Broadcom representatives pressed for FCC action certifying automated frequency coordination providers in the 6 GHz band and approving use of very-low power (VLP) devices without coordination, meeting with an aide to Chairwoman Jessica Rosenworcel and top officials at the Office of Engineering and Technology. “In addressing those issues, we pointed to the submission of two large-scale probability analyses and a detailed technical response to filings by FirstEnergy and Evergy, and we explained that the Commission now has a full and robust record and can move ahead on items in the pending” Further NPRM, said a filing posted Tuesday in docket 18-295.
Most reply comments supported FCC grant of a waiver request by the Wi-Fi Alliance of rules for the predictive propagation models that an automated frequency coordination system must employ in the 6 GHz band (see 2303210039). Only the National Wireless Communications Council (NWCC), which represents a diverse group of 6 GHz incumbents, filed reply comments in opposition.
As NTIA tries to craft a national spectrum strategy, advocates are far apart on whether exclusive licenses for spectrum or reuse and sharing should be the primary focus, per comments submitted this week (docket 2023-0003). It continued to get pushes for repurposing bands including 3.1-3.45 GHz (see 2304170009).
Arguments against opening the 6 GHz band to unlicensed operations rely on "flawed and unreliable" analysis, tech industry representatives told aides to the four FCC commissioners, per a docket 18-295 filing Monday. They said Evergy's claims of potential interference from 6 GHz low-power indoor operations from utility use of the band (see 2303020077) relied on a "carefully manufactured, unrealistic, worse-than-worst-case study." They said FirstEnergy's arguments about interference by low-power indoor devices in the 6 GHz band to its licensed operations (see 2301130037) made such errors as artificially maximizing line of sight to microwave receivers ignoring real-world power levels. They said supposed interference events in Miami highlighted by APCO (see 2211220044) involved devices not operating under the FCC's 6 GHz rules and apparently were operating improperly in the band. Meeting with the FCC were reps from Apple, Broadcom, Cisco Systems, Google, Hewlett-Packard, Intel, Meta, Microsoft and Qualcomm. APCO, FirstEnergy and Evergy reps didn't comment.
The U.S.’ citizens broadband radio service approach has been at forefront of a global movement for private 5G, said Dave Wright, Hewlett-Packard head of global wireless policy, said at an FCBA spectrum CLE seminar Wednesday. CBRS commercial service has been available since 2020 in the U.S., and the FCC has authorized more than 500 devices in CBRS, and more than 4,300 professional installers are CBRS certified, he said. Beyond traditional spectrum access via licensing or unlicensed use, CBRS in the 3.5 GHz frequency range is a new approach in spectrum management by introducing a three-tiered sharing model, he said. Incumbents get protection from interference from priority access licenses and general authorized access, and PAL has priority over GAA, he said. One key difference in the U.S. approach is that no other country has used a dynamic framework like the U.S., and in most cases they're using local licenses instead, he said. Unlicensed spectrum is increasingly a linchpin for communications networks, with more devices using more data, said Alex Roytblat, Wi-Fi Alliance vice president-worldwide regulatory affairs. Telehealth, virtual reality and industrial IoT will require connectivity magnitudes faster than what's provided today by 5G, and opening up the 6 GHz band will help enable them, he said. That will require more use of local-area short-range communications and spectral reuse, he said. “The wide area network model is not going to be there to support our connectivity,” he said. The U.S. is unique in spectrum management with two agencies having authority -- the FCC regulating non-federal commercial use and NTIA regulating federal use such as by DOD, said Becky Tangren, NCTA associate general counsel. With spectrum increasingly crowded, the FCC is no longer as focused on exclusive access and is getting more creative in allowing access, such as via unlicensed bands, or shared use, she said. Some 2023 World Radiocommunication Conference agenda items will look at harmonizing frequencies for 5G, and WRC-2027 will likely look at what bands are to be used for 6G, she said.
Representatives of the Open Technology Institute at New America and Public Knowledge urged FCC action on pending 6 GHz issues, in a video call with an aide to Commissioner Brendan Carr. “We reiterated our strong support for rapidly making the full benefits of expanded unlicensed spectrum capacity for next generation Wi-Fi 6E/7 available to consumers,” said a filing posted Thursday in docket 18-295: The groups also asked about the status of the 12 GHz proceeding “and, in particular, whether the Commission will continue to consider alternatives to mobile 5G sharing in the band if coexistence is not possible.”
Comments were sharply divided on a waiver request by the Wi-Fi Alliance of rules for the predictive propagation models that an automated frequency coordination system must employ in the 6 GHz band (see 2303210039). The alliance asked to be able to incorporate building entry loss (BEL) in its AFC model for specifically identifiable “composite devices” designed to operate in both low-power indoor (LPI) and standard power modes.
APCO opposed a waiver sought by the Wi-Fi Alliance of rules for the predictive propagation models that an automated frequency coordination system must employ in the 6 GHz band (see 2303210039). The waiver of a rule is appropriate “if special circumstances warrant a deviation from the general rule and such deviation will serve the public interest and will not undermine the policy underlying the rule,” APCO said, posted Wednesday in docket 23-107: “Wi-Fi Alliance has not demonstrated that special circumstances warrant deviation from the rule. Nor has it shown that such deviation will serve the public interest.”
Utility, public safety and other groups asked the FCC to launch a proceeding looking at cost recovery for 6 GHz incumbents, “an issue which has not been examined as part of this proceeding.” They also asked for “improvements in interference detection, identification, reporting, tracking, and elimination for the 6 GHz band, including the creation of a centralized interference reporting point that is publicly available” and a public comment period on extending the automated frequency coordination requirements “to all uses of the 6 GHz band to support the interference detection, identification, reporting, tracking, and elimination process,” per a filing Friday in docket 18-295. Among those signing the petition were the American Public Power Association, APCO, Edison Electric Institute, the Enterprise Wireless Alliance, the National Rural Electric Cooperative Association and the Utilities Technology Council.
NTIA Administrator Alan Davidson assured attendees at an NTIA listening session on a national spectrum strategy Thursday the administration understands the need for concrete action and a spectrum pipeline for 5G and 6G. Twenty other speakers signed up to offer comments, which covered all the usual spectrum issues, from the importance of unlicensed and dedicated license spectrum to evolving sharing technologies to the potential role for THz spectrum.