Before the


Department of Commerce

1401 Constitution Avenue, NW

Washington, D.C.


RE: Docket No. 011109273-1263-01

RIN 0660-XX13

ACTION: Request for Comments on Deployment of Broadband Networks and Advanced Telecommunications Services



ArrayComm, Inc. (ArrayComm) respectfully submits these brief comments in response to the above-referenced Notice of the National Telecommunications and Information Administration (NTIA). ArrayComm is encouraged by the NTIA’s inclusion wireless and mobile networks and services within its study of the deployment of broadband networks and advanced telecommunications services. NTIA has long championed the development and broad availability of broadband services in this country. This freshening of the broadband debate is welcome and timely. ArrayComm’s contribution to this debate will focus on the impediments to the development of wireless broadband networks and services.


Among the questions posed in the Notice is the following:

What problems have companies experienced in deploying broadband services via wireless and satellite? Is available spectrum adequate? What additional spectrum allocations, if any, are needed?

This question anticipates the almost obvious answer: the most immediate barrier to wireless broadband deployment in the lack of available spectrum. ArrayComm has made this case before the FCC in that agency’s Third Generation Wireless Systems or 3G rulemaking. For small companies like ArrayComm, and especially companies focused on the provision of spectrally efficient and affordable wireless data services based on TDD technologies, the availability of unpaired spectrum bands is crucial.

The current domestic approach to spectrum allocation has focused primarily on new spectrum for voice services. For instance in the 3G rulemaking, the FCC’s reallocation proposals are largely restricted to a variety of reallocation options based on pairing options for services based on Frequency Division Duplex (or FDD) technologies. FDD proponents expect to provide some data capability as part of their 3G service offerings. However, ArrayComm maintains that truly robust and affordable wireless data services would best be provided over unpaired spectrum bands utilizing TDD technologies.

For instance, with its i-BURST™ product, ArrayComm has demonstrated that the use of TDD technologies in conjunction with highly sophisticated spatial processing can deliver communications at data rates far in excess of that provided by today’s FDD systems, as well as that which FDD proponents predict for their 3G offerings. Furthermore, because TDD uses the same channel to transmit and receive, it can provide such wireless data solutions with remarkable spectrum efficiency and at significantly lower cost.

ArrayComm believes the FCC is sympathetic to this message. In the currently pending Government Transfer Bands proceeding, the FCC is expected to allocate several bands of unpaired spectrum. One of those bands, the 1670-1675 MHz band, is suitable for ArrayComm’s i-BURST™ product. Likewise, in its recent adoption of service rules for the lower 700 MHz band (Channels 52-59), the FCC allocated two contiguous 6 MHz bands of unpaired spectrum, which someday could be utilized for TDD-based data applications. Although this amount of spectrum is not sufficient to meet the growing demand for high-speed wireless Internet access and data services, it at least appears that the FCC acknowledges that the totality of wireless growth cannot be met by technologies designed primarily for voice services.

Acknowledgement of this fact raises the second, related impediment to wireless broadband: adoption of technology neutral spectrum policies. This second point should not be perceived as a criticism. It is more a reminder that technology neutrality is a long-held principal of federal regulators. However, in the rush to find new spectrum for voice service, the current dominant application for which spectrum is employed, the spectrum needs of developing services, namely wireless data, have been overshadowed. Notwithstanding the FCC’s efforts to acknowledge the wireless data field, more attention must be paid to this area. This is not to say that wireless data services will someday surpass the capacity and subscriber levels of wired data services or the subscriber level of wireless voice services. However, as data needs grow and as the need to access data rich information on the go, the spectrum necessary to make such access a reality must be made available.


For these foregoing reasons, ArrayComm urges NTIA to encourage the allocation of more spectrum on an unpaired basis and to use its policy expertise to highlight and strengthen the need for even-handed, technology neutral spectrum policies. Federal regulators and policy makers must not allow themselves to select specific technologies, such as FDD, to the exclusion of others based merely on the legacy of such technologies as today’s prevailing mode of providing mobile wireless services. FDD will be useful for some Advanced Mobile Service applications, but other technologies, such as TDD, will be superior in other instances. The marketplace is proving this to be true on a daily basis.

ArrayComm is pleased to submit these brief comments, and hopes to have an opportunity at a later date to expand on the matters discussed in this filing.

Respectfully submitted,



Bradley P. Holmes

Senior Vice President

Regulatory & Government Affairs



Randall S. Coleman

Vice President, Regulatory Affairs

888 16th Street, N.W., Suite 700

Washington, DC 20006

(202) 835-1925