Public Interest Groups Urge Spectrum-Sharing Regime for High-Band Spectrum

The FCC should separate the access rights for indoor use of the spectrum from outdoor use, PK and OTI said. Following the model in the 3.5 GHz band, the FCC should establish a millimeter wave Spectrum Access System, they said. Companies that buy rights to the spectrum should have to use it or share it, they said. “There is no legitimate reason to let a large geographic license area lie fallow for five years.”

The high-band spectrum is well suited to unlicensed use, but not necessarily licensed use, PK and OTI said. “Unlike lower-frequency spectrum, the extremely attenuated propagation characteristics of millimeter wave (mmW) bands benefit wireless carriers and consumers alike not by increasing coverage for truly ‘mobile’ use (on the go), but rather by enhancing the density and capacity of networks (self-provisioned as well as carrier-provisioned) that support the ‘nomadic’ use of mobile devices, mostly indoors (in homes, offices, public places) and always very close to fixed, typically wireline, backhaul.”

Verizon is testing 5G and will have some kind of commercial rollout next year, Charla Rath, vice president-wireless policy development, said in a blog post. “By launching this proceeding, and proposing to give current millimeter wave licensees the flexibility to bring new services to market quickly, the FCC has begun to pave the way for 5G,” she wrote. “5G could enable about 50 times the throughput of 4G LTE, latency in the single milliseconds, and the ability to handle exponentially more Internet-connected devices to accommodate the explosion of the Internet of Everything.”

Five G won't consist of a single radio access technology (RAT), AT&T said. “Rather, a combination of existing RATs and new RATs optimized for specific deployments and use cases will work together to support 5G services,” the company commented. “The next generation of networks will use higher frequencies, more bandwidth, and higher density cell deployments.” The 5G network will also use higher frequencies, more bandwidth and higher density cell deployments than traditional networks, AT&T said.

T-Mobile said the high-frequency spectrum will be critical to deployment of small cells as carriers seek to densify their networks. Generally, the FCC should offer licensed spectrum, T-Mobile said. “Deploying a network is a lengthy process involving standardizing a new frequency band, developing and certifying new equipment, acquiring sites, securing local permits and zoning, building infrastructure, and incorporating spectrum into consumer devices,” the carrier said. “Licensed operations help guarantee reliable service and encourage greater investment and technical innovation by providing carriers with needed certainty.” The FCC should also consider use of the 24, 29/31, 42-42.5 and 71-76/81-86 GHz bands in addition to the bands listed in the rulemaking, T-Mobile said.

The Fixed Wireless Communications Coalition stressed the importance of protecting existing 28 and 39 GHz fixed licensees from interference and also allowing them to use the spectrum for mobile operations. The FWCC opposed rules that require buildout in the spectrum by a given date. “These criteria have prompted licensees to build facilities that serve no practical purpose, and have resulted in license take-backs which left behind needlessly vacant spectrum,” the group commented. “We support the alternative under which the licensee pays the winning bid amount, adjusted for inflation, every five years.” FWCC said the FCC should rethink its proposal to license the spectrum on a county-by-county basis, saying most counties are too small for this to be practical.

Satellite Concerns Raised

The FCC 28 GHz, 37 GHz and 39 GHz rules change proposals, as they stand now, “will deprive [Inmarsat’s] constellation of the spectrum it needs to provide, expand and enhance its services” and force it to take such steps as shut down a recently constructed earth station in Minnesota, the satellite company said. The FCC should upgrade fixed satellite service earth stations to co-primary status in the 28 GHz band and keep co-primary allocation for FSS earth stations in the 37 and 39 GHz bands, Inmarsat said. Global VSAT Forum and SES also backed co-primary status for earth stations in the 28 GHz band (see here and here). SES also said first-come first-served licensing approach rather than auctions in the 28 GHz band would be the most efficient route for encouraging satellite and terrestrial mobile use of the spectrum outside heavily populated areas.

The Satellite Industry Association -- warning of “enormous spectrum uncertainty for satellite services” under the 28 GHz, 37 GHz and 39 GHz rules proposals -- said earth stations having co-primary status in the 28 GHz band would help satellite and terrestrial mobile services “work out an appropriate sharing environment based on concrete deployment steps.” That and letting earth stations operate on a co-primary basis in the 39 GHz band “would allow for a clear interference environment” as new millimeter wave spectrum uses are worked on, SIA said.

Any FCC proposal to assign terrestrial mobile licenses by geographic area would hurt satellite services and their future growth “even while leaving the [millimeter wave] bands unused in large areas,” O3B said. It argued geographic licensing is a bad choice for bands that could cover a city block or two. Instead, mobile service in the millimeter wave bands, such as the 28 GHz band, should be done on site licensed basis, the satellite company said.

The 28 GHz band, used by satellites for years, could be shared with mobile wireless services, but the FCC sharing proposal in docket 14-177 isn’t sufficient, ViaSat said. Mobile operators need to design their networks “to accept a reasonable amount of unwanted energy from satellite earth stations,” ViaSat said. Any incompatibility areas would be, at most, 160 meters from earth stations, and shielding could make that radius smaller, it said. So 28 GHz band earth station operators shouldn’t need to get geographic license rights to protect their facilities, it said. Meanwhile, as satellite operators have already begun planning for satellite broadband offerings in the 37.5-40 GHz band as the Ka band becomes more congested, the FCC should allow for higher power limits for downlinks, it said.