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combined with the lower 12 GHz to create a con guous 1,000 upper mid-band spectrum that could be put to use rather rapidly. "It's poten ally a game-changer for capacity," he said. CTIA: Make it licensed CTIA previously said that it wants to see the band allocated for exclusive-use licenses that the major U.S. wireless carriers could use for their services. Likewise, the na on's biggest carriers are discouraging the commission from adop ng any kind of shared usage in the 13 GHz band, saying an exclusive-use, licensed framework is the best way to go. CTIA pointed out that three blocks of lower mid-band spectrum offer the greatest poten al for 5G expansion: the lower 3 GHz band (3.1-3.45 GHz); the mid 4 GHz band (4.4-4.94 GHz); and the 7/8 GHz band (7.125-8.4 GHz). But it's not turning its back on this or any other spectrum. CTIA said the 13 GHz band is par cularly suitable for exclusive use licensing, as it already has primary fixed and mobile alloca ons and limited federal users, which makes it easier to expedi ously repurpose the band. Plus, the majority of incumbent uses can be efficiently accommodated through reloca on, according to the organiza on. Others say: Make it shared use The Open Technology Ins tute (OTI) at New America and Public Knowledge (PK) said a shared-licensed framework would be a par cularly good fit for the 13 GHz band if the commission decides not to relocate incumbent services to other bands. A shared-license framework that includes both priority access licenses and opportunis c use can also enrich and diversify the na on's developing 5G wireless ecosystem "in a way that specifically meets the needs of smaller wireless ISPs, innovators, community anchor ins tu ons and the tens of thousands of individual enterprises that will choose to customize their own private IoT, neutral host or access network," according to OTI and PK. Federated Wireless, which is a Spectrum Access System (SAS) administrator for the 3.5 GHz CBRS band, recommends the commission consider a similar mul - ered licensing framework for the 12.7-13.25 GHz band to protect the incumbents while offering access to new users. Federated offered up several ways the FCC could develop such a framework. Hold on a minute While the 13 GHz band is considered mostly unencumbered with fewer federal users compared to other bands, the Na onal Telecommunica ons and Informa on Administra on (NTIA), which oversees federal spectrum ma ers, said there are a variety of federal uses of 12.7-13.25 GHz and adjacent bands, as well as commercial uses that are important to federal missions. Therefore, NTIA is concerned about the poten al for harmful in-band and adjacent-band interference if the 12.7-13.25 GHz band were repurposed as contemplated in the FCC's No ce of Inquiry (NOI). NTIA said before the FCC reaches any conclusions here, there needs to be addi onal technical analysis to evaluate the effects of repurposing the spectrum. NTIA said its adjacent-band concerns are mostly with the 13.25-13.75 GHz band, which is primarily a federal band with both military and scien fic uses. Meanwhile, the Na onal Associa on of Broadcasters (NAB) said the FCC must ensure that broadcasters retain reliable access to spectrum to cover live events and breaking news. NAB acknowledged that it may be possible to repack broadcaster opera ons in the 13 GHz band into a smaller por on of the band, but it wants to make sure broadcasters don't have to bear any costs associated with reloca on. Also in the "hold it" camp are satellite players like Hispasat S.A., a Spanish satellite communica ons operator and content distributor. Hispasat said the agency should refrain from any ac on to repurpose the 12.7-13.25 GHz band for terrestrial mobile broadband and instead find ways to increase spectrum available to satellite operators that are seeing increased demand for their services. The FCC received more than 30 comments on the topic. Another round of input is expected, with reply comments due to the FCC by January 10, 2023. Ar cle Credit: h ps://www.fiercewireless.com/5g/fcc-hears- all-about-how-it-should-deal-13-ghz-band Talleycom.com SHEET QUARTER 4 2022

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