Agreeing with many industry stakeholders, including Google and Microsoft, ACA said that FCC action was needed because the 2.4 GHz band - which has just 83.5 MHz of Wi-Fi dedicated spectrum - is rapidly reaching a state of exhaustion. The 2.4 GHz band is also insufficient because hitting 1 Gbps speeds requires access to 160 MHz contiguous channels, a template which has been developed specifically for use in the 5 GHz band under the IEEE's 802.11ac standard.
ACA said the 5 GHz band provides the best opportunity for provisioning significant additional spectrum for unlicensed use. The 5 GHz band can accommodate the 802.11ac standard, and because devices are already on the market, this new spectrum can be rapidly accessed.
"It is clear that by providing additional spectrum for higher speed service, we can open new opportunities for innovation and economic growth," Polka said.
ACA said allocating two bands -- the 5.35-5.47 GHz band for U-NII-2B and the 5.85-5.925 GHz band for U-NII-4 -- would provide potentially 195 MHz of new spectrum for unlicensed use and in combination with the other rules changes, would more than triple the amount of usable unlicensed spectrum in the 5 GHz band and permit use of 160 MHz contiguous channels for 1 Gbps transmissions.
ACA said it supported harmonizing rules for unlicensed use in the U-NII-1 band (5.150-5.250 GHz) with the existing rules for unlicensed use of the U-NII-3 band (5.725-5.850 GHz) by adopting for the U-NII-1 band a maximum transit power limit of 1 W and eliminating the band's restriction preventing outdoor use.
The U-NII-1 band currently restricts unlicensed use in two key ways: imposing a low (50 mW) power limit and permitting only indoor use. As a consequence, cable companies do not use this portion of the 5 GHz band. ACA agreed with the FCC's conclusion that harmonizing the power and use conditions across the lower 200 megahertz of U-NII spectrum would likely permit the introduction of a wide-range of new broadband products capable of operating at higher data rates than is now possible.
"Cable operators throughout the country are continuously responding to consumer demands for faster broadband service. We cannot permit the benefits that come from these increased wireline speeds to be nullified by congested Wi-Fi service," Polka said.
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