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CEI CLIP - FCC Comments on 700 MHz Interoperability

CEI CLIP - FCC Comments on 700 MHz Interoperability

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Categories:Types, Letters
Published by: Competitive Enterprise Institute on Jun 02, 2012
Copyright:Attribution Non-commercial

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06/02/2012

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www.driveinnovation.orgJune 1, 2012
CommunicationsLiberty
and 
Innovation Project
 
Interoperability in the 700 MHzCommercial Sectrum
Liberty Drives Innovation
 
2The Communications Liberty and Innovation Project
1
submits these comments inresponse to the Notice of Proposed Rulemaking released on March 21, 2012.
2
 The Commission says that the “core” issue in this proceeding is whether a unifiedtechnical standard would result in harmful interference to lower 700 MHz licensees in theB and C Blocks. By framing the issue in technical terms, the Commission is attempting tobypass the threshold policy issues raised by its proposed interoperability mandate: Shouldthe Commission abandon its flexible use policies in the mobile bands? Should theCommission impose a technology mandate
after 
licensees have purchased spectrum atauction and begun deployment in reliance on the Commission’s assurances that it would“look to them to consider potential interference situations when designing anddeveloping their systems.”
3
The answer is “No.” Imposing technology mandates only afterthe deployment of systems based on consensus-based industry standards that are in fullcompliance with the Commission’s rules would be manifestly unjust, deter investment inmobile infrastructure, and inhibit innovation.
1
TheCommunications Liberty and Innovation Project(CLIP) is a project of theCompetitive Enterprise Institute. CLIP supports 21st Century policies that promoteboundless innovation, private investment, and sustainable economic growth through freemarkets and entrepreneurship in America’s technology industries.
2
Promoting Interoperability in the 700 MHz Commercial Spectrum,
Notice of Proposed Rulemaking 
, FCC 12-31 at ¶¶ 3-5 (2012) (
700 MHz Interoperability NPRM 
).
3
Reallocation and Service Rules for the 698-746 MHz Spectrum Band (TelevisionChannels 52-59),
Report and Order 
, FCC 01-364 at ¶ 23 (2001) (
Lower 700 MHz Report and Order 
).
 
3
A.
 
An interoperability mandate would be inconsistent with theCommission’s rules and expectations for the 700 MHz Band
The Commission attempts to avoid a policy discussion by implying that thedeployment of non-interoperable services in the 700 MHz band was unexpected andinconsistent with Commission policy. This implication is revisionist history. TheCommission not only expected that different technology standards would be deployed, it
encouraged 
them. It should be no surprise that licensees accepted the Commission’sinvitation.From the band’s very inception, the Commission envisioned that it would be usedfor a “wide range” of fixed, mobile, and broadcast services employing a variety of technology standards,
4
including “stand-alone technologies.”
5
Based on its “own review of technical issues,” the Commission found “that a flexible, market-based approach is themost appropriate method for determining service rules in this band.”
6
The Commissionthus allowed “licensees to make determinations respecting the services provided andtechnologies to be used . . . so long as those services comply with our technical rules.”
7
Itexpected that such services “could include mobile and other digital new broadcastoperations, fixed and mobile wireless commercial services (including FDD- and TDD- 
4
 
See
Service Rules for the 746-764 and 776-794 MHz Bands, and Revisions to Part 27 of the Commission's Rules, First Report and Order, FCC 00-5 at ¶ 1 (2000) (
Upper 700 MHz First Report and Order 
).
5
 
See
 
id 
. at ¶ 18.
6
 
See
 
id 
. at ¶ 2.
7
 
See
 
id 
. at ¶ 15.

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