Federal Communications Commission
Washington, DC 20554
In the Matter of Amendment of Part 90 of the Commission’s Rules | WP Docket No. 07-100
REPLY COMMENTS OF CALIFORNIA INTERNET, L.P. DBA GEOLINKS
California Internet, L.P. DBA GeoLinks (“GeoLinks” or the “Company”) submits these reply comments in response to the Commission’s Sixth Further Notice of Proposed Rulemaking in the above-captioned proceeding.
GeoLinks largely supports the comments filed by the Wireless Internet Service Providers Association (“WISPA”) and Federated Wireless. As an initial matter, and as both WISPA and Federated Wireless point out, the 4.9 GHz band is highly underutilized. To meet the Commission’s stated goal “to ensure that public safety continues to have priority in the band while opening up the band to additional users that will facilitate increased usage,” both parties propose sharing techniques that would allow commercial users to utilize the band while protecting public safety users from harmful interference. GeoLinks believes that this approach is appropriate for the 4.9 GHz band and will help the Commission reach its stated goals.
As the Commission explains, the 4.9 GHz. Band has “fallen short of its potential.” Despite the fact that the Commission has recognized the underutilization of the band, some commenters attempt to persuade the Commission that the 4.9 GHz band should not be opened up to commercial use. The Region 21 700 MHz Planning Committee appears to urge the Commission not to open the band up to any additional licensees claiming that “additional spectrum exists to accommodate these users.” In addition, the Utilities Technology Council, the Edison Electric Institute, the National Rural Electric Cooperative Association, and the GridWise Alliance (“UTC/EEI/NRECA/Gridwise”) assert that doing so “would threaten to diminish the reliability of the band, which would in turn discourage investment by utilities and public safety and indeed effectively displace them from the band as a practical matter.”
GeoLinks asserts that the band can be utilized for commercial users while also ensuring protection for public safety users. By utilizing an automated spectrum management database system, such as those proposed by WISPA and Federated Wireless, the band could support “dynamic secondary use of the 4.9 GHz band while ensuring that primary public safety users maintain priority access and are able to operate across the band without interference from secondary users.” As Federated Wireless explains, dynamic shared spectrum is already well understood and is becoming more readily recognized for its capabilities to effectuate enhanced spectrum usage and protect users from harmful interference.
In addition, GeoLinks believes that opening up the 4.9 GHz band to commercial users will encourage investment in the band by all users, not diminish it as UTC/EEI/NRECA/Gridwise suggests. Specifically, allowing commercial users (i.e. those with commercial capital) to utilize the band will promote technological improvement by driving up demand for compatible equipment, which, in turn, will drive down price. Moreover, as both WISPer and Federated Wireless point out, the 4.9 GHz band is in “spectral proximity” to the 5 GHz and 3.5 GHz bands. GeoLinks believes that use of the 4.9 GHz band by commercial entities will encourage equipment manufacturers to create equipment that is also compatible for these other bands, increasing equipment efficiency and encouraging additional investment in the band. This will benefit not only commercial users but primary, public safety users, as well.
Based on the foregoing, GeoLinks urges the Commission to allow for commercial use of the 4.9 GHz band on a secondary basis through dynamic spectrum sharing.
/s/ Skyler Ditchfield, Chief Executive Officer
/s/ Melissa Slawson, General Counsel/ V.P of Government Affairs and Education
August 6, 2018