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Google: FCC's 3.5GHz Policies Are "Overprotective"

In the shadow of the upcoming spectrum auction in March, the FCC issued policies not too long ago outlining some protections for 3.5GHz wireless spectrum, 3550MHz-3700MHz specifically. These protections are in place to allow certain high-priority operations like radar and satellite to operate without interference. Many spectrum licensees are pushing for more protections, some of which may potentially bar newcomers and leave spectrum on the table. After hearing of these protections via a public notice, Google made their own FCC filing to put their two cents on the table. In their FCC filing, Google wrote, “for example, some commenters suggested protection radii of at least 6 and up to 24 kilometers around their current operations, regardless of the directionality of their antennas station. Establishing such indiscrimiate protection zones will leave spectrum underutilized.” Instead, Google wanted to have protections based on actual usage patterns to ensure a lack of interference while also leaving spectrum alone for others to use in the area.

Google went on to point out that, in many ways, the FCC is “making worst-case assumptions regarding interference”. They also say that the FCC should set interference limits higher for protected sites, since this would ease the transition into the new spectrum rules and allow more usage by new users and allow easier transferring of old operations to new frameworks on the new spectrum scheme, hopefully at no cost to incumbents. They also wanted the FCC to adapt the new protections to protect “specific installation locations and frequencies”. Some of these policies threaten to leave about 150MHz of spectrum unused and sitting available for incumbents in case they want to shift their usage during the transitional period.

Ideally, there will be no unutilized spectrum and everybody who is going to use the airwaves will have enough protection to keep their operations running smoothly. Google, in particular, has a stake here because of things like drone operations, Project Loon and other moonshot projects, and of course, the fact that wireless carriers are the primary adoption method for their own Android OS. With spectrum utilization at maximum, there should be no shortage for anybody’s operations, although the upcoming auction may end up giving some bidders an inordinate amount of spectrum compared to others.