcare, and learn. Wi-Fi is also a critical component of Internet of Things (“IoT”) connectivity and supports an ever-expanding variety of applications and use cases, such as home control (“smart home” devices), security, and entertainment.

In addition to the key role that Wi-Fi connectivity plays in enabling America’s connectivity, Wi-Fi also delivers significant economic value. In the United States alone, Wi-Fi is on pace to contribute more than $1.5 trillion in economic value by 2025 and it is estimated that between 2021 and 2025, Wi-Fi will have generated nearly 720,000 jobs.

However, the benefits of Wi-Fi deployment depend on sufficient access to spectrum. Without enough available spectrum, Wi-Fi-connected devices simply cannot provide the fast and reliable connectivity on which most Americans rely. While there are already an estimated 19.5 billion Wi-Fi-enabled devices in use globally, billions more will be deployed in the coming years, supporting more spectrum-intensive use cases.”