This week, WifiForward submitted comments to the National Telecommunications and Information Administration (NTIA) on the development of a National Spectrum Strategy, emphasizing our support for unlicensed and shared licensed spectrum. And we’re not the only ones: Many other voices chimed in to share the importance of a balanced spectrum policy.
These comments are an important first step towards developing a roadmap for spectrum management that will ensure the U.S. continues to lead on innovation over the next decade. As NTIA seeks to identify additional spectrum for commercial use in increasingly crowded spectrum bands, creating a balanced approach to how spectrum is allocated will play an important role in our nation’s wireless and competitive future. The potential benefits are immense, and the possibilities for the future are endless – so it’s critical that we get the National Spectrum Strategy right.
In our comments to NTIA, WifiForward urged the administration to take a balanced, all-of-the-above approach, specifically supporting:
- protecting and strengthening existing unlicensed spectrum designations,
- efforts to free up new spectrum for unlicensed use at a variety of frequencies including low, medium and high-frequency bands and
- investment-friendly, transparent, predictable unlicensed rules that encourage growth and deployment.
We went on to point out that advances in technology enable us to establish spectrum policy not through antiquated, incumbent approaches based on scarcity, but on dynamic, future-forward applications that facilitate rapid innovation and wider use of our nation’s airwaves.
WifiForward stands ready to work with NTIA to ensure that any National Spectrum Strategy prioritizes innovation and enables all types of users to access spectrum.
WifiForward is not alone in this effort. Last week, we spearheaded a letter to NTIA from industry and public interest groups in support of unlicensed and shared spectrum. In comments filed this week, several industry and public interest voices called for a balanced approach. Here are just a few examples of what others are saying…
Industry:
Broadcom expressed its support for the strategy and emphasized the importance of expanding spectrum availability. “Broadcom supports a comprehensive national spectrum strategy that focuses on rapidly making licensed, lightly licensed, and unlicensed spectrum available,” the company stated in its comments. “In particular, we believe it is vital to complete the 6 GHz band by extending it up to 7250 MHz to create a fourth nationwide 320 MHz low power channel to meet the growing demand we see for indoor wireless services.”
Amazon recognizes the importance of spectrum access for innovation, economic growth, and national security. They suggest that identifying 1,500 megahertz of spectrum for potential repurposing to allow more intensive use is a reasonable starting point for the NTIA to consider in shaping a proactive National Spectrum Strategy. Amazon stresses that the strategy must recognize the value of all wireless technologies and be regularly updated to reflect our increasingly connected and wireless world. They emphasize the importance of this saying that “at Amazon, almost everything we do for consumers is built on connectivity, including wireless technologies enabled by spectrum. We are committed to developing innovative wireless devices and services for consumers, and to enabling and expanding affordable connectivity.”
The Wi-Fi Alliance argues that “enabling Wi-Fi in conjunction with ongoing fiber and satellite broadband deployments will deliver versatile and extremely affordable connectivity, making Wi-Fi an ideal force multiplier for connectivity. NTIA should leverage proven coexistence techniques to expand spectrum access for Wi-Fi, which is urgently needed by U.S. consumers, businesses, and institutions.”
According to Comcast, coexistence technologies enabling services by commercial and incumbent users are crucial in expanding spectrum access. Comcast recommends that NTIA and the Federal Communications Commission (FCC) make the 7.125-8.400 GHz (“7/8 GHz”) band available for unlicensed and shared use, as well as the 3.1-3.45 GHz (“Lower 3 GHz”) band for shared use. By pursuing a spectrum policy that leverages these coexistence technologies, the NTIA and other federal agencies can help to address the urgent need for expanded spectrum access for consumers, businesses, and institutions.
Additionally, NCTA commends the NTIA for its tireless efforts in developing a National Spectrum Strategy and welcomes the opportunity to provide feedback. They stress that a successful strategy must encompass licensed-exclusive, licensed-shared, and unlicensed spectrum, while also recognizing the connectivity needs of American consumers and industries. Furthermore, the strategy should evaluate the costs and challenges of clearing federal and commercial incumbents from valuable spectrum resources. In prioritizing implementation, they recommend that the NTIA focus on the 3.1 GHz band, which is already being studied for licensed-shared access, and the lower 7 GHz band, which holds great potential for unlicensed access. By taking these steps, we can ensure that the United States remains a global leader in wireless innovation and deployment.
Public Interest:
Public Knowledge recognizes the importance of a National Spectrum Strategy that prioritizes efficiency, access models, stakeholder dynamics, and diversity, equity, and inclusion. To promote the public interest, Public Knowledge recommends that policymakers should balance metrics that benefit the public and update regulations based on advancements in spectrum sharing and reuse technologies. It is also crucial to consider the impact of spectrum policies on DEI and Native American tribes to prevent inequality. By adopting a value-based framework, NTIA can steer us towards a future that provides reliable telecommunications services, and spectrum is used effectively to increase our access to education, economic, and cultural opportunities.
The SHLB Coalition asks NTIA to “enable future development of anchor-enabled broadband networks by making unlicensed, shared, and licensed spectrum available to anchor institutions and other entities.”
The Public Interest Spectrum Coalition also filed comments as a collective. They urge “NTIA to put the needs of the public first in its NSS by adopting guiding policies that are rooted in public interest values, maximizing spectrum access and bandwidth abundance through spectrum sharing, establishing a pipeline that will meet our nation’s spectrum needs, recasting efficiency using metrics that serve the public, and prioritizing diversity, equity, and inclusion (DEI)”.
Between industry and public interest groups, the consensus is clear: our nation’s economic growth depends on a balanced approach that recognizes the value of all users—not just the ones who can afford exclusive licenses. Whether you’re a big tech company or a small community anchor institution, access to spectrum is crucial for innovation and economic growth.