NTIA, on behalf of the Executive Branch and consistent with its responsibility to ensure that the views of the Executive Branch are effectively presented to the Commission, provides these comments in response to the Notice of Inquiry (NOI). There are a variety of federal uses of 12.7-13.25 GHz and adjacent bands, as well as commercial uses that are important to federal missions. NTIA, therefore, is concerned about the potential for harmful in-band and adjacent-band interference if the 12.7-13.25 GHz band (12.7 GHz band) is repurposed as contemplated in the NOI. This concern is based upon both input from federal agencies that regularly operate in these bands and NTIA’s own preliminary assessment. Accordingly, before the Commission reaches conclusions here, additional technical analysis is necessary to evaluate the effects of repurposing this spectrum and to understand whether such effects can be mitigated (taking into account the costs and required resources for such mitigation).
GN Docket No. 22-352