Today, AT&T is responding to a Request for Information from the U.S. Department of Defense (DoD) that seeks comment on spectrum sharing technologies and leasing arrangements; asks whether the DoD should own and operate its own 5G network; and addresses myriad technical, statutory, legal, regulatory and policy issues associated with new approaches to spectrum sharing.  What’s really at issue, however, is the determination of a vested minority to roll the dice with American 5G leadership by upending the proven methods of delivering wireless service in the U.S. in favor of unproven spectrum allocation approaches.

Before getting into why it makes no sense to do something so drastic and unproven (whether you call it “nationalizing” or “wholesaling” or “spectrum arbitrage”), let’s consider why the U.S. is currently the recognized global leader in wireless.  From the Nobel Prize in economics awarded this year to a pair of Americans who pioneered new spectrum auction frameworks; to America’s wireless providers’ $29.1 billion investment last year to meet the growing demand for mobile data and to continue to build out 5G networks; to the 70 percent of Americans who use a cellphone, the incredible growth and widespread impact of U.S. wireless services are the result of ingenuity and free enterprise.

For these reasons, we share the DoD’s goals of ensuring the spectrum necessary to deploy 5G is being efficiently and effectively utilized.  We also support the DoD’s efforts to pilot and test new approaches to 5G, as seen in the recent $600M in awards by the DoD for prototype development and testbed implementation.  Today, we offer suggestions on how best to achieve these objectives.  But the answers sought will be found neither in a new national military cellular network nor in a broad scale wholesale/leasing scheme, which will not deliver the benefits its proponents claim.  Those approaches would, at this pivotal moment, be a huge step in the wrong direction.

America leads the world in mobile broadband technology and deployment because the federal government has consistently relied on market-driven auction forces and private capital to get the job done.  By using FCC-administered auctions to assign frequencies to the private companies most capable of deploying them for the public good, our wireless networks are the envy of the world.

It’s a process that has served both the DoD and the general public exceptionally well. The AWS-3 auction by itself generated $40 billion for the U.S. Treasury and placed spectrum rights in the hands of the commercial providers best able to bring the power of 4G mobility to America while protecting incumbent defense and national security uses in specified geographic locations.

Indeed, geographic sharing has been proven to be an effective way to promote commercial usage while protecting incumbent services.  And while we support innovative new approaches to spectrum sharing, we must proceed with caution, grounding each step in what has been proven to work.  Going immediately all-in on dynamic spectrum sharing (DSS) implementation without fully understanding its possibilities and its limitations threatens to undermine all the progress we’ve made to date.

One need only look to the CBRS band to understand DSS comes at a price. First, to support the type of sharing envisioned in the band there are strict power restrictions that limit the utility of the band, particularly in urban areas. While there is great promise in the band for local area industrial solutions, for example, wide area 5G deployments will be challenged. Second, we are learning that the sensing capabilities that are the foundation for true dynamic assignments are falling short of delivering as promised. In a recent panel discussion, one industry expert argued that the entire environmental sensing capability (ESC) system should be scrapped. It turns out that DSS may not be so dynamic after all. In short, DSS is far from ready for 5G prime time.

There are, however, proven paths to a successful transition to our 5G future.  The first steps have already been taken.  The DoD, in partnership with the FCC, is already working to bring critical mid-band spectrum to auction in 2021.  That effort must continue.  Second, the federal government should continue to work with the private sector to leverage the massive investments already underway in commercial 5G technologies to innovate 5G services in support of our nation’s defense needs. The recent awards on testing and prototypes will move that effort forward effectively.

Finally, a word on “spectrum arbitrage,” or the notion that some unproven wholesale approach will attract investment dollars to rural America and rain money down on the DoD.  Spectrum is only one piece of the wireless infrastructure puzzle.  It’s an essential piece to be sure, but spectrum licenses generally represent only a small fraction of the expense of delivering wireless service to end users.  The bulk of the costs arise from the need to deploy hard assets, such as ubiquitous radio access networks (RAN) and fiber-backhaul infrastructure.  Without high-speed backhaul, there is no path to true 5G.  And an unproven spectrum arbitrage scheme does nothing to address the economic challenges of deploying fiber and RAN infrastructure to sparsely populated communities.

We stand ready to support the Defense Department with its 5G needs.  We have successfully deployed a nationwide first-responder network – FirstNet – in partnership with the U.S. Department of Commerce.  Through FirstNet, we have shown how a private network operator can provide priority, preemption and a secure, dedicated network core to governmental partners, while leveraging and maximizing the value of commercially deployed assets, including in rural areas.

The U.S. wireless industry has been a bright spot in the darkest hours of a tumultuous 2020.  It has delivered through a pandemic, social unrest, expansive wildfires and unprecedented natural disasters.  Our 5G future lies on the paths that have been proven to incent deployment and foster innovation and wireless leadership.  There is simply no reason to take a gamble and rush through an unproven and barely tested change of course now.

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