CEI’s CLIP Submits Comments Before the FCC on 700 MHz Interoperability

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The Communications Liberty and Innovation Project submits these comments in response to the Notice of Proposed Rulemaking released on March 21, 2012.

The Commission says that the “core” issue in this proceeding is whether a unified technical standard would result in harmful interference to lower 700 MHz licensees in the B and C Blocks. By framing the issue in technical terms, the Commission is attempting to bypass the threshold policy issues raised by its proposed interoperability mandate: Should the Commission abandon its flexible use policies in the mobile bands? Should the Commission impose a technology mandate after licensees have purchased spectrum at auction and begun deployment in reliance on the Commission’s assurances that it would “look to them to consider potential interference situations when designing and developing their systems.” The answer is “No.” Imposing technology mandates only after the deployment of systems based on consensus-based industry standards that are in full compliance with the Commission’s rules would be manifestly unjust, deter investment in mobile infrastructure, and inhibit innovation.