37. 1780-1850 MHz. The 1780-1850 MHz band, which is part of the larger 1755-1850 MHz band, is allocated to the fixed and mobile services on a primary basis for Federal use and assigned to a wide-range of military and other government uses. As noted above, NTIA reports that the Federal government uses the entire 1755-1850 MHz band across the nation and that the majority of Federal services that operate in the 1755-1780 MHz band also operate in the larger 1755-1850 MHz band. Although the commercial wireless industry appears primarily interested in the 1755-1780 MHz portion of the 1755-1850 MHz band to pair with the 2155-2180 MHz band, NTIA has been studying the entire 1755-1850 MHz band and industry has not entirely dismissed the possibility of seeking access to this spectrum in the long term. NTIA reports that it appreciates the Commission's "recognition of the potential need to address rules to accommodate the phased relocation of the entire 95 megahertz of the 1755-1850 MHz band."
38. Because of the commercial industry's focus on the 1755-1780 MHz band, NTIA makes several requests of the Commission. First, NTIA requests consideration of the potential for a phased transition to facilitate commercial access to the 1755-1780 MHz band in a shorter timeframe while preserving longer-term repurposing and transition opportunities for the entire 1755-1850 MHz band. Second, NTIA requests that if a Commission auction of the 1755-1780 MHz band results in the relocation of or sharing with Federal systems that currently have access to the entire 1755-1850 MHz band, agency transition plans for the lower 25 megahertz account for those systems, even if the Commission holds multiple auctions over time. Third, NTIA requests that, if necessary, the Commission assist NTIA in identifying and reallocating replacement spectrum to accommodate displaced Federal operations unless these agencies can maintain comparable capability of systems via sharing or utilizing alternative technology. We invite comment on the NTIA plan for ultimately making the entire 1755-1850 MHz band available for wireless broadband based on a phased transition. How could this spectrum be used in ways that would significantly answer the need for additional wireless spectrum? Should different portions of the band be made available with different service rules, including, for example, technical rules, and sharing/coordination provisions?
39. 2095-2110 MHz. As discussed above, CTIA recommends that the Commission consider identifying 2095-2110 MHz as the additional 15 megahertz for reallocation under this statutory provision. We invite comment on CTIA's recommendation. We note that footnote 5.391 to the Table of Frequency Allocations states administrations shall not introduce high-density mobile systems into this band. Parties that advocate licensing 2095-2110 for wireless broadband should explain how such use can be reconciled with the footnote 5.391, including the underlying need to protect U.S. and foreign space systems, and describe in detail the technical, operational, and licensing rules that we should apply. Commenters should also describe potential effects on incumbent BAS users and Federal users, particularly given that this proposal would appear to conflict with use of two of the seven BAS channels available in the 2025-2110 MHz band. Additionally, as described above,
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