The Enterprise Wireless Alliance (EWA) filed comments yesterday in response to National Telecommunications and Information Administration’s (“NTIA”) National Spectrum Strategy (“NSS”) as mandated by the Presidential Memorandum entitled “Modernizing United States Spectrum Policy and Establishing a National Spectrum Strategy. EWA noted in our remarks that the development of an NSS provides an opportunity for addressing the importance of spectrum used by enterprise entities that support the public’s welfare.  

While appreciating the value of commercial networks and accessible Wi-Fi for both consumers and businesses, the NSS should nevertheless pursue a balance between those interests and the spectrum requirements of business enterprises.  Commercial, shared, and unlicensed spectrum all have a place in the wireless inventory, yet they do not always allow private entities to design and operate systems with the coverage, security, reliability, resiliency, and operating features that support their contributions to the American economy.

For these reasons, EWA welcomed “the development of an NSS framework and expects to be an ongoing contributor to what NTIA has described as a near-term and longer-term undertaking.”

The NSS also identified several bands to be studied for wireless broadband use on a licensed and/or unlicensed basis, including the 7 GHz band (7125-8400 MHz). EWA recommended that at least a portion of the 7 GHz band be considered for licensed fixed wireless use by non-Federal entities, including enterprise licensees, given the rules adopted by the FCC with respect to incumbent 6 GHz operations.