As indicated in the initial comments filed by PISC in this proceeding, PISC supports the
Commission’s initiation of this inquiry as the first step toward fulfilling two recommendations in
the National Broadband Plan “to accelerate the development of opportunistic use technologies
and to expand access to additional spectrum.” The comments filed to date evidence widespread
agreement that dynamic spectrum access (DSA) technologies have tremendous potential to
promote greater spectrum access, capacity, and efficiency in both licensed and unlicensed bands.

There is a strong consensus among the comments filed in favor of building on the TV white
spaces geolocation database in particular as a means to enable the productive use of unused or
underutilized spectrum, based on band-by-band conditions that would ensure no harmful
interference to primary licensees. The combination of a transparent, real-time database and
spectrum sensing is noted in several comments as a particularly powerful means to protect
primary users while making unused spectrum capacity available for flexible, shared use. PISC
concurs with other comments suggesting that certain underutilized bands that are spectrally
proximate to existing unlicensed bands make particularly promising candidates for consideration as capacity to open for DSA, even if only in certain areas of the country, subject to band-by-band
conditions. Finally, PISC addresses the concerns expressed in comments filed by a number of
industry associations and individual companies, suggesting that involuntary and/or uncoordinated
access to unused spectrum capacity in licensed bands where some of these companies operate
would cause severe interference and generally be counterproductive. While PISC agrees that
CMRS bands are among the most intensively and efficiently used – and generate enormous
economic and social value – it is also important to make a distinction between licensed spectrum
that is being used to serve the public interest and licensed spectrum that lies fallow.

The comments are available for download on the right.