T-Mobile, one of the more aggressive in terms of wanting to use unlicensed spectrum to improve services for its customers, is urging the FCC to make more spectrum available for licensed use as part of its rules for spectrum bands above 24 GHz.

T-Mobile acknowledges that it is a significant user of unlicensed spectrum and has been a pioneer in how network operators use Wi-Fi, but it still wants to see more spectrum available for licensed purposes. T-Mobile was the first carrier to introduce calling over Wi-Fi in 2007 with its HotSpot @Home and has made a point to make sure all new smartphones in T-Mobile stores are capable of Wi-Fi calling and texting.

But T-Mobile argues that the FCC’s current plan is heavily weighted in favor of making unlicensed spectrum available at the expense of licensed use. Of the 10.85 gigahertz of millimeter wave spectrum being made available, only 3.25 gigahertz was made available for licensed use on an exclusive basis. “While spectrum for both licensed and unlicensed uses is important, the disparity here is stark,” the operator said in its Dec. 14 filing. “Moreover, only a small amount of the 3.25 gigahertz of spectrum designated for exclusive licensed use will actually be auctioned, as most is already licensed to incumbent entities. Thus, potential service providers that wish to use licensed spectrum received limited potential benefit from the Report and Order.”

Sponsored by Southco Inc. How To Secure 5G Equipment With Electronic Access Learn how to protect small cell enclosures from physical threats and deliver better, stronger and more reliable networks with electronic locks and access control systems. Read the Article

Licensed spectrum is the “foundation of today’s robust mobile wireless ecosystem, driving investment, innovation, and competition,” T-Mobile said. “Investment by wireless carriers in licensed spectrum has made America the world’s wireless industry leader, facilitated the creation of networks capable of supporting greater speeds and functionalities, and led to new, more powerful and sophisticated devices. Licensed spectrum is also a critical driver of the Nation’s economy – for instance, every 10 megahertz of spectrum made available adds $3 billion to the US. Gross Domestic Product and supports approximately 202,000 new jobs.”

T-Mobile also has been a proponent of using LTE in unlicensed spectrum bands, through the introduction of LTE-U, to ultimately improve services for end users. But its desire for more licensed spectrum is nothing new given U.S. operators’ collective history of citing a spectrum crunch and wanting more spectrum.

Regarding the 5G proceeding, T-Mobile also said the commission was too quick to dismiss the possibilities for licensed mobile operations in the 64-71 GHz band despite there being increasing evidence of the band’s potential. A Nokia study released in December 2015, for instance, shows that 5G mobile services are possible in these higher frequencies, and a recent study by NYU Wireless demonstrates that “remarkable distances that can be achieved using millimeter wave communications, and presents a new rural macrocell (RMa) path loss model for millimeter wave frequencies, based on measurements at 73 GHz.” Such studies show the 64-71 GHz band has value for licensed mobile services and could lead to even greater 5G investment, the carrier said.