The Need for a Robust National Spectrum Strategy

Hi, my name is Mike Dienhart. I am the vice president of engineering and operations at UScellular. I’ve been at UScellular for 20 years, and in the wireless industry for 28 years. Thank you for allowing me to speak here today.

Just last week we celebrated the 50^th anniversary of the first cellular phone call. Since Martin Cooper’s call, wireless technology has become foundational to our national security and economic prosperity.

But the benefits of wireless have not been delivered equally.

UScellular’s mission is to connect our customers to the people who matter most to them, and we do this primarily in rural and underserved markets. I expect most of us either drove through or flew over the types of markets that we serve in order to speak here today. Connecting the unconnected is in our DNA as a company, from its inception in 1983 by our visionary founder Roy Carlson.

Our recommendations today are informed by our continued focus on bringing all the promises of wireless technology to the traditionally unserved and underserved.

A National Spectrum Strategy (NSS) must be both ambitious and deliverable for the U.S. to catch up to China’s spectrum and technology plans. As others have noted today and in the earlier listening session, the U.S. lags far behind in allocating licensed mid-band spectrum for mobile use, and experts expect the U.S. to fall behind in licensed spectrum in the low- and high-bands within the next few years. Losing the leadership position in wireless is unacceptable and is avoidable through an aggressive spectrum pipeline geared towards the proven highest benefit uses. Spectrum is a public good, owned by taxpayers, and the FCC and NTIA have proven capable and trusted stewards of this public good.

The National Spectrum Strategy will identify new spectrum allocations, and we agree with other commenters that 1500MHz represents a good start – but much more will be required to keep pace with other nations and with our own domestic demand. In your strategy deliberations we recommend exclusive, licensed, full power use to realize the maximum public good.

Dedicated licensed spectrum has proven to be the best and highest use of our nation’s spectrum resources, contributing nearly $1 trillion annually to our economy. Dedicated licensed spectrum benefits from high spectral efficiency, and it enables the delivery of the deterministic and consistent experience needed for the development and adoption of future use cases.

Power matters, especially when bringing wireless to the unserved and underserved, and when enabling productivity-enhancing applications throughout rural America. This is an important point – the more rural the user, the more critical it is to have full power. Anything less degrades the customer experience and creates prohibitive economics for universal connectivity. Power limitations deepen the digital divide.

One measure reflecting the differentiated value of dedicated licensed spectrum is the value that markets place on it – for example, comparing the recent C-Band auction which raised just under $1/MHz pop with the CBRS auction raising about one quarter of that amount. Unlicensed spectrum users, by contrast, do not contribute to the U.S. Treasury for the spectrum assets they benefit from.

Shared spectrum does have a place in wireless, and we support static, well-defined, full power, shared spectrum licensing as a complement to dedicated licensed spectrum.

Dynamic sharing schemes, however, create complexity that limits adoption and investment, and potentially leaves valuable spectrum underutilized – in stark contrast to its purported benefit. This is not a theoretical argument, but a very real and practical issue especially in unserved and underserved areas of our country. A cell site equipped with CBRS will provide a usable connection to approximately a 1.5km radius. In contrast, a similarly designed site using C-Band will provide customer benefit up to a distance of 9km. That’s six times the distance, and over 40 times the area covered by using full power spectrum. There can be no question that additional dynamic shared spectrum, with the attendant power compromises, will not deliver the National Spectrum Strategy benefits that our country demands.  

Unlicensed spectrum also has a place in wireless, for best effort services with lower requirements for latency, speed and full mobility. These needs are well satisfied through existing spectrum allocations for unlicensed use. And, notably, many advocates of unlicensed spectrum have pockets deep enough to purchase licensed spectrum if needed to deliver their services.

To be clear, dedicated licensed spectrum enables the greatest benefits for the most people. Universal connectivity should be the goal, with special focus on leveraging fixed wireless solutions to bridge the digital divide.

Developing innovative technologies and delivering the promise of wireless technology throughout the U.S. requires massive investment. Dedicated licensed spectrum provides the long-term certainty needed for markets to invest tens of billions annually developing scale needed to provide service in all markets. Dedicated licensed spectrum provides companies – ranging from wireless carriers like us to auto and airplane manufacturers with decade-long product development cycles – with the certainty to commit their business models to nascent technologies.

Beyond spectrum, American leadership in wireless technology depends on a number of other policy, regulatory and economic factors. The National Spectrum Strategy must also consider infrastructure challenges, inadequate research and development funding, the need for healthy friendly industry partners and suppliers, the benefits of friend-shoring of research and manufacturing, and other related issues.

This administration and Congress have made a significant down payment on connecting the U.S. with the $42 billion BEAD program. Yet this will not ensure all Americans are covered with wireless technology or connected to broadband. NTIA should build on the BEAD foundation to fully close the digital divide.

The time is ripe to build our digital future, with universal connectivity ensuring America’s economic prosperity, global competitiveness, and national security.

Thank you for the work you’ve done so far, your inclusion of so many stakeholders – including UScellular – in this process, and the hard work you have yet to do before issuing the strategy later this year.

Please consider UScellular as a partner in this process.