It’s hard to say the debate over the 12 GHz band is heating up, given it’s already been the subject of high-level jabs from SpaceX, Dish Network and others at loggerheads over how the spectrum should be used. But if a recent Zoom event is any indication, the debate is indeed ratcheting up.
Maybe it has something to do with the $81 billion the C-band auction raised. The 12 GHz band, once considered high on the cellular spectrum charts, is now being described as one of the best positioned mid-band spectrum bands potentially available for 5G. Granted, the C-band involved lower spectrum, in the 3.7 GHz band, but that was only 280 megahertz up for auction. The 12 GHz band represents a chance to bring a full 500-megahertz contiguous spectrum band to market for 5G.
The FCBA Foundation hosted a Zoom meeting on Thursday that included representatives from AT&T, Dish Network, RS Access and OneWeb, where panelists clashed over whether it’s possible for the band to be shared between satellite and terrestrial users. The FCC in January voted to issue a Notice of Proposed Rulemaking (NPRM) on the 12 GHz band, exploring whether rules may be changed to accommodate 5G services.
Dish is one of the original members behind the 2016 MVDDS 5G Coalition petition that asked the commission to consider new uses for the band and it’s supportive of the FCC’s NPRM. It is one of the main users of the 12 GHz band for its direct broadcast satellite (DBS) offering that serves millions of satellite TV subscribers who use it to watch video.
Dish also holds the greatest number of MVDDS licenses; it has 82 licenses. That gives Dish a unique perspective on the potential for sharing the band and using it to support 5G. “Dish believes there’s a path forward for sharing between DBS and terrestrial, flexible use,” said Alison Minea, senior counsel at Dish. “This is 500 megahertz of contiguous spectrum that’s far better in terms of propagation” than some other spectrum allocated for 5G.
Dish’s hope, at the end of this, is the FCC can find a way to allow two-way, terrestrial flexible operations in the 12 GHz band while protecting DBS. “We believe that this is a win-win outcome,” she said.
Alternative spectrum for NGSOs?
As for the satellite operators that are currently using the band for trials and demos, she said Dish wants to see them be successful and suggested there are other spectrum resources they can use.
“I would love to know what other band you think we could use,” said Ruth Pritchard-Kelly, senior advisor at OneWeb. “That is one of the biggest questions that the satellite industry has.”
OneWeb’s low earth orbit (LEO) strategy calls for providing last mile connectivity for mobile network operators to make sure they can connect everyone and that connection doesn’t have to be done solely with a terrestrial network, she said.
The satellite services are being prepared. “We’ve already started demos and trials,” she said, and by the end of 2022, the entire globe will be covered by SpaceX and OneWeb constellations. “I love engineers. They’re amazing. I do hope they figure out a way to share the spectrum, but as it stands now, certainly our opening position is you can’t share with a ubiquitous thing that is moving.”
Oh, yes you can share
RS Access holds 82 licenses in the MVDDS band; its frequency covers about 25% of the U.S. geography and about 16% of the U.S. population.
“This is a very unique resource,” said V. Noah Campbell, founder and CEO of RS Access. “It’s a huge amount of spectrum... It’s fairly lightly used.”
RS Access is not against non-geostationary orbit (NGSO) services, such as SpaceX’s Starlink, Amazon, or OneWeb. They will play a critical role in bridging the digital divide, he added.
As a result of the NPRM, RS Access is engaged in an intensive engineering analysis and its preliminary analysis shows sharing is feasible here. “I think we have creative solutions,” he said. The NPRM was announced on January 15, when the initial stage of the C-band auction closed with proceeds over $80 billion, and “there’s obviously a huge amount of demand… for mid-band spectrum.” The 12 GHz band is “very much like mid-band spectrum.”
RS Access has pointed out that both SpaceX and OneWeb were put on notice when they received authorization to use the spectrum that it could be used for something else in the future. “The Commission has repeatedly warned SpaceX and other NGSO FSS authorization recipients that it was considering the initiation of an NPRM on exactly this issue,” RS Access told the FCC last November. “Neither SpaceX nor OneWeb can claim to be surprised that the Commission could initiate an NPRM on this matter.”
Current state of usage
As for the current users of the spectrum, “this is our bread and butter,” Minea said. “This is how Dish began,” providing satellite TV. DBS is a business that it hopes to grow over time, she said, even though it is currently losing subscribers.
“Our engineering studies indicate there is a very viable plan for DBS to share with terrestrial flexible use,” she said. Engineering coordination measures will be required, but “all of this is doable.”
DirecTV is the biggest user of the band, and it uses the entire 500 MHz to support its subscribers, according to Raquel Noriega, director, Federal Regulatory at AT&T. “We certainly do not see an engineering path forward here” for sharing, she said.
(AT&T last month announced a deal with TPG Capital to sell a minority stake in its linear video businesses DirecTV, U-verse and AT&T TV. The new DirecTV company will be run by Bill Morrow, who once led Clearwire.)
Pritchard-Kelly said one of the things about satellites is “we can’t just switch from Ku to Ka." The satellite is in the sky for its lifetime, which can be 15 to 20 years. This is the kind of discussion that needs to go on for years to give engineers time to discover other bands, she added. “This is a highly used band for a service that at this time, has no alternative.”
Users and prospective users of the 12 GHz band will have a chance to tell the FCC what they think should be done. Initial comments in the NPRM are expected to be filed by April 7, with reply comments due May 7.