FCC's 5.9 GHz and 3.3-3.5 GHz Proposals Good for Wireless Marketplace, Rural Americans

The following statement may be attributed to Louis Peraertz, VP of Policy for WISPA:
Washington, DC, December 12, 2019 – Today’s work by the FCC to open up more spectrum – as seen in the Commission’s 5.9 GHz and 3.3–3.5 GHz proposals – continues the good and necessary efforts to provide the raw resource underpinning the evolving U.S. wireless broadband marketplace.   Taking fallow spectrum in the 5.9 GHz band and dedicating 45 MHz of it to new unlicensed uses will both improve Wi-Fi performance and help extend commercial fixed wireless offerings which sit contiguous to the band.  Similarly, in working to clear the 3.3-3.55 GHz of non-federal incumbents so that it can eventually be safely used for more widespread commercial use, the FCC takes yet more giant steps to reclaim grossly underutilized spectrum for higher and better purposes.
Of course, demand for wireless broadband uses will not abate.  The challenge to find new spectrum to satisfy those needs will only grow.  The Federal government occupies over 80% of useable spectrum, much of it going to inefficient use.  Key to getting more out of this resource is spectrum sharing.  We know sharing works.  It’s being employed successfully in the CBRS band sitting adjacent to the 3.3-3.55 GHz band.  The CBRS “sharing experiment” is so successful, in fact, it is expected to move to fully approved commercial deployment within a matter of weeks.  If it can work in the exceedingly complex and critical CBRS realm, it can work also in the 3.3-3.55 GHz, C-band, 6 GHz band and elsewhere.  It must.  New and exciting unlicensed uses, such as those delivered by fixed wireless companies and others, are eagerly awaiting to deliver on the promise of wireless broadband, and spectrum sharing can make that happen quickly and cost-effectively. 
Sharing spectrum via lightly licensed approaches is especially important to rural Americans.  WISPs already serve 6 million, mainly rural customers with their powerful and innovative broadband services.  They serve areas stranded, neglected or simply left behind by legacy telecom providers through broadband services which bring rural consumers into our digital economy. While there is much hype surrounding the promise of 5G, rural Americans are smart enough to know that 5G will not be making its way out to the hinterlands any day soon.  Put bluntly, it is not a timely answer to the digital divide.  Sharing lightly licensed spectrum can, though, giving local fixed wireless providers a powerful tool to boost and improve coverage to serve their vibrant, rural communities. 
We urge to Commission to continue its good work.  We also respectfully ask that as it moves forward, it dedicates more unlicensed and lightly licensed spectrum to new uses, as well as more actively pursue sharing of that spectrum so that all Americans, no matter where they live, are not left behind. 
WISPA’s approximately 800 members are composed of fixed Wireless Internet Service Providers (WISPs) and the industry that supports fixed wireless broadband, including equipment suppliers, support services, and other components needed to run a successful business. Our members, and WISPs, in general, provide broadband access to over 4 million residential and business customers, often in exclusively rural areas.
Mike Wendy