AT&T and Google have filed a joint letter regarding the FCC’s innovative proposal to use the 3550-3650 MHz band as a way to promote major advances in spectrum sharing and small cells deployment, including “micro cells” and “het-nets.” The 3.5 GHz band, which is presently occupied by federal government radar systems, represents a significant and unique opportunity to experiment with spectrum sharing concepts between incumbent government systems and new commercial use.

As we have noted many times, AT&T continues to support clearing and licensing spectrum below 3 GHz for exclusive use, and clearing new bands, particularly those at 1755 to 1780 MHz, must remain a priority for the U.S. Government.  At the same time, the 3.5 GHz band, and the FCC’s proposal to utilize it in small cell deployments, provides an interesting opportunity for mobile broadband operators to explore spectrum sharing models.  Even on a shared basis, spectrum in this band could be critical to increasing capacity in high demand areas and improving coverage inside buildings or other difficult to cover areas, all without causing interference to incumbent government users. In addition to licensed small cell use, the FCC has also raised interesting questions about whether this spectrum could provide opportunities for unlicensed use of as long as the federal incumbents and licensed small cell users are protected from interference.

The FCC also proposed limiting the secondary access to what they called “critical users,” which includes hospitals, utilities, and state and local governments. AT&T and Google disagree with this approach and believe limiting the tier to such small market segments is in contrast to the FCC’s goals of bringing mass market, commercial scale technologies to this band. More importantly, if the FCC’s goal was to advance the use of small cell technology, it should at a minimum, allow commercial wireless carriers access to this tier, as they are the ones deploying small cell technology now. AT&T alone has committed to deploying more than 40,000 small cells over the next three years.

As the FCC continues to explore innovative ways to use the band, AT&T and Google have outlined their collective support of some key principles around the sharing model being developed.  Clearly there is much work to be done to bring the promise of the 3.5 GHz band to fruition.  But we applaud the FCC for putting forth innovative ideas for new rules for the band, and we look forward to working with Google and other interested parties to develop trials and prototypes to bring these ideas to reality.

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