The Petition

The Petition for Rulemaking seeks to add a new, licensed, point-to-multipoint (P2MP) Fixed Wireless service in the underutilized 3700 - 4200 MHz band used primarily by fixed satellite services (FSS). The proposed licensing scheme and operating rules will enable gigabit and near-gigabit broadband service in rural and underserved areas, promoting competition for broadband delivery among various technologies and licensees.

The Petition is submitted by a broad-based coalition of broadband providers, technology companies, trade associations, and non-profit public policy advocacy groups. The Petition seeks expedited adoption under Section 7 of the Communications Act, which requires a public interest determination within one year.

Read Our Full Petition

Read the Comments

Mid-Band NOI: BAC Comments


  • Summary of Petition

    Would authorize 500 megahertz of contiguous mid-band spectrum for licensed P2MP broadband services.

    The shared use of the band for P2MP broadband services can be implemented rapidly and simply by the FCC and service providers because:

    Incumbent FSS and Fixed Service (point-to-point) will be protected from harmful interference.

    Existing Part 101 frequency coordination procedures will be used, pending transition to an automated frequency coordination system to be developed by a multi-stakeholder group.

    No new allocations are needed

    There are no Federal government allocations in the band.

    No sophisticated spectrum management techniques, like SAS, are required.

  • Policy Benefits

    Rapidly makes available 500 MHz of mid-band spectrum for licensed P2MP broadband service.

    Supports Chairman Pai’s “Digital Empowerment Agenda” by establishing a new service as “spectrum infrastructure.”

    Enables gigabit and near-gigabit Fixed Wireless service in Tribal, rural, and suburban areas where consumer choice is lacking and where FTTH deployment costs are prohibitive.

    Accelerates the policies behind MOBILE NOW by inviting immediate FCC action regarding the 3700 - 4200 MHz.

    Promotes efficient use of a greatly underutilized spectrum resource by maximizing sharing.

  • Technical Proposal – Modernizing Part 25

    Require FSS licensees in the C-band to refresh the IBFS database to remove “ghost” earth stations and provide the specific frequencies and locations currently used and the orbital slot being accessed.

    Coordination would be undertaken using modern “real world” protection standards, not the antiquated “full-band, full-arc” policy that has contributed to underutilization of the spectrum band.

    Coalition will work with the FSS C-band industry to define the circumstances when changes in frequency and/or orbital slot communications will be necessary, and to refine the procedures that will implement the changes so that FSS operations can be preserved.

  • Technical Proposal – Modernizing Part 101

    Expand Part 101 to include P2MP fixed wireless broadband service

    Licenses would be issued for self-defined areas coordinated under Part 101, with a 30- day reservation period and a one-year build-out requirement to incentivize expeditious deployment.

    Licenses would be awarded in 20-megahertz channels. No licensee could obtain access to more than 40 megahertz in a given area unless it first meets its build-out requirements for the initial 40 megahertz.

    Licensees could obtain licenses for up to 160 megahertz in an area, meaning that there would be a minimum of three separate competitors licensed in an area.

    Frequency agile radios capable of operating across the entire 3700 – 4200 MHz band, and able to accommodate any 20 MHz channel, would be required.

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