Proponents Optimistic FCC Will Act on 12 GHz

After the FCC wrapped up the comment cycle on possible use of 12 GH for 5G, some experts said having a permanent chair will help move things along. Divisions remain on whether the FCC can safely open the band. Replies were due Wednesday. Proponents and critics told us the key will be how convincing the FCC finds the technical case asserting that incumbent satellite operators in the band can safely share with terrestrial use.

“We’re very confident in the FCC’s decision-making process,” said RS Access CEO Noah Campbell. “We’re very confident in the FCC’s ability to recognize sound engineering and sound policy. … The FCC leads the world in this.” Proponents believe they have offered the engineering and economic arguments that justify moving forward, he said. “We don’t think there are any tradeoffs.” The FCC didn't comment.

“It's going to come down to the technical analysis,” said Dish Network Executive Vice President-External and Legislative Affairs Jeff Blum. He said the lack of counter technical analysis from opponents “ups the odds” of FCC OK. He said next comes lobbying bureaus on technical issues and with the eighth floor, Capitol Hill and administration. The agency, policymakers and lawmakers “agree 5G leadership is really important and spectrum is a critical element of that and we're behind on mid-band,” he said. Blum said there haven't been compromise talks with non-geostationary orbit satellite incumbents, though once there is analysis of the reply comments, “there can be engagement.”

The RKF Engineering Solutions study supporting coexistence (see 2105100028) is flawed in numerous ways, said Eric Graham, OneWeb director-government and regulatory engagement, North America. He said it focuses on a single operator's deployment, assumes the most favorable deployment characteristics for terrestrial mobile and yet still shows incumbents will suffer harmful interference.

The FCC shouldn’t wait, said Incompas General Counsel Angie Kronenberg. “The U.S. needs additional mid-band spectrum for 5G to compete,” she said: “It is our hope that the rulemaking process keeps moving, with the staff reviewing the record, meeting on the issues, and making their recommendations to the acting chair so that we have a decision as soon as possible.” The FCC has what it needs to act with a “robust record with substantial engineering data showing feasibility of coexistence of 5G in the band,” she said.

The Computer & Communications Industry Association is “optimistic” because the Biden administration and the commission “are prioritizing 5G networks and better connectivity for Americans,” a spokesperson emailed: “Once there is a full commission in place, we hope that the commission will vote on updates to the rules … to make better use of the band.”

Replies

Docket 20-443 posted replies through Thursday. The record “supports the FCC making modifications that would expand the use of the band for two-way communications and mobile services by showing that shared use of the band is technically feasible and that doing so has enormous public interest benefits, including for the 5G economy,” the 5G for 12 GHz Coalition said.

Some oppose moving forward. “While the Commission’s objectives in this proceeding are admirable, insurmountable barriers appear to preclude coexistence between terrestrial mobile 5G systems” and fixed satellite service operations in the band, Google said. Microsoft President Brad Smith cited the importance of “ensuring that satellite operations in the 12 GHz band are not undermined,” in a call with FCC acting Chairwoman Jessica Rosenworcel.

NCTA said it’s unclear whether converting the band to 5G is possible. “The record is still developing on whether the 12 GHz band can support greater terrestrial use without causing harmful interference to incumbent operations,” the group said: “Any Commission review of the 12 GHz band must provide all interested parties a fair opportunity to access any new spectrum resources made available through expanded terrestrial use rights.”

Among major carriers looking for more spectrum for 5G, only T-Mobile supports opening the band. Verizon didn’t file. Dish supports acting. Opposition is “muted and nuanced rather than firm and absolute,” Dish said: “Even the incumbents who profess concern about the introduction of 5G services stop short of asserting that sharing is impossible.”

“Those who bear the burden of proving that coexistence is possible continue to fall short when making their case,” filed AT&T. “This effort was particularly lacking with respect to the proposed services’ ability to protect incumbent [direct broadcast satellite] DBS services, analysis of which was regularly omitted or given short shrift.”

“Commenters resoundingly agree that more spectrum is needed to support terrestrial 5G services and that the 12 GHz band may be an ideal target,” T-Mobile said. The carrier wants a broad exam of other bands for 5G: “NTIA has already examined the feasibility of commercial use of the 7 GHz and 8 GHz bands, the 17 GHz band is complementary to the 12 GHz band, and the 13 GHz band is suitable for terrestrial mobile use because of its proximity to the 12 GHz band.”

Satellite interests were critical of RS Access' RKF study. SpaceX said flaws include assuming 5G base stations only in densely populated areas and satellite use only in rural and remote areas, and assuming at most 2.5 million customers for all NGSO systems, despite SpaceX's Starlink having more than 500,000 orders for its beta service. The study bases analysis on elevation angles used only by SpaceX, ignoring other satellite operators authorized to operate at lower angles. OneWeb said RKF used terminal characteristics and terrestrial mobile deployments that don't represent the real world, and its claim there could be case-by-case site coordination doesn't jibe with terrestrial mobile or fixed satellite service systems.

Allowing terrestrial use in 12 GHz “could well produce the worst of both worlds” by limiting satellite service growth even while not boosting the likelihood of terrestrial service availability thanks to the band's unfavorable propagation characteristics and lack of an international allocation for mobile service, SES said. Also critiquing the study or arguing that 5G in the 12 GHz band unduly threatens incumbent services were Intelsat, Boeing and Kepler.