In The Matter of

Before the FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

Recommendations of Advisory Committee and Draft Proposals ofNTIA for the

) ) ) ) )

IB Docket No. 04-286

2015 World Radiocommunication Conference

COMMENTS OFT-MOBILE USA

June 11,2015

Steven Sharkey Chief, Engineering and Technology Policy John E. Hunter Director, Spectrum Policy T-Mobile USA

TABLE OF CONTENTS

I.

II.

Ill.

A.

B.

c. IV.

v. Vl.

Introduction .......................................................................................................................................................... I

National Policy on Mobile Broadband ................................................................................................................. 4

WAC Recommendations 112-116 ................................................................................................................... 5

WAC/112 - 1300-1400 MHz ......................................................................................................................... 5

WAC/l 13-1375-1400 MHz and 1427-1452 MHz ...................................................................................... 8

WAC/114 on 270-0-2900 MHz 10

No Changes Limited to our Country or as necessary, our Region .................................................................. 11

Agenda Item I0 ................................................................................................................................................... 12

Conclusion ...................................................................................................................................................... 14

ii

Before the FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In The Matter of

Recommendations of Advisory Committee and Draft Proposals ofNTIA for the 2015 World Radiocommunication Conference

) ) ) ) )

IB Docket No. 04-286

COMMENTS OFT-MOBILE USA

T-Mobile USA, Inc. ("T-Mobile") 1 respectfully submits these comments in response to

the Federal Communications Commission ("Commission") Public Notice in the above

referenced proceeding ("Public Notice"). 2 T-Mobile commends the Commission for seeking

additional input from the public on recommendations from its World Radiocommunication

Conference Advisory Council. T-Mobile submits these comments to keep a path open for

mobile allocations in the 1300-1390 MHz, 1427-1452 MHz and 2700-2900 MHz bands through

U.S. Positions for WRC-15 under Agenda Item 1.1, consistent with the View Bs of the

associated industry Recommendations presented May 20, 2015, and to support the study of

spectrum above 6 GHz for IMT leading to WRC-19, consistent with View A of the item relative

to Agenda Item 10.

I. Introduction

The Commission seeks comment on the latest recommendations of its World

Radiocommunication Conference ("WRC") Advisory Committee (the "WAC") for the upcoming

1 T-Mobile USA, Inc. is a wholly-owned subsidiary ofT-Mobile US, Inc., a publicly traded company. 2 Federal Communications Commission Seeks Comment on Recommendations Approved By the Advisory Committee for the 2015 World Radiocommunication Conference, Public Notice, DA 15-604 (rel. May 21, 2015).

regional meeting of administrations from the Americas, the Committee on International

Telecommunications ("CITEL"), of the Organization of American States, the last before this

November's WRC, as well as on draft proposals provided to the Commission by the National

Telecommunications and Information Administration ("NTIA").3 The WRC will be held by the

International Telecommunication Union ("ITU") in November 2015 ("WRC-15"). The WAC

adopted a number of Recommendations for the Commission at its May 20, 2015 meeting on U.S.

Proposals for identifying more terrestrial mobile broadband spectrum under Agenda Item 1.1,

other Agenda Items, 4 and on future spectrum studies under Agenda Item 10 for WRC-19. 5

Agenda Item 1.1 is:

to consider additional spectrum allocations to the mobile service on a primary basis and identification of additional frequency bands for International Mobile Telecommunications (!MT) and related regulatory provisions, to facilitate the development of terrestrial mobile broadband applications, in accordance with Resolution 233.

The Commission notes in its public notice the differing Views in the Recommendations,

largely aligned within the mobile broadband industry and the fixed satellite industry, regarding

whether the U.S. should limit its position on changing international allocations to add mobile or

an identification for IMT to just our Region of the Americas, or whether it should propose ''No

Change" to the allocation tables for all three Regions.

T-Mobile supports the U.S. taking Positions that will lead to more spectrum allocated to

mobile broadband both home and abroad. Demand for mobile data continues to explode. Based

on mobile data growth to date, total traffic in 2019 is expected to be about 100 times greater than

3 Jd. 4 The majority of Agenda Items at WRC-15 address studies for additional allocations to satellite systems or other satellite regulatory matters. T-Mobile's comments will only address the Recommendations pertaining to key issues relating to terrestrial mobile broadband under Al I. I or Al I 0. 'Agendas for future WRCs are adopted at the end of the current WRC.

2

in 2010, when the world was preparing for the last WRC.6 In the last five years alone there have

been about a 20 times increase in mobile data growth, as measured in petabytes per month. 7

The United States has led the world in deployment of mobile broadband, with the highest

number of 40 connections in any Region.8 Policies implemented by the Commission under the

National Broadband Plan have contributed to the rapid roll-out of LTE in the U.S. To continue

U.S. leadership in mobile broadband, the Commission must continue to support a pipeline of

new spectrum, consistent with its goal of identifying 500 MHz of spectrum below 3. 7 GHz for

mobile broadband. One particular band of spectrum of interest to the mobile broadband industry

is 1300-1390 MHz, given its identification in the National Telecommunications and Information

Administration's (NTIA) Ten Year Plan and Timetable, Fast Track Evaluation and recent re-

prioritization in the Fourth Interim Report.9 Yet NTIA' s W AC/l 09 proposed Position would

threaten this band, as well as a possible path to IMT in 1427-1452 MHz. The Commission should

advocate for U.S. positions internationally that do not undermine possible consideration of these

bands domestically. The Commission should therefore support the View Bs of W AC/112-116,

and View A of W AC/118.

6 Cisco, Cisco Visual Networking Index: Forecast and Methodology, 2014-2019, White Paper Report (May 27 2015), avail able at http://www.cisco.com/c/en/us/solutions/service-provider/visual-networking-index-vn i/index.htrn I ("Cisco VNI Forecast and Methodology"). 7 ERICSSON, Ericsson Mobility Report: On the Pulse of the Networked Society (June 2015), available at http://www.ericsson.com/res/docs/20I5/ericsson-mobility-report-june-2015 .pdf. 8 See Press Release by 4G Americas, June 5, 2015, available at http://www.4gamericas.org/en/newsroom/press­releases/l q2015-lte-connections-worldwide-increase-150-percent. 9 U.S. DEPT. OF COMMERCE, Plan and Timetable to Make Available 500 Megahertz of Spectrum for Wireless Broadband (Oct. 20 I 0), http://www.ntia.doc.gov/files/ntia/publications/tenyearplan_ l l I 520 I 0.pdf; U.S. DEPT. OF COMMERCE, An Assessment of the Near-Term Viability of Accommodating Wireless Broadband Systems in the 1675-1710 MHz, 1755-1780 Miiz, 3500-3650 MHz, and 4200-4220 MHz, 4380-4400 MHz Bands (Oct. 2010), http://www.ntia.doc.gov/files/ntia/publications/fasttrackevaluation 111520 I O.pdf; and http://www.ntia.doc.gov/fi les/ntia/publications/fourth_interim _progress _report_ final. pdf

3

II. National Policy on Mobile Broadband

The National Broadband Plan established the goal of repurposing 500 MHz of spectrum

below 3. 7 GHz for mobile broadband, with 300 MHz by 2015.10 President Obama also called for

500 MHz of new spectrum for mobile broadband by 2020 in his Plan. 11 Despite a great deal of

focus and dedication by leaders across a number of agencies, the U.S. is behind that goal.

Working with its federal user partners, NTIA has been able to identify several bands of federal

spectrum for repurposing, including the 1755-1780 MHz band auctioned as A WS-3 last year and

the 3550-3700 MHz band for shared access. In his June 2013, the President issued another

spectrum memorandum, calling for renewed efforts to exam repurposing federal spectrum.12 In

his more recent memorandum, the President directed federal spectrum managers to work

cooperatively with the industry to explore ways to facilitate commercial access to spectrum.

Last year, NTIA reprioritized certain bands for study, including the 1300-1390 MHz and 2700-

2900 MHz bands. NTIA listed the 1370-1390 MHz band as a possible band for exclusive non-

federal use, and the 1300-1370 MHz band for possible sharing between federal users and non-

federal entities. And last month NTIA issued its Fifth Interim Report on its Ten-Year Plan and

Timetable which listed the 1300-1390 MHz band as one that NTIA was "investigating for

potential repurposing". 13

1° FCC, Connecting America: The National Broadband Plan (20 I 0), available at https://transition.fcc.gov/nationaJ­broadband-plan/national-broadband-plan.pdf. 11 THE WHITE HOUSE-OFFICE OF PRESS SECRETARY, Unleashing the Wireless Broadband Revolution, Presidential Memorandum (June 28, 2010). 12 THE U.S. WHITE HOUSE, Expanding America's Leadership in Wireless Innovation, Presidential Memorandum, Office of the Press Secretary, (June 14, 2013), available at https://www.whitehouse.gov/the-press­office/2013/06/ 14/presidential-memorandum-expanding-americas-leadership-wireless-innovatio 13 See U.S. DEPT. OF COMMERCE, Fifth lnLerim Progress Report on the Ten-Year Plan and Timetable, at Table B-1 (Apr. 2015), available at http://www.ntia.doc.gov/files/ntia/publications/ntia 5th interim progress report on ten­year timetable april 2015.pdf.

4

T-Mobile recognizes the impressive efforts of the Commission, the Defense Department,

NTIA and other agencies in repurposing the A WS-3 spectrum, and its continuing efforts to study

additional bands for repurposing, consistent with Presidential guidance. The bands NTIA

recently reprioritized to study for possible repurposing are now under discussion in the context of

U.S. proposals to the WRC. The U.S. government should not allow our Positions for the WRC

to undermine progress domestically on these bands. U.S. proposals that suggest to U.S. federal

spectrum managers a lack of continued prioritization of these bands for possible repurposing

would impede momentum on studies at home. The Commission should not support U.S.

proposed Positions for international Conferences that undermine our domestic policy goals.

III. WAC Recommendations 112-116

AI 1.1 invited the ITU-R to study bands for mobile allocation on a primary basis and possible

identification for International Mobile Telecommunications ("IMT"), to facilitate the

development of terrestrial mobile broadband applications. WAC Recommendations 112-116

address bands studied at the ITU-Rover the last several years for mobile. T-Mobile supports the

View Bs of each of those Recommendations, which appear to be more consistent with NTIA's

reprioritization of the 1300-1390 MHz and 2700-2900 MHz bands for study. The View Bs

would ensure that the U.S. does not undermine the development of terrestrial mobile broadband

in other parts of the world, while it continues to make progress in studies on repurposing

candidate bands at home. T-Mobile therefore urges the Commission to support the View Bs of

WAC/112-116.

A. WAC/112-1300-1400 MHz With respect to WAC/112, T-Mobile recognizes that currently, the 1300 - 1400 MHz band is

allocated to radiolocation services globally. However, T-Mobile notes that in Region I (EMEA)

5

and in the U.S., the upper sub-band, 1350-1400 MHz, currently has a co-primary allocation for

mobile. In the U.S., 1350-1390 MHz has a co-primary mobile allocation for federal use, and

efforts are underway to study whether through the transition to multi-function phased array radar

agency operations might be made more spectrally and operationally more efficient. The Federal

Aviation Administration (FAA) and the National Oceanographic and Atmospheric

Administration (NOAA) have sponsored studies to evaluate the feasibility of replacing existing

primary radar systems with phased array radars, including for air route surveillance radar

(ARSR) in the 1300-1390 MHz band.14

lfNTIA continues to make progress on repurposing the 1370-1390 MHz band for licensed

exclusive non-federal use, there is a path to possible global harmonization for mobile broadband

in that upper band of 1350-1400 MHz. Just this last year, NTIA reprioritized the majority of the

band for possible shared use in the lower portion of 1300-1370 MHz. T-Mobile therefore agrees

with View B ofWAC/112 to strike the language on the criticality of incwnbent operations, and

replace it with a reference to the Ten-Year Plan and Timetable's plan to study 1300-1390 MHz. 15

NTIA in its Second Interim Report on the Ten-Year Plan noted that "the PPSG listed the 1300-

1370 MHz band to study for sharing and the 1370-1390 MHz band for potential relocation.

14 FED. AVIATION ADM ., NextGen Surveillance and Weather Radar Capability: Multifanction Phased Array Radar (MPAR) Notional Functional Requirements Document, Ver. 2.2 (Apr. 18, 2013), available at http://www.ofcm.noaa.gov/wg-mpar/references/nswrc/MP AR %20NFR% 20ver2-2%20Final.pdf ("April 2013 NextGen Surveillance and Weather Radar Capability Document"). "No one disputes the critical nature of Aeronautical Mobile Telemetry ("AMT'') for safety in flight testing. T­

Mobile agrees that the band is critical for aerospace research and development and safety standards certification. However, in light of both domestic and international goals for efficient spectrum use, it is important to note AMT currently has 285 MHz of spectrum allocated across 1435-1525 MHz, 1780-1850 MHz, 2200-2290 MHz, and 2360-2390 MHz, all in the "beachfront" range below 3.7 GHz. As noted in its February 2014 comments in this proceeding, T-Mobile believes that given both the President's goals to repurpose 500 MHz of spectrum below 3.7

GHz to mobile broadband, and the National Broadband Plan's comparable goals, that the U.S. should continue to explore ways to share more of that critical spectrum.

6

Sharing the entire 90 megahertz across these two bands may achieve greater benefits; however,

there are differences in use of the 1300-1370 MHz and the 1370-1390 MHz bands that the PPSG

must take into account if they prioritize these two bands as one for the next band to study for

sharing."'6

As NTIA may have contemplated, the 1300 - 1370 MHz sub-band contains 70 MHz that

could be paired with the 70 MHz in 1780 - 1850 MHz for mobile broadband that NTIA and the

Department of Defense are studying for possible repurposing for shared commercial access. As

directed by the President, the industry and NTIA are currently studying new sharing technologies

for 1780-1850 MHz that might also prove useful in the 1300-1370 MHz band. Those paired 70

MHz bands could be used toward the full 500 MHz target. The 1370 - 1390 MHz could

potentially be repurposed for exclusive licensed broadband.

T-Mobile therefore agrees with W AC/112 View B that the U.S. should not propose No

Change to the international Table of Allocations in all three Regions, across the entire 1300-1400

MHz band. The current state of domestic study may inhibit the U.S. from stating in the sum.mer

of2015 that it supports identification in the upper 1350-1400 MHz, but the U.S. should make no

proposal regarding that upper sub-band in other regions. T-Mobile agrees with View B

proponents that any No Change proposal for all three Regions should be limited to the lower

1300-1350 MHz band, which NTIA and its federal partners are studying for shared access, which

also includes the study of consolidating L, S and C band radars to a Next Generation (NEXGEN)

Multi-phased Array Radar platform to reside within a common band.17

16 U.S. DEPT. or COMMERCE Second Interim Progress Report on the Ten-Year Plan and Timetable, at 8-9, Table 2-3 (Oct. 2011 ), available at www.ntia.doc.gov/files/ntia/second interim progress report on the ten year plan and timetable.pdf. 17 April 2013 NextGen Surveillance and Weather Radar Capability Document.

7

T-Mobile also agrees with proponents of View B, as raised in WAC/112, that the ITU-R

should not be the entity that decides the "practicality" of mitigation techniques. The practicality

of providing a viable service while complying with incumbents' protection criteria should be left

to industry to decide, since that is an economic decision involving supply chain, pricing and

other market issues. The ITU-R does not have the competency to make a decision on the

practicality of mitigation techniques. ITU-R Working Parties may have the requisite expertise to

determine protection criteria for services within their assigned services. But as a body, these

largely government representatives have no operational experience in running networks, or

developing mitigation technology. Like the U.S. government, the ITU-R has begun to study

sharing scenarios at a greater frequency, given the increasing global demand for mobile

broadband. But it doesn't follow that the ITU-R should be the entity to determine the practicality

of mitigation techniques employed by mobile broadband providers. T-Mobile urges the

Commission to oppose that precedent in W AC/112 and other such attempts for the ITU-R to

expand beyond its competency, particularly when that precedent is inconsistent with the

Commission's rules and practice.

B. WAC/113 -1375-1400 MHz and 1427-1452 MHz T-Mobile also agrees with View B ofWAC/113. In contrast, View A ofWAC/113, and

WAC/109, would potentiaJly foreclose any opportunity for IMT in the future in both 1370-1390

MHz, and in 1427-1452 MHz, a band which is of interest to providers of mobile broadband in

other markets. View A is inconsistent with the repriorization of 1370-1390 MHz as a band to be

studied for possible exclusive licensed non-federal use. Mixed signals would be sent both to

domestic and international spectrum mangers if the U.S. now supported a global, mandatory and

more stringent mask on IMT in that band.

8

At issue in W AC/113 and W AC/109 is whether the U.S. should propose changes to ITU-R

Resolution 750 ("RES750-1 ") to add mandatory limits on unwanted emissions on IMT in the

1427-1452 MHz band. RES750-1 provides mandatory emission limits on services in bands

adjacent to passive EESS in Table 1-1 and recommended emission limits in Table 1-2. T-Mobile

agrees with View B proponents that the U.S. should not propose changes to RES750-1 that

would close the door on possible IMT in either 1370-1390 MHz or in 1427-1452 MHz. Such a

Position would be inconsistent with national spectrum policy and with the Commission's rules.

Any changes to add OOBE limits for IMT mobile in the 1427-1452 MHz band should be

consistent with the FCC's out-of-band emission rules, which provide a- 58.7 dBW/27 MHz

mask to protect incumbents. 18 The U.S. should not support the more stringent ITU-R Report

RS.2336 limits. RS.2336 would require for IMT base stations an OOBE limit of-75 dBW/27

MHz in the case of only one of the 1375-1400 MHz or 1427-1452 MHz bands being used for

IMT, and-80 dBW/27 MHz in the case of both I 375-1400 MHz and 1427-1452 MHz bands

being used for IMT simultaneously. In addition, RS.2336 would require a -65 dBW/27 MHz for

IMT user equipment. RS.2336 was developed without regard to the advances made in L TE and

newer sharing technologies. The Commission should insist that any U.S. proposal should be

based on more realistic L TE parameters, in order to keep the door open for L TE in both possible

bands- 1370-1390 MHz and 1427-1452 MHz.

As a matter of policy and practice, the U.S. should not support mandatory international

rules that are inconsistent with the U.S. regulator's OOBE rules. That would serve as an

18 Part I 5.209(a) of the Commission Rules provides that emissions from an intentional radiator shall not exceed the field strength of 500 microvolts/m measured at 3 m for the bands above 960 MHz. That limit can be stated as -43 dBm/MHz, or -58.7 dBW/27 MHz. A mask of-58.7 dBW/27 MHz is close to the current recommended mask for mobile in Table 1-2 for mobile in both the lower band of 1350-1400 MHz and the upper band of 1427-1452 MHz. A mask of -58 dBW/27 MHz is close to the ECC draft European Common Proposal ofa mask of-60 dBW/27 MHz.

9

unfortunate precedent were the U.S. ever in a position to allow LTE in the 1427-1452 MHz

band, the 1370 - 1390 MHz band, or in other bands not currently allocated for mobile that are

adjacent to passive EESS. Moreover, asserting a more stringent OOBE requirement would

require larger, possibly unnecessary guard bands and therefore foreclose access to larger

amounts of spectrum that are necessary to support more robust bandwidth requirements

associated with LTE Advanced and future 5G technologies. Such a move would not only limit

the utility of adjacent spectrum bands, but would also suppress the billions of dollars that would

otherwise materialize at future auctions - thereby depressing revenue available to the U.S.

Treasury and ultimately depriving American consumers access to much needed spectrum. While

T-Mobile appreciates that the U.S. cannot at this time allocate portions of the 1370-1390 and

1427-1452 MHz bands to commercial mobile, it advises the Commission to argue for letting the

engineering studies in the U.S. run their course, without closing a door internationally.

C. W AC/114 on 2700-2900 MHz T-Mobile also supports View B of W AC/114 on the 2700-2900 MHz band. As noted above,

several federal agencies are involved in an effort to update radar technology to achieve more

efficient operations. In addition to the ARSR radar discussed above, the FAA and NOAA have

sponsored "next generation" studies to evaluate the feasibility of replacing additional existing

primary radar systems for weather and airport traffic with phased array radars. These legacy

radars were developed by different agencies, and deployed at different times in different

locations for different purposes. Many public benefits may be realized if a new radar system

could be designed to take over the missions of the legacy radars, and reduce their extensive

overlapping spectrum use. Reducing the total number of radars needed for national surveillance,

while introducing a common radar system design that would simplify logistics and maintenance,

has the potential to significantly reduce life cycle costs. This can be a realized benefit for the

10

FAA in the terminal domain, and across both terminal and en route airspace should a federal

enterprise solution be developed.

One option for such upgrading legacy radars is to move newer phased-array multi-purpose

radar into the 2700 - 2900 MHz frequency band, allocated for aeronautical radio navigation.

Since that could potentially fre.e up a portion of the 1300-1390 MHz band, specifically the 1350-

1390 MHz band for mobile allocation in the U.S., T-Mobile is supportive of treating the 2700-

2900 MHz band in the U.S. as a primary band for national surveillance. But until legacy radar

systems are upgraded and moved to free up 1300-1390 MHz, T-Mobile prefers not to take the

2700-2900 MHz band off the "reprioritized" table for possible commercial access. Therefore, T­

Mobile agrees the better course- as outlined in View B of WAC/114- is for the U.S. to limit its

position of No Change to Region 2, with an affirmative statement that the U.S. makes no

proposal regarding other Regions.

IV. No Changes Limited to our Country or as necessary, our Region

As discussed above, T-Mobile agrees with the approach of the View Bs in WAC/112-116 to

limit the appearance of U.S. opposition to IMT identification, in light of the Commission's and

President's policy pronouncements to find 500 MHz of spectrum to repurpose for mobile

broadband.

Due to technology innovation in broadband, and the transparency of the U.S. government,

the whole world is aware of U.S. leadership on mobile spectrum policy. To be consistent in our

domestic and international policymaking, it is appropriate for the U.S. not to propose a No

Change in other Regions. Were the U.S. to propose No Change in all three Regions, the pace of

repurposing spectrum in those bands would be slowed not just in the U.S., and our Region, but in

other Regions as well. Given the slow pace of spectrum repurposing, especially in other Regions

ll

that have not experienced U.S. leadership, U.S. consumers will benefit from repurposing in other

Regions beginning from WRC-15. As the Commission knows, it takes years to re-allocate and

re-assign spectrum. Certainly it takes more than the four years consumed by a WRC cycle. By

the time the U.S. is ready to re-purpose the studied bands domestically, other markets may still

be engaged in the arduous process of repurposing the same bands. U.S. consumers will benefit

from the commencement from WRC-15 in November of the development of a scale eco-system

in other Regions. Not only do U.S. consumers roam to other markets as tourists, family

members, and business people, but they are participants in a global ecosystem.

The U.S. government has made tremendous strides on re-purposing spectrum. A U.S.

proposal for No Change in all three Regions, absent a compelling demonstration of harm, is

inconsistent with U.S. global leadership on spectrum policy ..

V. Agenda Item 10

Because current WRCs set the Agenda for future WRCs, WRC-15 Agenda Item I 0 provides:

to recommend to the Council. items/or inclusion in the agenda/or the next WRC, and

to give its views on the preliminary agenda/or the subsequent conference and on possible agenda items for future conferences, taking into account Resolution 806

(WRC-07).

In W AC/118, View A, the mobile industry proposes to study during the cycle leading to

WRC-19 spectrum above 6 GHz for IMT. T-Mobile supports View A of W AC/118. The fifth

generation of mobile broadband applications, "5G", will require a range of spectrum, including

both microwave spectrum from 6-30 GHz and millimeter wavelength spectrum above 30 GHz

for high-capacity, short distance links. The 5G standards-setting is not yet complete. The mobile

12

industry has announced that it expects to standardize and begin to deploy SG in the year 2020. 19

The business case for certain 5G applications should drive the studies - not arbitrary limits on

bands. View B of W AC/118 proposes to limit the bands as a threshold matter, which would be

premature before the business applications are developed. Drivers of SG are expected to include

the Internet of Things, particularly connected cars, wearables and Smart Cities,20 but these

applications are still under development. To identify the bands before the drivers would be the

proverbially tail wagging the dog.

Fixed satellite providers in View B propose that during the study cycle leading to WRC-

19, the mobile industry study how much spectrum is needed for SG. An entire WRC cycle is not

necessary given a large amount of information on global mobile data growth.21 View B

advocates for a second four-year cycle leading to WRC-23 to study specific bands. Delaying the

development of scale economies for SG by action at the next WRC would undermining U.S.

leadership in a technology industry will deploy around 2020. Studying bands during the first

cycle leading to WRC-19 is more consistent with the National Broadband Plan to identify 500

MHz for mobile broadband by 2020.

T-Mobile also agrees with View A proponents that Resolution 233 should not be

suppressed until the final results of WRC-15 are determined. Suppression before the end of the

year could slow down the NTIA's continued study of bands identified in its Ten-Year Plan and

19 See, e.g., W AC/118, View A, referencing the Report ITU-R M.2320, which provides information on the technology trends of terrestrial IMT systems considering the time frame 2015-2020 and beyond, and Preliminary Draft New Recommendation ITU-R M.[IMT.VISION], which describes the framework and overall objectives of the future development of !MT for 2020 and beyond. 20 See 4G Americas White Paper on Recommendations on 5G Requirements and Solutions at Section 2.1, available at www.4GAmericas.org. T-Mobile's CTO serves as the Chair of 40 Americas. 21 See Cisco, Cisco Visual Networking Index: Forecast and Methodology, 2014- 2019, White Paper Report (May 27 2015 ), available at http://www.cisco.com/c/en/us/sol utions/service-provider/visual-networking· index-vni/index.htm 1 ("Cisco VNI Forecast and Methodology").

13

Timetable and Interim Reports, and would therefore be another example of international

positions undermining progress in U.S. domestic spectrum policy.

VI. Conclusion

T-Mobile thanks the Commission for requesting public comment on the WAC

Recommendations and the NTIA draft proposals. With respect to W AC/ 112-116 under

Agenda Item 1.1, T-Mobile advises the Commission to support the View Bs of

Recommendations presented to the May 20th WAC. With respect to Agenda Item 10, T-

Mobile advises the Commission to support View A of WAC/118. The Commission's leaders

were prescient in the National Broadband Plan in its realization of the growing need of

spectrum for flexible mobile use. The United States, in its international proposals, should do

nothing to slow the pace ofrepurposing spectrum domestically, nor indeed globally, given

the benefits to the United States and its citizens of having a global, competitive broadband

ecosystem. The U.S. should not propose No Change to allocations in other Regions that

could contribute to the growth of that ecosystem. With respect to a future agenda item to

study IMT in 6 GHz and above, that proposal is crucial to continued U.S. leadership on 50.

Respectfully submitted,

/s Steve Shark' Chief, Engineering and Technology Policy, Federal Regulatory John E. Hunter Director, Spectrum Policy T-Mobile USA

14

N 0 -VI