¹ú²úÊÓƵ

The Open Technology Institute at ¹ú²úÊÓƵ—along with Charter Communications, Inc.; Federated Wireless, Inc.; Qualcomm Incorporated; Starry, Inc.; and WISPA—submitted in response to the Wireless Telecommunications Bureau Public Notice seeking information on sharing the Lower 37 GHz band (37.0-37.6 GHz band) in the context of the forthcoming report mandated by the National Spectrum Strategy (NSS) Implementation Plan. These joint comments explain the common ground the groups agree should be incorporated into the NSS Implementation Plan for the Lower 37 GHz report. We argue that:

• The lower 37 GHz band should be made available in the near term to enable low-barrier shared access to high-capacity millimeter-wave spectrum for innovative use cases,
• The Commission should adopt a non-exclusive, non-auctioned shared licensed framework with a dynamic spectrum management system that leverages experience from other shared bands, and
• The Commission should adopt a common licensing and spectrum management framework for both the Lower 37 GHz and 42 GHz bands to enable commercial flexible use operations on a shared basis and facilitate access to both bands.