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The Open Technology Institute at �鶹������ý filed with the Federal Communications Commission (FCC) as part of the Broadband Access Coalition on the feasibility of allowing commercial wireless services to use or share use of the 3.7 – 4.2 GHz band. OTI and the Broadband Access Coalition submitted these comments as part of its ongoing efforts for the FCC to authorize a new, licensed, point-to-multipoint (P2MP) fixed wireless service in the underutilized 3700 – 4200 MHz spectrum band used primarily by fixed satellite services. Opening this spectrum would catalyze fixed wireless services to begin bridging the rural broadband gap. An introduction and summary of the comments are copied below:

From the outset of this proceeding, the Coalition has repeatedly demonstrated the feasibility of allowing commercial licensed point-to-multipoint (“P2MP”) fixed wireless broadband services to share use of the 3.7 – 4.2 GHz band with incumbent Fixed-Satellite Service (“FSS”) and Fixed Service (“FS”) users under Part 101 of the Commission’s Rules. Nearly one year ago, on June 21, 2017, the Coalition filed a Petition for Rulemaking (the “Petition”) proposing to amend and modernize Parts 25 and 101 of the Commission’s Rules to enable deployment of high-throughput, licensed P2MP fixed wireless broadband services in the 3.7 – 4.2 GHz band in a spectrally efficient manner, while protecting FSS and FS incumbents from harmful interference through Part 101 frequency coordination. The Petition proposed specific and concrete rule changes that would enable the immediate introduction of P2MP fixed wireless broadband service into the 3.7 – 4.2 GHz band without disrupting incumbent operations.

Subsequently, the Coalition filed Comments and Reply Comments in response to the Mid-Band NOI. In its Comments and Reply Comments, the Coalition further demonstrated the feasibility of allowing commercial licensed P2MP fixed wireless broadband services to share use of the 3.7 – 4.2 GHz band with incumbent FSS and FS users.5 Consistent with the directive in the Public Notice,6 today’s Comments incorporate by reference the Coalition’s Petition and other filings in RM-11791 and its Comments, Reply Comments and ex parte presentations in GN Docket No. 17-183.