Groups Make Late Case for Changes to Draft 6 GHz Order

NSMA questioned the lack of testing and reminded the FCC of problems when other bands were opened for sharing. It's "a requirement that well-known, actual-deployment, spectrum management tests be conducted well prior to confirming rules for comprehensively launching additional services or systems in those same channels and geographic locations,” the group said. After Wi-Fi started to use 5 GHz spectrum, “at least 53 separate FCC enforcement-related actions” followed, NSMA said.

“The FCC provided NSMA with listening opportunities,” the group said on Facebook: “NSMA outlined data on the need to conduct live, peer-reviewed tests of the potential impact of the proposed introduction of over 900 million unlicensed devices into bands housing incumbent mission-critical transport, backbone and backhaul systems.”

“A lot of people, including the Fixed Wireless Communications Coalition, have been arguing that there should be mandatory testing before the unlicensed devices are allowed,” said Donald Evans of Fletcher Heald, who represents the coalition: “In our meetings this week on the eighth floor, there seemed to be some sympathy for that.”

NAB President Gordon Smith spoke this week with Pai and Commissioners Mike O’Rielly, Jessica Rosenworcel and Geoffrey Starks, a filing said. An NAB spokesperson told us the group is “confident” commissioners will find its compromise proposal “appealing.” Under the association's plan, “the commission can still maximize the number of 160 MHz channels for low power indoor unlicensed use, and the remainder would be an 80 MHz safe zone for broadcast and other operations,” the spokesperson said: “NAB has grave concerns that without the interference protections preserved under our compromise, remarkable lifesaving programming such as that aired by local TV stations during the COVID-19 crisis would be jeopardized.”

Association of American Railroads officials spoke with aides to the commissioners other than Pai to ask for more clarity on how interference problems will be addressed. Members rely on at least 1,600 private fixed microwave links in the band for safety, including positive train control, AAR said. “Incumbent licensees cannot reasonably be expected to bear the financial and logistical burden of determining which unregistered low-power device interrupted a critical system or caused an outage,” the railroads said: “The strictly voluntary framework in the Draft Order carries a number of risks.”

NCTA asked the FCC to move forward as proposed, saying the interference risk from low-power indoor (LPI) operations without automated frequency control is “insignificant.” The FCC isn't “required to refrain from authorizing services or unlicensed operations whenever there is any possibility of harmful interference,” the cable association said.

CableLabs, Charter, Comcast and Cox had calls with aides to all the commissioners. “CableLabs’ extensive interference analysis … demonstrates that LPI Wi-Fi poses no material risk of harmful interference to 6 GHz incumbent users,” they said: “The draft Order’s mandate to implement a technology-neutral listen-before-talk requirement, when combined with low power restrictions and indoor-only use requirements, represents a ‘belt-and-suspenders’ approach to even further protect incumbent licensees.”

The industry-led multistakeholder group the order mentions, which will study technical and operational issues, and other technical issues, should “include a broad range of stakeholders from across the Wi-Fi ecosystem,” CTA told Office of Engineering and Technology staff. Be cautious on involving the FCC in the selection of security protocols for communications between automated frequency control systems and access points, CTA said: “Industry, as opposed to the FCC, may be best suited to develop these device security protocols.”

Approve power levels of 8 dBm/MHz radiated power spectral density, rather than the 5 dBm/MHz in the order, the Open Technology Institute encouraged aides to the commissioners other than Pai. “The ‘sporadic and bursty nature of Wi-Fi transmissions,’ which is inherent in the contention-based protocol the Commission mandates in this Order, makes the occurrence of harmful interference even less likely,” the group said. Eleven groups including American Commitment, the American Conservative Union, Institute for Policy Innovation and Market Institute said opening the band will benefit the economy. “The FCC will enable the deployment of next-generation Wi-Fi, which will transform this highly underutilized band of radio spectrum into one that is for wider and more efficient use,” they said.

Rethink its approach, electric utility Entergy asked the regulator. “Entergy’s 6 GHz wireless networks" operate and monitor "our electric transmission and distribution grid,” the company said: “Entergy has serious concerns that the proposed rules will cause debilitating interference.”