In the on-going drama surrounding Dish Network's AWS-4 spectrum, CTIA said there is no need for the adoption of GPS-specific technical requirements in the FCC's final rules on Dish's holdings. 

In a filing with the FCC, CTIA noted that "GPS operations, located at 1559-1610 MHz band, are nearly 400 MHz away from the lowest point of the proposed AWS-4 spectrum located at 2000-2020 MHz."

CTIA claims that the 43 + 10 log10(P) dB of attenuation already included in the AWS-4 Notice of Proposed Rule Making (NPRM) is completely consistent with past FCC regulation of Out of Band Emissions (OOBE) – and has not led to any reports of harmful interference.   

CTIA also said that any further rules imposed on the spectrum would be "unnecessary" and would not "constitute good precedent" in this instance.

CTIA's comments on the matter are in response to recommendations made by the United States GPS Industry Council (USGIC). The USGIC argued that contrary to CTIA’s assertion, OOBE into the GPS bands is not a concern that is limited to directly adjacent spectrum operations.

"Other mechanisms such as local clocks, oscillators, and mixing products inside the transmitter can and do produce spurious emissions in other bands without regard to the proximity in frequency of those bands to the transmitter’s band," wrote the USGIC in an ex parte filing

The USGIC is asking that the forthcoming AWS-4 report and order include reference to OOBE values agreed to by DISH and the USGIC.