12 GHz for 5G Proponents Say FCC Engineering Work Appears Far Along

Supporters of a proposal to reallocate the 12 GHz band for 5G think the proposal will likely move forward in coming months, buoyed by responses by FCC Chairwoman Jessica Rosenworcel and Commissioner Brendan Carr to members of Congress last week, as a follow-up to the recent House hearing. Meanwhile, Dish Network Chairman Charlie Ergen offered a candid assessment of the future of DBS spectrum in a presentation to analysts.

“Our coalition was very pleased with chairwoman’s response” to Rep. Brett Guthrie, R-Ky., said Chip Pickering, Incompas president and a leader of the 5G for 12 GHz Coalition. The FCC should act by the end of the summer, he predicted.

The response "did show that the engineering and technical staff were getting into the granular details and looking at specific issues,” Pickering told us. “We interpret that in a very positive way and that the commission is looking at this very seriously and trying to identify outstanding issues that need to be addressed and resolved.”

“We’re encouraged by the chair’s response,” said RS Access CEO Noah Campbell. “We are looking forward to engaging with the world-class engineers at the FCC to prove out the research that our engineering team has built out over the last year and a half,” he said. “The engineering is proven here, and the record is basically closed. So the fact that the work is occurring on coexistence is an important next step to determining how this frequency is ultimately used.”

“The FCC has started a proceeding to explore opportunities for making more intensive use of 500 megahertz of spectrum in the 12 GHz band,” Rosenworcel told Guthrie, co-chair of the Congressional Spectrum Caucus, in a written response. Rosenworcel noted the band has historically been used for DBS and the multichannel video and data distribution service, and now a new generation of satellites offering broadband. “With this proceeding, the FCC is reviewing whether there may be additional opportunities to open this band up for new terrestrial use, including 5G, without causing harmful interference to existing users,” she said.

Rosenworcel confirmed the work already being done at the FCC. “At present, the agency is considering the criteria that should be used for assessing interference between mobile and satellite services,” she said. The FCC is also studying “how to model the increase in probability of interference to satellite user terminals and how to determine what level of probability increase, if any, should be determined as acceptable,” she said: “Work is also underway regarding the specific assumptions that should be made regarding the operational parameters and technical specifications of satellite user terminals in the band -- such as how many there will be, what will be the separation distances between satellite user terminals and 5G stations, what will be the elevation angle, antenna height, and antenna gain of the satellite user terminals -- and how best to structure a Monte Carlo simulation.”

“A wide range of legal, technical, and policy experts” from the Wireless and International bureaus and Office of Engineering and Technology “are engaged in this review, analyzing these questions, and coordinating, as necessary, with other federal authorities in the process,” Rosenworcel said. The FCC declined further comment.

Carr weighed in on a question from Rep. Buddy Carter, R-Ga. “As part of the ongoing 12 GHz proceeding, the FCC is assessing whether adding additional authorizations would promote or hinder the delivery of next-generation services,” Carr said: “As we do so, I believe it is imperative that we approach the policy and technical issues associated with this band in a balanced manner to ensure that we reach a result that will promote the public interest. I hope that the engineering demonstrates that we can get to a win-win in this proceeding.”

Dish, a DBS player now building a 5G network, has been a leading advocate of the 12 GHz proposal. Ergen, at a recent analyst meeting, suggested the band can have a higher use.

Ergen on DBS

“DBS has been a great long-term business for us, but obviously, that’s a business that’s declining, but it still does offer tremendous cash flow,” Ergen said. 12 GHz is “the only 500 MHz band, probably in the next decade, that’s going to be available, and it’s not owned by the Department of Defense,” he said: “This is going to get more use, and we’re well positioned there.”

USTelecom raised objections, in a letter posted Tuesday in docket 20-443. “The 12 GHz band cannot be reallocated given the substantial investments that have already been made by service providers in reliance on existing FCC rules and the infeasibility of terrestrial operations coexisting with incumbent services,” the group said. The group took a shot at Dish, saying the commission “should be particularly wary of the reallocation request when the primary agitator demanding access to the band has a track record of failing to deploy within the massive amount of spectrum it already has, including the 12 GHz band.”

“The record clearly shows that a terrestrial mobility allocation in the 12 GHz band would create harmful interference for incumbents, including” non-geostationary orbit fixed satellite systems, emailed Eric Graham, director-government and regulatory engagement, North America for OneWeb. “We are confident that the Commission understands this, and we hope they will conclude the proceeding very soon by rejecting the … efforts to disrupt the existing services in this band,” he said. SpaceX didn’t comment.

Other 12 GHz supporters saw room for hope.

“We are pleased that the FCC is engaged on analyzing the technical analysis to try to find a win-win-win,” Jeff Blum, Dish executive vice president-external and legislative affairs, told us. “Dish is confident that there can be, based upon the engineering, a real opportunity to unleash 500 MHz of high mid-band spectrum for 5G, while protecting incumbent operations,” he said.

“There isn't a heck of a lot of new spectrum around,” said Public Knowledge Senior Vice President Harold Feld: “This is 500 MHz of spectrum without federal users that will be immediately put to use if an unlicensed underlay, opportunistic sharing or mobile is approved. It also has the advantage of not needing an auction at a time when the FCC's auction authority is in danger of expiring. These external considerations make expanding the 12 GHz band too good an opportunity to pass up, assuming the engineering works out.”

Feld warned some details may be difficult, and the FCC may need to issue an order, while seeking further comment, which he noted is an approach followed on other bands, including the citizens broadband radio service and 6 GHz. “One of the problems with extremely open-ended interference questions is that these are complicated and interrelated questions,” he said: “The challenge is always how to keep the agency focused and to make sure enough of the agency's scarce resources are allocated to addressing the outstanding questions.”

“The FCC needs to get moving,” said Digital Progress Institute President Joel Thayer. “The 12 GHz band is a wide swath of valuable mid-band spectrum and can play a real part in future 5G deployments,” he said. Interference concerns are “overstated, because it seems highly unlikely that companies providing rural services, like SpaceX, will be affected by carriers using the band in urban settings hundreds, if not thousands, of miles away,” he said.