Opening 12 GHz to 5G Brings Feasibility Claims

RSA filed its RKF Engineering Solutions study indicating 5G and NGSO FSS deployments in the band are "achievable in nearly all deployment scenarios -- even without coordination." It said RKF's modeling of 2.5 million SpaceX terminals found fewer than 1% nominally affected, and few if any of those would see service hurt. RSA filed a Brattle Group report indicating sharing without interference or seeing limited interference would result in up to $54.1 billion worth of mobile services in the band. NGSOs "have yet to provide meaningful commercial service," RSA said.

Satellite operators pointed to the importance of the 12 GHz band to their broadband plans. Some jabbed at RSA for not providing beforehand any study proving its claims that sharing between co-primary users is feasible. These operators argued for termination of the multichannel video and data distribution service (MVDDS) allocation in the 12 GHz band on the grounds terrestrial interests aren’t using it. None provided its own new technical analysis.

Undermining the current co-primary allocation for NGSO FSS or introducing terrestrial mobile services in the band “will jeopardize the extraordinary ability” of NGSO FSS to bring broadband to unserved and underserved parts of the U.S., said OneWeb. It said that it uses the 10.7-12.7 GHz range for downlinks and that the 12 GHz band is particularly unconstrained by fixed, point-to-point operations or the requirement to protect the radio astronomy service, while it represents only a small fraction of the high band spectrum available or expected to be available to 5G. Intelsat said that if the FCC moves from its status quo conclusion about co-frequency incompatibility, it first needs careful consideration of interference potential between 5G transmitters and satellite receivers.

The five years since MVDDS and satellite interests fought over two-way mobile broadband in 12 GHz “has decimated any possible public interest rationale for radically changing the 12 GHz regulatory framework,” SES said. Since then, satellite operators “have collectively invested billions ... in facilities that rely on the 12 GHz band,” while the FCC has made thousands of terrestrial megahertz available for 5G, it said.

The MVDDS allocation here “is far from the highest and best -- or even an average use -- of the spectrum,” SpaceX said, urging termination of MVDDS licenses. Despite its claims otherwise, MVDDS licensee Dish Network “is providing effectively no service” there, it said. “Best and highest use of this spectrum does not involve providing windfall profits to spectrum speculators.”

“Given recent technological developments in automated shared spectrum technology and services, it is now possible to enable true sharing of a spectrum band amongst several disparate services without the administrative difficulties associated with traditional coordination methods,” said Federated Wireless. The citizens broadband radio service shows that incumbents can be protected, Federated said.

Others said opening the “underutilized” 500 MHz between 12.2-12.7 GHz will promote 5G and Wi-Fi and help close the digital divide. They asked the FCC to authorize an unlicensed underlay for low-power, indoor use across the entire band. Licensed use should come with “aggressive” buildout obligations, they said. “Expanding non-interfering access in 12 GHz will help maximize the number of potential 5G broadband providers, particularly in rural areas, and increase competitive broadband offerings,” said New America’s Open Technology Institute, Public Knowledge, the Consumer Federation of America and others.

The Competitive Carriers Association said 12 GHz should be considered “high” mid-band spectrum important to 5G. CCA sought more study. “With knowledge of the location and operating parameters of the satellite receivers in need of protection, an automated sharing system can be designed and implemented to facilitate additional access to these frequencies,” the Dynamic Spectrum Alliance said. Many more satellite receivers are in 12 GHz than in the CBRS band, but “today’s automated sharing systems are fully scalable,” the alliance said.

Protection of direct broadcast satellite services “must be the guiding star,” said DirecTV owner AT&T. Two-way, terrestrial mobile services are “fundamentally incompatible with satellite services,” the carrier said: “Neither the [MVDDS 5G Coalition] nor its individual members have provided a legitimate or sufficiently comprehensive technical analysis to otherwise demonstrate that the proposed new terrestrial mobile services could generally coexist with DBS.”

Carefully consider satellite implications, said the U.S. Chamber Technology Engagement Center.