Discussions about opening the 12 GHz band to 5G need to start focusing on technical issues such as the right interference criteria, the acceptable probability of interference and the means for determining how much of a terrestrial signal has been attenuated before it reaches a satellite receiver, Dish Network said in an FCC docket 20-443 filing Friday. It said differences are minimal between the interference thresholds being proposed by satellite and terrestrial 5G interests. It said the U.S. Court of Appeals for the D.C. Circuit's 6 GHz decision last month (2112280047) eviscerates two key arguments of 5G opponents -- that satellite and terrestrial spectrum sharing needs to be rejected unless there's zero interference, and that a "Monte Carlo"-style statistical analysis is inferior to a worst-case-scenario one. It said SpaceX hasn't supplied any evidence of its own to back its contention that 5G/non-geostationary orbit fixed satellite service sharing is impossible and studies it cites "were based on extremely conservative assumptions ... and a worst-case analysis." It said SpaceX also is mischaracterizing those studies. SpaceX didn't comment.

The FCC shouldn’t rethink whether to authorize automated frequency coordination system operations in the 6 GHz band, Wi-Fi advocates said in calls with aides to all four FCC commissioners, said a filing posted Friday in docket 21-352. Some 6 GHz incumbents “have attempted to use the [Office of Engineering and Technology] Public Notice process to relitigate issues already resolved by the 6 GHz Report and Order and advocate for additional requirements on AFC operations that do not appear in the Order and are beyond OET’s delegated authority in this process,” they said. Broadcom, CableLabs, Cisco, Meta Platforms, the Wi-Fi Alliance and Wireless Broadband Alliance were among those represented.

The biggest surprises in the 3.45 GHz auction were that Dish Network came in relatively big and T-Mobile small, according to the early analysis of the results, which were released Friday (see 2201140040). Verizon dropped out of the auction, after dominating the C-band sale, as expected (see 2111170037).

The International Association of Fire Chiefs supported concerns raised by APCO and others on companies and organizations seeking FCC certification to become automated frequency coordination (AFC) system operators in the 6 GHz band (see 2112220070). A representative of the group spoke with David Furth, deputy chief of the Public Safety Bureau, said a filing posted Wednesday in docket 21-352. “All fourteen AFC proposals failed to meet FCC’s rules and should be rejected until each proposal is supplemented with additional technical details,” the group said.

APCO said Tuesday it’s considering an appeal of the U.S. Court of Appeals for the D.C. Circuit decision last week upholding the FCC’s 6 GHz rules (see 2112280047). The court remanded to the FCC for further work a single, narrow issue, raised by broadcasters. “While federal review courts typically accord the FCC deference, we are of course disappointed because we remain concerned that new unlicensed devices will cause harmful interference to public safety communications,” the group tweeted: “We will consider our additional options in court and continue to actively work directly with the FCC to ensure that public safety operations are protected.”

Results of the 3.45 GHz auction are likely to be made public as early as this week, New Street’s Philip Burnett told investors Monday. Burnett said the consensus seems to be that AT&T spent $9 billion, T-Mobile $6 billion, Dish Network $5 billion and Verizon just over $2 billion. That could be wrong, with Verizon more likely to have taken a pass, he said. “Our conviction that Verizon sat out isn’t especially high, but we’d note that Verizon” management has gone “to serious lengths to point out the deficiencies in 3.45 GHz … when compared to C-Band, which they described as a ‘clean’ band of spectrum,” he said: “We also believe that the equipment initially deployed to towers by Verizon for C-Band isn’t compatible with 3.45 GHz spectrum.”

The FCC and Wi-Fi advocates notched a win in the U.S. Court of Appeals for the D.C. Circuit Tuesday, which upheld the agency’s April 2020 order reallocating the 6 GHz band for unlicensed use. The court remanded part of the order for more explanation. Judge Justin Walker, a new member of the court, had warned the order could be remanded or even vacated, and the FCC faced tough questions during oral argument in September (see 2109170057).

Seek more information and ask more questions of the 14 companies or organizations seeking FCC certification to become automated frequency coordination (AFC) system operators in the 6 GHz band (see 2112010002), asked the Fixed Wireless Communications Coalition and other incumbents in comments posted Wednesday in docket 21-352. “Protecting incumbent 6 GHz users remains critically important, and the Commission must demand that AFC operators meet rigorous standards to ensure licensees’ protection,” the coalition said: “At least one FWCC member has already experienced harmful interference to a licensed 6 GHz link from an unlicensed device.” The Utilities Technology Council and Edison Electric Institute raised similar concerns. None of the applicants “sufficiently demonstrate that they will fully comply with the Commission’s rules and all lack necessary technical detail for the Commission or affected incumbent operators to be certain that they will properly function and protect primary licensees from harmful interference,” the groups said. Applicants offer “differing explanations for how they will respond to reports of harmful interference,” with some suggesting “they will only be responsive to reports from the Commission,” APCO warned: “Public safety agencies should not be expected to report interference to individual AFC operators. Even if the particular device causing interference can be identified, incumbents are not likely to know which AFC operator is controlling the device.” AT&T said “the vast majority of the AFC System applications only superficially describe their compliance with the requirements of the 6 GHz Report and Order, and therefore fail to provide assurances that primary … incumbents will be protected.” Stakeholders haven't "identified consensus parameters for the propagation models that will assess unlicensed 6 GHz transmissions, in particular the confidence level, and only one of 13 AFC system applicants revealed the confidence level its system applies,” Verizon said. Apple, Broadcom, Cisco, Google, Hewlett Packard Enterprise, Intel, Microsoft, Meta and Qualcomm encouraged the FCC to act. “Articulate a decisional framework for processing the applications … with a goal of completing the review and authorization of commercial operations of AFCs and Standard Power devices in 2022,” the tech players said: “The relative simplicity of the AFC sharing mechanism compared to those in other bands should make FCC review and approval straightforward.” That 14 entities submitted proposals to operate AFC systems “evidences the utility of AFC-controlled standard power devices in the 6 GHz band,” the Wi-Fi Alliance said.

The FCC is unlikely to finalize pending orders on broader use of the 6 GHz band until after the U.S. Court of Appeals for the D.C. Circuit rules on a challenge to the 2020 order opening the band, experts told us. The FCC wrapped up a comment cycle on a Further NPRM in July 2020 (see 2007280033). This year, the agency sought comment on whether to allow client-to-client operations in the spectrum (see 2103240065). Chairwoman Jessica Rosenworcel has said only that the commission is working on the item.

Representatives of the Utilities Technology Council, Edison Electric Institute, APCO and others told an aide to FCC Commissioner Brendan Carr they would like the agency to stop certifying low-power indoor (LPI) devices in 6 GHz and seek new rules for the band (see 2112080058). “Adopting new rules for 6 GHz LPI devices and granting a stay of certification of all 6 GHz LPI devices is procedurally appropriate and in the public interest,” said a filing posted Monday in docket 18-295.