NTIA's National Spectrum Strategy Must Ensure Meaningful Access for Small ISPs to Licensed, Shared and Unlicensed Spectrum

The following statement may be attributed to Louis Peraertz, VP of Policy for WISPA – Broadband Without Boundaries:

Licensed, shared and unlicensed spectrum enable trillions of dollars of annual growth and productivity in our economy.?It helps us stay in touch with our families, friends and communities.?Keeps us safe and healthy.?And plays an integral and expanding role in how we effectively and equitably self-govern.?But spectrum is finite.?Little greenfield spectrum exists yet demand for wireless services which depends on access to spectrum continues to grow.?

To this end, WISPA applauds and supports the development and implementation of NTIA’s National Spectrum Strategy (Strategy) as it seeks to better understand the complex future of spectrum availability and access.?Armed with the guidance derived from it, policymakers will be able to make better use of fallow and underutilized spectrum, providing the wireless economy more tools to meet consumer demand for the years ahead.?This will help Americans live more connected and prosperous lives, especially in hard to serve rural, under-resourced and Tribal communities of the country, which stand the most to gain from meaningful access to more wireless services.?????

Specifically, WISPA urges NTIA to adopt the following policy priorities:

• Create an audit of actual use of spectrum by federal and non-federal users.
• Build a balanced spectrum policy that enables access to spectrum by large and small providers to licensed, shared and unlicensed spectrum.
• Auction spectrum in smaller blocks and smaller geographic areas.
• Focus on spectrum sharing via spectrum coordination methods such as SAS and AFC models for sharing among federal and non-federal users (e.g., CBRS) and sharing among different kinds of non-federal users (e.g., 6 GHz).
• Study other bands, such as the 3.1-3.45 GHz and 10 GHz bands, in the short-term for shared use.

Spectrum can go places more quickly and at less capital cost than traditional wired connectivity.?Consequently, wireless broadband is an answer in the U.S. to bridging the digital divide.?On top of wired alternatives such as fiber, WISPs use licensed, shared and unlicensed spectrum as core infrastructure to carry reliable broadband to nine million Americans.?Having more commercial spectrum would allow them and others to more flexibly achieve the national policy prerogative of universal service to all Americans quicker and at far less cost to taxpayers.???

WISPA stands ready to engage with NTIA and all stakeholders to build a balanced Strategy which works with incumbents and commercial interests to get more spectrum infrastructure quickly and equitably into use.

A copy of the filing can be obtained here.