6 GHz Replies Take on Claims in Earlier Comment Round
Replies on the 6 GHz NPRM largely refuted claims in initial comments (see 1902190005), which included many from incumbents concerned about interference. The FCC appears committed to moving forward with unlicensed in 6 GHz, and licensed in the C band, and must decide on such issues as whether to allow use of the band indoors without automated frequency control (AFC) (see 1902250054). Replies were due Monday in docket 18-295.
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The Dynamic Spectrum Alliance fired back at commenters who questioned efficacy of dynamic spectrum management. “It will work, as it has in other bands in the United States and across the globe,” DSA said. “A small number of other commenters argue that the Commission should limit the band’s potential by foreclosing applications like decentralized architectures and mobile options, but do so based on unfounded speculation.”
Incumbents in the 6 GHz band “provide important services” and the FCC’s interference protection criteria and the “corresponding technical and operational rules for unlicensed operations should protect each licensed service from harmful interference,” Microsoft said. Rules “should not be driven by the most unlikely of corner cases or leveraged by incumbent operators as an opportunity to squeeze another few years of service life out of outdated legacy communications equipment.”
The FCC should understand the extent of the interference threat, with more engineering analysis and field tests, before proceeding, Los Angeles said. Don’t adopt rules “until it has conclusive scientific evidence proving that unlicensed 6 GHz operations will not introduce interference, and will not threaten life and property, as is likely the result of the NPRM’s proposals,” the city said.
The American Association of State Highway and Transportation Officials warned of the threat to safety systems in the 5.9 GHz band. BMW Group also urged protection for the band. The proposed out-of-band-emission limit would likely mean harmful interference for safety-related cellular vehicle-to-everything services, BMW said: “Given the potential of C-V2X services to dramatically improve safety on America’s roads, this seems like an unnecessary potential risk to safety-relevant communication.”
The National Spectrum Management Association opposed indoor operations without AFC. Radio local area network commenters argue management of interference “is not necessary for low to moderate power RLAN transmitters,” the association said: “They contend interference will be rare and therefore not worthy of consideration. We do not agree. We know from more than thirty years of frequency management experience that the ‘rare cases’ are in fact the performance limiting cases that must be managed or they will significantly impair Fixed Service reliability.” Rules are clear, the NSMA said: “Licensed services must be protected from harmful interference.”
Sharing is especially challenging for unlicensed, “often nomadic” uses, the Enterprise Wireless Alliance said. “Individuals that purchase consumer wireless devices typically have little or no knowledge of any FCC limitations on their use of the equipment,” EWA said. “Protective measures, and the means for enforcing them, need to be baked into the regulatory process, including provisions for both rapid intervention if interference occurs and accountability for any problems that do arise.”
The Utilities Technology Council, Edison Electric Institute, American Public Power Association, National Rural Electric Cooperative Association, American Petroleum Institute and American Water Works Association urged caution, for members widely using the band. “The public interest in reliability and safety outweighs the benefits of unlicensed access to the 6 GHz band,” they said.
No RLAN commenters promise to fully protect fixed-service operations, the Fixed Wireless Communications Coalition said. “Some fail to grasp the legal principle that unlicensed devices must protect licensed, critical services,” the coalition said. “The more responsible RLAN interests offer only to limit interference, not to prevent all RLAN-caused failures. Their approach, repeated through several pleadings, consists of concatenating unlikelihoods.”