CTIA Wants Some Licensed Operations in 6 GHz; Others Oppose Any Changes to Band

CTIA urged the FCC to launch an additional NPRM to look at reserving the 6 GHz band's upper part for exclusive use licenses, while opening other parts for Wi-Fi and other unlicensed use. While many other commenters in docket 18-295 emphasized the importance of unlicensed spectrum and the need for mid-band alternatives, some 6 GHz incumbents said the FCC should drop the proposal completely, saying nothing it would mandate would eliminate the risk posed by widespread unlicensed use of the band. Comments were due midnight Friday.

Carriers need more licensed mid-band spectrum to keep up with the rest of the world, CTIA said. “As of the end of 2018, the U.S. ranked sixth out of ten countries in terms of licensed mid-band spectrum availability, and other nations continue to rapidly make significant amounts of mid-band spectrum available,” CTIA said. “China, Japan, South Korea, Spain, Ireland, Italy, and Australia have already auctioned or assigned hundreds of megahertz of mid-band spectrum.” While seeking 3 GHz spectrum, wireless companies “also view the 6 GHz band as an important opportunity for mid-band licensed spectrum,” the group said.

Verizon agreed with CTIA. “The United States needs to identify additional spectrum for both licensed and unlicensed use. Spectrum in the 6 GHz band affords an opportunity to introduce unlicensed operations using a new, robust spectrum sharing regime,” the carrier said. The FCC also “should continue to explore ways to address the dearth of licensed mid-band spectrum for 5G and other next-generation services.” Ericsson also urged that parts of the band be allocated for flexible licensed use. “The mobile industry requires large blocks of licensed spectrum to support 5G -- particularly in the mid-bands,” Ericsson said. “Presently, there is no large swath of mid-band spectrum available for licensed macro 5G service in the U.S.”

The Public Interest Spectrum Coalition countered that the FCC should allow unlicensed sharing across the entire 1,200 MHz, from 4925 to 7125 MHz. The band is essential for both “gigabit-fast Wi-Fi and other connectivity needs” and “high-capacity fixed wireless in rural and underserved communities,” the coalition said. The Open Technology Institute at New America, the American Library Association, Consumer Federation of America, the Consortium for School Networking, Public Knowledge and Access Humboldt jointly made the filing.

But the public interest groups said the FCC should change its approach beyond the NPRM and require more expensive automated frequency control (AFC) systems only for higher-power, outdoor use. The FCC’s failure to “set a power level at which Wi-Fi can operate indoors across the entire 6 GHz band, using off-the-shelf routers and low-cost devices, will sacrifice what is likely to be the greatest benefit of this rulemaking,” the groups said.

GE Healthcare said putting more unlicensed spectrum in play should be a top U.S. goal. “Spectrum congestion is already occurring in hospitals and negatively affecting the reliability of their systems,” GEHC said. “Opening up the 6 GHz band to unlicensed use can help address this growing need and alleviate congestion.” GEHC explained that some applications have greater needs for throughput, such as high-resolution imaging transfers, “because the frequencies” in the mid-band “are low enough to cover large areas but offer greater bandwidth to support high-capacity services.”

The NPRM is “a crucial step in making more unlicensed spectrum available to address exploding consumer demand for wireless technologies,” a group of major tech players said in a joint filing. “The Commission’s action on 6 GHz comes at a critical time. Multiple studies have demonstrated that the country requires a substantial increase in unlicensed spectrum resources just to keep pace with demand and deliver the important new capabilities of today’s wireless technologies to consumers.” The key to success is letting low-power devices operate indoors across the band without requiring AFC, the companies said. Apple, Broadcom, Cisco, Facebook, Google, Hewlett Packard Enterprise, Intel, Marvell Semiconductor, Microsoft, Qualcomm and Ruckus Networks signed the filing.

The Wi-Fi Alliance warned that a shortfall in unlicensed spectrum “threatens Wi-Fi performance and viability.”

Concerns Raised

The Association of American Railroads was among the groups that raised a red flag. Allocating any part of the band for unlicensed “will create an intolerable risk of interference to incumbent communications systems, which relay mission-critical information for railway operations, other critical infrastructure industries, and public safety operators,” AAR said. If the FCC proceeds anyway, AAR said it must take steps to limit the risk, including requiring the use of an AFC that is “centralized, relies on an accurate database, controls all unlicensed devices (whether indoors or outdoors), and establishes an initial connection with the unlicensed device in a band other than the 6 GHz band,” mandating an interference-to-noise power ratio of -6 dB and limiting the initial deployment of unlicensed devices.

The Utilities Technology Council and other groups representing electric utilities and other critical infrastructure companies said the FCC should drop any proposal for unlicensed use of the band. Critical infrastructure companies rely on the band and don’t have any alternatives, the filing said. “The proposed AFC system is based upon false assumptions and inaccurate data about incumbent microwave systems in the band; and it does not account for sources of passive reflection and multipath fading that can increase the potential for interference,” they said.

Sirius XM said the FCC must protect more than 34 million satellite digital audio radio service customers. “Sirius XM requires ongoing, reliable access to 6 GHz frequencies in order to operate its business, since the only spectrum it can use for SDARS feeder links lies in the range that the Notice proposes for sharing with unlicensed devices,” the satellite company said.

APCO also objected. “APCO remains concerned that expanding unlicensed use in the 6 GHz band will cause harmful interference to public safety operations,” the group said. “Fixed links are not designed to detect interference until after a communications link fails, putting safety of life and property at risk.”

​​​​​​​Global mobile data traffic grew 71 percent in 2017​​​​​​​ over 2016, Cisco said in a market update. Worldwide mobile data traffic hit 11.5 exabytes/month at the end of 2017, compared with 6.7 exabytes/month at the end of 2016. An exabyte is 1 billion gigabytes. Cisco found that mobile traffic saw a 17-fold increase over the past five years. Most of the traffic didn’t get carried on a wireless carrier network -- 54 percent was offloaded onto the fixed network through Wi-Fi or a femtocell, Cisco said.