As the deadline for comments on the FCC’s midband spectrum consultation came, the US debate about these important airwaves heated up. An unprecedented variety of stakeholders and would-be operators is eyeing spectrum between 3.5 GHz and 6 GHz, but with very different agendas.
The regulator aims to get better use out of a portion of the C Band spectrum from 3.7 GHz to 4.2 GHz. Some players want a similar shared structure to the three-tiered CBRS scheme, proposed for the nearby 3.5 GHz band, to be expanded up to 4.2 GHz. This protects federal incumbents while supporting a licensed, priority access layer and an unlicensed, general access approach.
Others are opposed to the whole idea of opening the 3.7-4.2 GHz band for mobile broadband. The incumbent satellite community is against this, and only Intelsat has made slightly encouraging noises about being able to clear their use of it over time, given some compensation, for the good of all.
In a joint proposal, Intelsat and Intel are suggesting that the FCC allow co-primary terrestrial mobile operations in the 3.7-4.2 GHz band through commercial arrangements between MNOs and relevant fixed satellite service (FSS) operators. The latter group would work cooperatively to identify areas of the country where they could undertake the “complicated and costly” process of clearing portions of the band for terrestrial use.
Intelsat CEO Stephen Spengler said: “We as an industry have not seen an approach to co-frequency sharing that is feasible. We have been concerned on behalf of our business and our customers that we needed to make sure that a wise approach was taken.”
“To do that we have to make significant expenditures in facilities and relocation of services and potentially some satellite redesign work to achieve that, but we believe we can do that if we have this kind of clarity of approach and do this effort collaboratively with the satellite industry and the wireless industry. We think now is the time” to take a more creative and market-based approach, he said.
The FCC has pointed out that the users of this spectrum have been slowly evaporating over time, falling from 39,000 licenses in 1988 to under 13,000 by 1997 and still falling. However, comments to the press over the course of the week, put Intelsat in the role of a traitor to the satellite cause, reminding the FCC just how many ground stations and antennas were active in this segment.
The Notice of Inquiry from the FCC was issued in July, but comments are only published once the deadline for reply has passed. The FCC asked about three key areas of spectrum, from 3.7 GHz up to 24 GHz, isolating the 500 MHz from 3.7 GHz to 4.2GHz, which is used by satellite operators, some for broadband delivery, some from uplink to satellites.
The Notice also calls out the 500 MHz from 5.925 GHz to 6.425 GHz which is essentially paired with the 3.7 GHz to 4.2 GHz for satellite purposes (Earth to Space), as well as the 6.425 GHz up to 7.125 GHz, which are also under existing use for governmental radars.
The FCC reminded us all that it has been already active above the 24 GHz line, making 11 GHz available licensed and unlicensed for fixed and mobile use, as well as finding 18 GHz, above 95 GHz, for commercial use.
One lone voice, the MVDDS 5G coalition, provided comments on an entirely different chunk of spectrum, the Multichannel Video Distribution and Data Service, which has been in limbo for about 15 years. Essentially this is an orthogonal ground signal which does not interfere with the 12.2-12.7 GHz satellite-to-ground distribution signal used, for instance, for DTH satellite TV. It is only licensed for one-way video distribution, and a handful of experimental services are in operation, such as one called Sail Internet in Palo Alto, California, which uses MVDDS as the delivery part of an interactive high speed broadband signal for condominiums.
Most of this spectrum is now owned by Dish Networks, which bought much of it in bankruptcy proceedings, and has been asking the FCC for the past two years to change its use to allow mobile two-way communication. It used this Notice to make its point once again. If the FCC were to make a move on this spectrum, it would change the Dish stock valuation overnight, as it would own much of a 500 MHz slice of spectrum ready for 5G, but there remain interference concerns and such a move is unlikely.
Indeed, analysts at Jefferies believe Dish’s spectrum portfolio is undervalued by about 45%, making the company “the most compelling investment opportunity” in the telecom and cable/satellite markets.
“We believe Dish’s spectrum assets should continue to draw attention from top-wireless carriers due not only to the midband capacity advantages, but also the availability and speed to market,” analyst Mike McCormack wrote in an investor note.
“Importantly, Dish’s spectrum represents some of the deepest spectrum available for immediate deployment, as we expect the repurposing of the broadcaster spectrum (from the incentive auction) to be a lengthy process. Aside from Dish, there are few other spectrum assets potentially available on the secondary market … Dish’s ability for asymmetric downstream capacity furthers the value of the Dish portfolio.”
Dish has always said it needs an infrastructure partner to make a national roll-out cost-effective, though it is deploying NB-IoT in order to comply with FCC coverage mandates associated with some of its airwaves. McCormack believes the company could partner with AT&T. “With AT&T planning to touch all of its towers in the coming 18 to 24 months as part of its FirstNet contract, we believe they would make an ideal partner; Dish management also noted that any build would need to begin by late 2018.”
The wider community comments were virtually unanimous suggesting that the FCC goes straight to a Notice of Proposed Rulemaking to make at least 5.9 GHz to 7.125 GHz (some 1.25 GHz of spectrum) available for unlicensed use (for WiFi and 5G) and possibly other protocols too, such as Bluetooth and ZigBee.
WiFi community battles for unlicensed expansion in 6 GHz:
There was also rising pressure for more unlicensed spectrum. About 30 companies signed a filing which claimed that Part 15 (unlicensed) access is essential in the 6 GHz (5925-7125 MHz) band to meet demand for next generation wireless broadband services. Signatories included Apple, Cisco, Google, Facebook, Broadcom, Intel, Qualcomm and Hewlett-Packard Enterprise.
They propose that the FCC should establish four 6 GHz sub-bands, with different technical rules and interference protections in each one, depending on the nature of the incumbents in the frequencies.
The four sub-bands proposed are:
U-NII-5: 5925-6425 MHz
U-NII-6: 6425-6525 MHz
U-NII-7: 6525-6875 MHz
U-NII-8: 6875-7125 MHz
The IEEE, which governs the 802.11 standards that underpin WiFi, recently voted to extend coverage to the 6 GHz band. As this spectrum adjoins the 5 GHz unlicensed band, that would support wide, gigabit-capable channels, as standardized in the upcoming 802.11ax specifications, which aim to boost WiFi data rates in dense environments.
Christopher Szymanski, director of product marketing and government affairs at Broadcom, commented in the filing: “We’re under a spectrum crunch.” He argued that, although about 80% of smartphone traffic goes over WiFi, there has been no corresponding increase in the spectrum devoted to the technology. “We think it’s very important that the Commission move quickly. We’re not looking to displace, we’re looking to protect,” he added.
While not among the signatories, the WiFi Alliance has been making similar protestations. It claims that a recent decision by the US NTIA, foreclosing unlicensed operations in the 5.35-5.47 GHz (U-NII-2B) band, significantly disrupted WiFi industry plans to support growing demand in midband spectrum.
Of course, some MNOs want at least some of the 6 GHz band for licensed use. T-Mobile USA wrote that it “urges the Commission to consider making some or all of this band available for licensed mobile broadband use.” Ericsson added that the 6.425-7.125 GHz band would be a good complement to millimeter wave spectrum for licensed mobile use cases in densely populated areas, and for connected car applications.
By contrast Verizon, which holds microwave spectrum in the band, said the proximity of 6 GHz to the 5.15-5.35 GHz and 5.47-5.727 GHz bands makes it attractive for unlicensed use, and therefore the telco conditionally supports unlicensed use as long as there are rules that provide adequate protections to incumbents and future microwave deployments.
Rural telcos take interest in midband spectrum:
Among the companies seeking to conduct trials in midband spectrum is CenturyLink, which wants to use the 3.4-3.7 GHz fixed wireless band as a way to extend its wireline reach to rural areas.
The company, like other fixed broadband and cable providers, is also interested in how it might harness 5G in future to extend its reach and add wireless services, possibly without having to invest in spectrum. CEO Glen Post told investors during the Goldman Sachs Communacopia Conference last month the firm would be open to partnerships, including in 5G, to accelerate its rural roll-out. “On the wireless side, we want to partner with 5G providers and other wireless providers where we can bring higher speeds to customers at less costs,” Post said, views that are echoed by other rural-focused operators such as Frontier, Consolidated and Windstream.
Frontier is conducting tests of fixed wireless to address the broadband gaps in the ultra-rural areas which are covered by the FCC’s CAF-II funding program. It also joined Consolidated and Windstream in a joint FCC filing requesting flexible use of spectrum bands between 3.7 and 24 GHz. They said that these bands would “provide another key tool in the toolbox to reach the hardest to serve rural Americans”.