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On August 14th, OTI joined Public Knowledge in submitting reply comments to the FCC on the Second Further Notice of Proposed Rulemaking on the “Use-It-or-Share-It” Rules for Citizen Broadband Radio Service. 

Summary

OTI and PK continue to strongly support the Commission’s conclusion in the Report & Order that “Priority Access Licensees should not be permitted to exclude other authorized users unless and until their networks are in use.” OTI and PK are pleased to concur with the diverse and overwhelming majority of parties filing comments that support an engineering definition of actual “use” and the general view that protection areas can be determined and enforced objectively by the Spectrum Access System (SAS).

In our initial comments, OTI and PK proposed that the Commission can best advance its goal to “ensure that the band will be in consistent and productive use” by defining actual “use” along two dimensions: geography and time. The Commission has the opportunity to leverage the capability of the SAS – using information reported to the SAS under the rules already adopted – to dynamically determine where and when the licensed spectrum is in actual use and what protection contour will ensure non-interference.

There is now strong support in the record for the view that the Commission can best promote consistency, accountability and spectrum efficiency by requiring that the neutral SAS administrators certified by the agency make this calculation by applying a standardized algorithm to the geolocation and basic operational parameters that are reported for each CBSD as part of the required registration process. Priority Access License (“PAL”) holders are required under the rules adopted in the Report & Order to report the basic operational characteristics of each and every Citizens Broadband Radio Service Device (“CBSD”) to the SAS at the time the CBSD is registered, and to immediately update the SAS if any parameter changes. Similarly, the CBSDs regularly contact the SAS and provide (or could provide) basic information on whether they are actively transmitting. Allowing the SAS to calculate the protection areas is consistent, objective and also imposes no added reporting “burden” on PAL operators.

Download the full comments below: