The FCC continues to get mixed views on whether sharing between unlicensed and incumbent operations in the 6 gigahertz band can be accomplished without resulting in harmful interference to incumbents.
Twelve senators from both parties wrote the agency yesterday, urging it to conduct a “thorough and thoughtful review of the proposal to protect critically important incumbent users” – namely, critical infrastructure industry (CII) entities such as electric, water, and natural gas utilities.
But 35 advocates of unlicensed spectrum – including cable operators, wireless Internet service providers, tech and Internet companies, and public interest and educational advocates – urged the FCC in an ex parte filing yesterday to open up the 6 GHz band to sharing with incumbents, arguing that such a scheme is possible without resulting in harmful interference.
“As the Federal Communications Commission (FCC or Commission) reviews public comments on its Notice of Proposed Rulemaking to allow the use of unlicensed technologies to expand wireless broadband access in the 6 GHz spectrum band, we ask for your thorough and thoughtful review of the proposal to protect critically important incumbent users. We ask that you assure the continued reliability of these uses, and not allow unlicensed use of the band unless FCC rules ensure protection against harmful interference. to the microwave facilities that these industries depend on for critical services,” the senators said in their letter to FCC Chairman Ajit Pai.
“Since the FCC first proposed opening the band to unlicensed use in October 2018 [TR Daily, Oct. 23, 2018], we have heard from critical infrastructure industries (CII) of all kinds, including electric, water, and natural gas utilities. These entities are concerned that the proposal does not protect their mission-critical systems located in the band from harmful interference caused by unlicensed use,” the senators added. “As these entities provide critical, life-sustaining services, it is essential that the FCC protects these industries from harmful interference and continues to reserve the band for these licensed operations if the Commission cannot ensure such protection.”
The letter noted that the Energy Department recently weighed in at the FCC and the National Telecommunications and Information Administration, urging the Commission to consider other spectrum outside the 6 GHz band for unlicensed use and asking the FCC to provide “dedicated spectrum” to utilities (TR Daily, Sept. 6).
“Electric, water, and natural gas utilities use the 6 GHz band for mission-critical communications, including routine reliability monitoring, emergency response, storm restoration, and situational awareness,” the senators said in their letter. “The 6 GHz band is well-suited to provide utilities and other CII with the longdistance, high-speed communications these essential services require. Harmful interference to these systems reduces a utility's ability to respond to problems or abnormalities on their grids, reducing their situational awareness and potentially compromising reliability. If this band can no longer be relied upon for these functions, this would be akin to removing a tried and tested tool from a utility's toolbox to manage reliability and resilience of the grid.”
The senators continued, “Although the FCC has proposed a mitigation tool to protect these and other CII from harmful interference, this tool has not been tested and remains theoretical. Given the criticality of electricity, water, and natural gas services to our economy and lifestyles, it is bad policy to put these at risk.”
The senators said it is important to conduct “rigorous testing of the proposed mitigation measures before any final decision is made.” The agency also “should insist that any particular mitigation approach be submitted for certification to the FCC before it is allowed to operate,” they said.
Signing onto the letter were Sens. James E. Risch (R., Idaho), Mike Crapo (R., Idaho), Mazie K. Hirono (D., Hawaii), Joe Manchin III (D., W.Va.), David A. Perdue (R., Ga.), James M. Inhofe (R., Okla.), Kevin Cramer (R., N.D.), John Kennedy (R., La.), Shelley Moore Capito (R., W.Va.), James Lankford (R., Okla.), Dianne Feinstein (D., Calif.), and Angus S. King Jr. (I., Maine).
But unlicensed advocates urged the FCC to move ahead and permit unlicensed operations to share the band.
“The unlicensed community has been steadfastly working with technical experts and conducting detailed engineering analyses that demonstrate how coexistence between incumbent and new unlicensed users will work,” the entities said in the filing to Mr. Pai yesterday in ET docket 18-295 and GN docket 17-183. “These analyses include very-low-power (VLP) and low-power indoor (LPI) devices and use cases that will be deployed quickly, in addition to an Automated Frequency Control (AFC) system to ensure standard-power unlicensed devices do not cause harmful interference. As you stated in Congressional testimony on October 17, 2019, ‘…American consumers can have the best of both worlds. They can have electric utilities using the spectrum in a way that allows them to deliver power more efficiently, and they can have the benefit of unlicensed innovation’” (TR Daily, Oct. 17).
The filing continued, “Opening up the 6 GHz band for these unlicensed innovations will benefit every aspect of our economy. This next generation of super-fast Wi-Fi and 5G NR Unlicensed will usher in a new era of AR/VR consumer experiences, revolutionize our agricultural economy by powering precision farming, and enable the expansion of industrial IoT, which will be the backbone of our factories of the future. Moving forward and opening up the 6 GHz band is critical. It has been more than twenty years since new mid-band spectrum was made available for Wi-Fi and other unlicensed uses, causing a severe shortage for a wireless technology that handles 75% of mobile data traffic.
“We can have ‘the best of both worlds,’” the parties argued. “Over a year of deep engineering analysis makes it clear that coexistence can be enabled while maximizing the efficiency of the 6 GHz band and utilizing the productive potential of this spectrum to its highest potential. Our collective view is aligned with your statement to the Senate, ‘Let’s protect the incumbent users, but let’s also have our eyes on the future. And the future in many cases is dependent on Wi-Fi.’”
Among those to sign the letter were representatives of Charter Communications, Inc., Facebook, Inc., HP, Inc., Boingo Wireless, Inc., Cisco Systems, Inc., Google LLC, Intel Corp., Apple, Inc., Broadcom, Inc., the Consortium for School Networking, Hewlett Packard Enterprises, Microsoft Corp., the Schools, Health & Libraries Coalition, the Wireless Internet Service Providers Association, Qualcomm, Inc., Sony Electronics, the New America Foundation, and Public Knowledge.
Incumbents in the 6 GHz band – including commercial, public safety, and utility entities – have raised concerns about interference that will result from sharing the spectrum. They also have said that AFC systems need to be tested before critical operations rely on their use. And they have complained that unlicensed advocates have pulled back on how widespread AFC use should be. —Paul Kirby, [email protected]
MainStory: FCC Congress FederalNews SpectrumAllocation PublicSafety
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