September 23, 2020

VIA ELECTRONIC FILING

Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554

Re: Ex Parte Presentation, WT Docket No. 19-348

Dear Ms. Dortch:

Back in January of this year, we urged the Commission to make 2020 the “Year of Mid- Band”1—and this year, the FCC has indeed taken remarkable action in mid-band spectrum and in particular, in the vital 3 GHz band. Next week, the Commission can complete its third of three critical 3 GHz band achievements with adoption of the 3.45-3.55 GHz Report and Order and Further Notice,2 following the 3.5 GHz CBRS auction this summer and the C-Band Order and announcement of the December 8 C-Band auction date. We commend the Commission for the upcoming vote and urge the U.S. Government to take rapid, decisive action to clear spectrum in this 100-megahertz swath in the near term and across the lower 3 GHz band (3.1-3.55 GHz) for commercial licensed spectrum.

Quick delivery of exclusive use, commercial licensed mid-band spectrum is critical to fueling our transition to a new, economy. As the Commission knows well, mid-band spectrum provides an ideal mix of coverage and capacity to advance 5G as a break-through enabler of innovation. And the 3 GHz band is of particular importance: nations across the globe are assigning large portions of 3 GHz spectrum for exclusive use 5G licensing, and FCC action to

1 See, e.g., Letter from Scott K. Bergmann, CTIA, to Marlene H. Dortch, CTIA, GN Docket 18-122 et al. (filed Jan. 31, 2020) (reporting on a meeting between CTIA President & CEO Meredith Attwell Baker and FCC Chairman ). 2 See Facilitating Shared Use in the 3100-3550 MHz Band, Draft Report and Order and Further Notice of Proposed Rulemaking, FCC-CIRC2009-01, WT Docket No. 19-348 (draft rel. Sep. 9, 2020).

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harmonize our mid-band spectrum in the same frequency range will allow U.S. deployments to benefit from economies of scale in 5G network infrastructure and devices, helping to deliver more 5G across America.

CTIA applauds the FCC for its actions this year, which have established a clear path for auctions totaling 350 megahertz of 3 GHz spectrum. The C-Band auction that launches in just 10 weeks will unleash 280 megahertz of exclusive use spectrum from 3.7-3.98 GHz for 5G deployments. Plans for the transition are well underway and it’s imperative for America’s leadership in the 5G economy that we stick to the C-Band Order’s timeline. And the CBRS auction that closed last month will deliver 70 megahertz of licensed 3.5 GHz spectrum across the nation.

The wireless industry commends the FCC, White House, and Department of Defense for recognizing that additional full-power spectrum would be needed for 5G to keep pace with our global rivals. The plan to quickly auction and provide access to 100 megahertz of additional mid-band spectrum for full-power 5G services is critical and timely. This winning formula helped us lead in 4G and will help unlock the 5G economy here in the United States. To ensure our continued leadership and our future global competitiveness, the United States should now seek to replicate this successful process for the lower 3 GHz (3.1-3.45 GHz) to maximize the amount of spectrum available for auction while safeguarding mission critical federal government services. In doing so, the United States should reject untested and radical approaches to spectrum management, particularly for spectrum as critically important as mid- band spectrum.

The FCC should be rightly congratulated on its impressive record of 3 GHz accomplishments in 2020. Now let’s not let up. Next week’s action is an important step for gaining access to the 3.45-3.55 GHz band for 5G, and we should ensure that happens quickly. With these actions, American consumers and the U.S. economy will reap the benefits that 5G promises—job creation, economic growth, the promise of smart cities, and improvements in public safety, health care, our environment, and much, much more.

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Pursuant to Section 1.1206 of the Commission’s rules, this notice is being filed in ECFS. Please do not hesitate to contact the undersigned with any questions.

Sincerely,

Meredith Attwell Baker President & CEO

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