Being in “the middle” has historically gotten a bad rap. There’s the underappreciated “middle child,” and of course no one wants to be the unneeded “middle man.” This concept has even proven true with the Commission’s wireless spectrum policies. While the FCC has made it a priority to promote industry access to wireless spectrum, these policies have largely focused on the bands below 3.7 GHz and above 24 GHz, leaving those in between crying “Marcia, Marcia, Marcia!

The Commission finally seems poised to show some love to the “middle man” after years of promoting flexible access to the clowns to the left and the jokers to the right. The Commission released a Notice of Inquiry that seeks comment on potential opportunities for wireless broadband in spectrum bands between 3.7 and 24 GHz.

This particular NOI, however, represents a “wait and see” approach more than anything. The Commission will only be seeking comment on three specific bands: 3.7-4.2 GHz, 5.925-6.425 GHz, and 6.425-7.125 GHz. Importantly, these three bands are allocated for exclusive non-federal use and 3.7-4.2 GHz has already garnered interest from industry stakeholders for expanding wireless broadband, while the two upper bands are targets for possible unlicensed devices. By seeking comment on potential uses for just these three bands, the Commission is testing the waters and gauging interest, in hopes that commenters will identify other bands that might also be suitable for expanding wireless broadband.

Mid-band spectrum is currently used predominantly for satellite, point-to-point links, and radar, which begs the question: does middle-band spectrum actually have potential for expanding wireless broadband, a goal Chairman Pai touts often, or is it destined to the same fate as all the other “middles”? Commissioner O’Rielly believes that the answer is the former, going so far as to publish a blog post setting forth his vision for the allegedly-underutilized bands, which he claims will be essential for meeting “the insatiable growth of wireless services.”

But before declaring mid-band spectrum the answer to our “insatiable” wireless appetites, the Commission needs to resolve key obstacles that have likely been the cause of the mid-band’s having been overlooked for expansion. The NOI seeks to do just that. For starters, the Commission will need to coordinate sharing federal spectrum with NTIA for many of the bands between 3.7-24 GHz. The Commission will also need to be cautious about disrupting existing and future operations in the Fixed Satellite Service and the Fixed Service, which operates about 95,000 links in the three bands identified for investigation. Many of these serve safety of life and property, and cannot readily relocate to other frequencies; and the Fixed Satellite Service’s thousands of earth stations would be expensive to convert.

The Commission will attempt to resolve these issues, and others, with the NOI it adopted at the August Open Commission Meeting. In addition to seeking comment on the three specific bands mentioned above, the Commission is asking commenters to identify other bands between 3.7-24 GHz that might be suitable for expanded flexible use, as well as “long-term strategies” for promoting flexible use opportunities. Comments are due on October 2, 2017,  and reply comments on November 1, 2017 and may be filed at this website. Enter proceeding number 17-183.