Need for Unlicensed vs. Exclusive-Use Spectrum Debated in IoT Comments
Commenters debated the need for more unlicensed versus licensed spectrum to promote the IoT, in comments posted Tuesday in response to an FCC notice of inquiry, in docket 21-353. Commissioners approved a broad NOI 4-0 last summer, looking at the broader spectrum needs of the IoT (see 2110010046). Multiple satellite operators offering or planning to offer IoT service argued against additional spectrum being allocated specifically for satellite IoT, instead saying there should be access to sufficient spectrum for satellite services overall.
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Making more exclusive-use spectrum available will best promote the IoT, said CTIA. “Develop a strategy to identify low-, mid-, and high-band spectrum for wireless deployments utilizing the highly successful flexible-use licensing model,” the group urged. Even with the 3 GHz spectrum the FCC is making available, the U.S. won’t be on “equal footing” with other countries on spectrum for 5G, CTIA said: With all the bands recently offered by the FCC “there is no near-term need for the Commission to dedicate additional spectrum for unlicensed or shared uses.”
Ericsson agreed industry needs more licensed spectrum to promote near-term expansion. “Without spectrum, IoT applications cannot grow,” the company said: “Additional licensed spectrum in the mid-band will be a key in the growth and support of IoT use cases. … Flexible use allows the market to respond to changing priorities or new developments without reallocating spectrum.”
The Competitive Carriers Association said both unlicensed and licensed spectrum is needed. CCA agreed flexible use rules are critical.
NCTA urged the FCC to make more unlicensed airwaves available in the 7 GHz band and shared spectrum in the lower 3 GHz. “Because unlicensed spectrum is open to everyone, subject to interference guardrails to protect other shared users from harmful interference, unlicensed innovators have strong incentives to develop and implement technologies that do not interfere with others and allow for large numbers of devices to share the same frequencies,” NCTA said.
Address remaining issues in key unlicensed bands, especially 5.9 and 6 GHz, the Wi-Fi Alliance commented. “Permitting very low power operations” at 6 GHz “will drive more portable connectivity and innovation,” the alliance said: Also allow “higher power spectral density for low power indoor operations; standard power access points to be used for mobile applications and at a higher power when used in fixed point-to-point applications; and direct client-to-client device communications indoors.”
The IoT is exploding and needs more exclusively licensed and shared spectrum, said Qualcomm. “Fully cleared spectrum that can be exclusively licensed for mobile broadband use will remain the gold standard because of the highly reliable service level it allows spectrum licensees to provide to consumers,” but some bands can only be shared, Qualcomm said: No spectrum should be allocated just for the IoT.
Intel supports “general-purpose flexible-use spectrum allocations for both licensed and unlicensed use.” No one band will fit all needs, the company said. “The spectrum requirements of any wireless system are directly related to its target technical performance requirements (e.g. throughput and latency) in addition to its radio interface design capabilities,” Intel said: “Given the wide range of IoT use cases and their corresponding technical performance targets, it is clear that the spectrum requirements of various use cases can be vastly different.”
"The anticipated growth of the IoT industry cannot be accommodated with the existing spectrum allocations," Kepler said. It urged evaluation and modernization of current spectrum restrictions that keep out many incoming operators and allowing the use of existing mobile satellite service spectrum for IoT. It said rather than restricting some MSS bands to time-division multiple access and code-division multiple access, there should be use by narrowband IoT. It said annual regulatory fees faced by IoT non-geosationary orbit operators also are a barrier to new entrants. Fleet Space Technologies backs repurposing five frequency bands crossing UHF and the S band to help solve the spectrum crunch IoT operators are facing, but such allocations should be for MSS generally and not just IoT, it said. Those bands are 454-456 MHz, 459-460 MHz, 2000-2020 MHz, 2021-2025 MHz and 2180-2200 MHz, it said.
Rather than IoT-centric spectrum allocations, the FCC should look at existing allocations and ax restrictions that would bar use of commercial and unlicensed spectrum for IoT and enable allocating additional spectrum at the radio service level to support IoT, EchoStar/Hughes said. Allocations of new spectrum for satellite and terrestrial wireless services should ensure that permitted uses are broad enough to encompass IoT, it said. OneWeb said the FCC should consider a rulemaking about how to allow IoT downlinks in unlicensed frequency bands because low-frequency bands would help allow less-expensive IoT devices.
Any spectrum allocated for satellite services needs to be handled on a service-neutral basis, rather than be allocated for satellite IoT alone, said Iridium. Eutelsat urged making spectrum available for satellite IoT in both licensed and unlicensed bands globally. It said the FCC also should assure frequency bands being used both by satellite and terrestrially for IoT are harmonized to make compatibility easier. Also against designating specific bands for IoT was Omnispace. Inmarsat said the FCC needs to protect use of the L band for satellite IoT.