Lobbying continued up to the sunshine notice period on the FCC’s proposed draft on the lower and upper 12 GHz bands, set for an FCC commissioner vote Thursday (see 2304270077). Representatives of Intelsat, SES Americom and New Skies Satellites met with staff for all four commissioners seeking revisions. The satellite operators asked for language in the NPRM “to more accurately reflect current and immediately deployable potential future satellite use of the 12.7-13.25 GHz band.” They warned “continued erosion of access to spectrum for satellite services -- particularly when demand is increasing rapidly -- will impede the United States competitiveness in the global space economy,” said a filing posted Friday in docket 20-443. CTIA representatives met with an aide to Chairwoman Jessica Rosenworcel, also on the upper part of the band. CTIA supports “proposals to allocate flexible, exclusive-use licenses in the 13 GHz band, and enable providers to transmit at high power levels, which would be key to unlocking the benefits of the … band,” the group said. Doing so is important to a spectrum pipeline, CTIA said. CTIA also expressed support for requiring broadcast auxiliary service licensees “to certify the accuracy of their licenses and confirm whether their facilities are operating as authorized, and suggested extending this requirement to Cable Television Relay Service licensees in order to further efforts to free up the band for more efficient and intensive use.” Go Long Wireless President Tim Meyer spoke with aides to the four commissioners about “the promise of fixed wireless in the 12.2-.12.7 GHz Band.” Go Long “has been working for some time on deployment options, including the development of proprietary, two-way radio equipment” and “appreciates and looks forward to the opportunity to comment on the issues posed in the Further Notice portion,” the company said. The Dynamic Spectrum Alliance asked for tweaks, including “crisper” language on unlicensed use of the spectrum “to make it consistent” with the commission’s 2020 6 GHz order.

Tower company CEOs expect a strong 2023, with 5G driving carrier investments, and the major carriers all building out mid-band spectrum. Meanwhile, a CTIA official said Thursday the key to the U.S. leading on 6G is getting 5G policy right.

A new study by utility FirstEnergy warns of interference risks to utilities and other incumbents of the 6 GHz band as more Wi-Fi users take advantage of the spectrum, authorized by the FCC for unlicensed use three years ago (see 2004230059). The study follows a similar report FirstEnergy submitted last year (see 2210130051). “Additive interference was consistently demonstrated with the Wi-Fi 6E test devices,” the company said in the report posted to the FCC Wednesday. “Repeated tests performed over multiple days consistently found greater impact when multiple study test units were in simultaneous operation versus when a single unit was in operation.” FirstEnergy found interference is “already starting to impact licensed operations.”

Public safety, critical infrastructure and other 6 GHz incumbents said they met with staff for all four FCC commissioners to seek action on a March 31 letter asking for protection from unlicensed use of the band. The incumbents asked for “action” on a “longstanding petition for rulemaking, including cost recovery for incumbent licensees” in the band, “improvements in interference detection, identification, reporting, tracking, and elimination … including the creation of a centralized interference reporting point that is publicly available,” an opportunity to comment on a proposal to extend automated frequency coordination requirements to all uses of the band and “sufficient time provided for review and completion of real-world testing of AFC systems before implementation,” and other protections. Representatives of APCO, the Edison Electric Institute, the Enterprise Wireless Alliance, the National Rural Electric Cooperative Association, Southern Company Services and the Utilities Technology Council were at the meetings, said a filing posted Tuesday in docket 18-295.

Pacific Gas & Electric filed at the FCC a new study, which it said raises additional concerns on the interference threat from unlicensed operations in the 6 GHz band. PG&E “has repeatedly expressed concern about the impact of unlicensed use of the 6 GHz licensed band, and over the past two years, real-world testing and filings by a variety of utility companies, research institutions, and trade associations have validated that concern,” said a filing posted Wednesday in docket 18-295. The study's key finding is that “over 50 links were found to have impact concerns over the next 5 years due to the projected growth of unlicensed Wi-Fi 6E in its territory,” PG&E said: “Additionally, four links showed such severe risk for interference that they are already being moved to 11 GHz channels at significant cost to PG&E.”

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.