As Incumbents Raise Concerns, Others Debate Best Model for Opening 12.7 GHz Band

Industry companies and groups disagreed sharply on the best way for the FCC to open the 12.7 GHz band for other users, and whether it should be offered for exclusive-use licenses or be the next big sharing band. Band incumbents urged caution. Comments were due Monday and posted Tuesday in docket 22-352. The FCC approved a notice of inquiry in October on what others call the 13 GHz band (see 2210270046).

NTIA cautioned that some federal agencies use the band. The band “includes a federal allocation for reception-only by a satellite ground station at the Goldstone Deep Space Communications Complex,” the agency said. DOD “leases commercial satellite services in the 12.7 GHz band and operates its own ground stations,” NTIA said: “Numerous passive radio astronomy observatories, operated and supported by the National Science Foundation and NASA, make observations in the 12.7 GHz band.” NTIA said its “adjacent-band concerns are principally with the 13.25-13.75 GHz band, which is primarily a federal band with both military and scientific uses.”

“A shared-licensed framework would be a particularly good fit if the Commission decides not to relocate incumbent services to other bands,” said the Open Technology Institute at New America and Public Knowledge. “A major advantage of opening the 12.7 GHz band for coordinated shared use on a secondary basis is avoiding the costly, disruptive and lengthy process associated with clearing and relocating band incumbents,” the groups said. They said the band may be a good fit for the kind of sharing in the citizens broadband radio service band.

CTIA, which fought against the FCC viewing CBRS as the optimal model for other bands (see 2212120050), seeks exclusive-use licenses. “Allocating flexible, high-power, exclusive use licenses in the 13 GHz band will be critical to supporting rapidly growing consumer and business needs for next-generation mobile and fixed broadband services,” CTIA said: “Limiting the 13 GHz band to low-power or shared access for commercial mobile and fixed broadband services would inhibit investment, innovation, and U.S. global leadership.” CTIA also urged the FCC to require incumbents to file data on their use of the band.

AT&T opposed using CBRS or other sharing models for the band. “To fully unlock the potential for innovative uses of the 13 GHz band, the Commission should prioritize exclusive, flexible use licenses in the band,” AT&T said: “This model has proven successful in helping efficiently deliver high-quality mobile broadband services to the public and should be extended to the 13 GHz band.” The U.S. “already has significantly more unlicensed mid-band spectrum than its global competitors, including the whole 6 GHz band,” the carrier noted.

Verizon also proposed exclusive-use licensing. “U.S. wireless networks supported more data traffic in 2021 than 2010-2017 combined, and Ericsson predicts that global mobile data use will grow nearly fourfold in the next five years,” Verizon said: “Demand is dramatic: 5G home broadband grew 140 times faster last year than all other home broadband offerings. … Licensed, exclusive-use wireless networks are the backbone of our Nation’s wireless deployment.”

Dish Network said the FCC shouldn’t forget the lower 12 GHz band, a continuing focus of Dish and others (see 2210130063). “The 13 GHz band is a valuable complement to the 500 MHz below it,” Dish said: “DISH supports opening the 13 GHz band for new terrestrial services if that spectrum becomes complementary to the 12 GHz band: joining these two bands will supply more than 1 GHz of uninterrupted mid-band spectrum for high power two-way services in the United States, an international gold standard approached only by Japan.”

“While the 5G for 12 GHz Coalition is primarily interested in maximizing the lower 12 GHz band for two-way terrestrial and 5G mobile and fixed services, the Coalition supports the agency’s efforts to expand opportunities for additional operations in this adjacent spectrum,” the coalition said.

Others also supported a shared-use model. “There is a significant opportunity to maximize the use of the 12.7 GHz Band using proven dynamic spectrum sharing technology, and Federated Wireless stands ready to work with all parties to implement a sharing solution that accommodates all users of the band,” Federated said: “The availability of new spectrum sharing technologies means the Commission no longer needs to choose one type of service over another or rely on conservative technical rules to ensure protection of incumbent services.”

“The great majority of commercially available low-band and mid-band spectrum rely on an exclusive-licensed approach that set high power levels and large geographic license areas,” said NCTA: “This approach only supports the particular deployment models of the largest carriers. The country needs both exclusive-licensed and shared-licensed bands to meet the diverse and growing needs of American consumers and businesses.”

Incumbent Concerns

Incumbents urged caution. “As the Commission considers whether and how to expand use of the 12.7-13.25 GHz band it should first examine how best to retain some portion of the band for broadcasters’ use.” NAB said: “Broadcast mobile operations (electronic news gathering or ENG) are already being displaced from the 2 and 6 GHz bands due to increased interference from band-adjacent AWS systems (in the case of the band 2025–2110 MHz) and expected interference from Wi-Fi 6E systems (in the case of 6425–6525 MHz and 6875–7125 MHz).”

Engineers for the Integrity of Broadcast Auxiliary Services Spectrum called the NOI “premature” and said broadcaster use of the band must be protected.

“Spectrum sharing only benefits the American people when it accounts for the different technologies that are sharing the band and those operating in adjacent bands,” said SpaceX, which uses the band for uplinks. “While the Commission should certainly account for existing uses in the 12.7 GHz Band and consider methods to either protect those uses or relocate them, such an approach initially appears more tenable in this band than forcing new services that are incompatible with existing services into other more intensively used bands.”

DirecTV said it has used the band to offer direct broadcast satellite service since 1994. But absent proposed operational parameters for new services in the band and technical and engineering analyses “that would enable quantification of potential interference and assessment of potential mitigation strategies,” DirecTV said, “it is not possible at this time to determine the extent to which introduction of such services could affect DIRECTV subscribers -- especially given the diversity of DBS equipment deployed in American homes.”