TPA Responds to DoD RFI regarding Dynamic Spectrum Sharing and 5G deployment

October 19, 2020

Gloria Norwood, Lead Contracting Officer
Department of Defense
1000 Defense Pentagon
Washington, D.C. 20301-1000
Via Electronic Filing

On the Request for Information regarding Dynamic Spectrum Sharing and 5G deployment:

The Department of Defense (DOD) should be commended for trying to help the United States win the race to 5G wireless deployment, but creating a government-owned and operated network is the wrong approach. In fact, such a move could have the unintended consequence of slowing 5G deployment by taking resources away from wireless carriers who are now rapidly building fifth generation wireless infrastructure. Deploying nationwide high-speed 5G wireless networks quickly will help close the digital divide while protecting taxpayers.

By pushing for lower siting fees and cutting various regulatory red tape, the Federal Communications Commission (FCC) has taken smart and aggressive steps to facilitate the nationwide deployment of 5G. Those moves have paid off, resulting in the rapid growth of 5G. The fact that the country’s largest carriers (AT&T, Verizon and T-Mobile-Sprint) are all now deploying 5G weakens the case for a national network. Creating a national network with the resources of American taxpayers will prove not only redundant, but could threaten national security by giving bad actors a single target to disrupt communications across the country.

This is not a partisan issue for the FCC.  Every commissioner on the FCC is united against the concept of nationalized 5G. A 2018 article in The Hill noted, “’The United States’ leadership in the deployment of 5G is critical and must be done right,’ Mignon Clyburn, one of the Democrats on the commission, said in a statement. ‘Localities have a central role to play; the technical expertise possessed by industry should be utilized; and cybersecurity must be a core consideration. A network built by the federal government, I fear, does not leverage the best approach needed for our nation to win the 5G race.’”

In a letter to President Trump last month, 19 Republican senators pointed out that the U.S. won the race to 4G against China and other nations by empowering the private sector to build multiple competitive networks by freeing up spectrum and reducing regulations. They argued that the DOD’s request for information contradicts the President’s successful free-market strategy.

Rather than consider building a nationalized 5G network, DOD should follow the lead of the FCC and help push the market-based approach that is already working. For example, the DOD should continue with its plan to work with the FCC in December 2021 to auction off shared spectrum in the 3450-3550 MHz range to private providers in order to facilitate 5G infrastructure growth. Auctioning, rather than leasing, the spectrum ensures that the bandwidth will be put to good use and removes doubt from recipients about the future status of the spectrum.

The request for information formally admits that the DOD can share spectrum without affecting military preparedness so there is no reason not to move forward with an auction. This farsighted move will maximize the efficiency of that spectrum and the DOD can share in the proceeds if Congress gives its approval.

The DOD should also continue to examine ways to partner with wireless carriers to facilitate 5G, such as the “living lab” project for military and defense-related uses of 5G with Verizon at the Marine Corps Air Station in Miramar, California.

Building out a private, nationwide 5G network is critical for consumers and businesses.  Whether it’s working (or learning) from home, receiving remote medical information/diagnosis, ordering food, or simply being entertained, consumers need the tools to access high speed broadband without government interference.

Efficient construction and use of a nationwide 5G network grounded in free enterprise is critical for business.  According to a February 2020 report by Act, The App Association, “The broadest impact on the labor market comes from new employment opportunities through the way 5G will enable new applications, services, ways of doing business, and general growth of businesses.”

Allowing the private sector to take lead in next-generation broadband deployment will help the U.S. win the race to 5G and extend the digital domain to the most Americans at the fastest speed possible.

Sincerely,

David Williams, President