Boeing really, really doesn't want the FCC to adopt a maximum transmit power of 75 dBm per 100 MHz for 5G base stations, noting that it's substantially higher than the 62 dBm per 100 MHz that was proposed in the Notice of Proposed Rulemaking (NPRM).
"The record in this proceeding lacks sufficient justification for dramatically increasing the 5G base station transmit power from 62 dBm to 75 dBm, and Boeing questions whether any such justification could exist," the aerospace giant said in an ex parte filing (PDF). "The only reason for the proposed increase that is offered in a 'Fact Sheet' announcing the new limit is that it is 'based upon anticipated deployment needs.'
"No party, however, has provided a technical analysis showing that 5G systems would benefit appreciably from such a power increase. In fact, in the Spectrum Frontiers NPRM, the Commission evaluated a wide range of possible power levels for new terrestrial wireless services in the 28, 37 and 39 GHz bands and correctly concluded after careful consideration to propose a power limit of 62 dBm per 100 MHz for these bands," the company added.
Boeing argued that the power increase would provide little to no improvement to 5G performance, coverage or deployment costs and would undermine the policy objective of maximizing the potential 5G data system options for end users. Such a substantial power increase also would limit significantly the capabilities and strength of a satellite system operating in the 37/39 GHz band.
Boeing has proposed building a non-geostationary satellite orbit (NGSO) system that would operate in the fixed satellite service (FSS) in the V-band to provide low latency, very high data-rate broadband service throughout the United States and internationally. The proposed system could share the 37/39 GHz band with terrestrial 5G licensees. But permitting transmissions from 5G base stations to operate at 75 dBm would mean terrestrial 5G licensees would have the ability to effectively exclude the proposed NGSO FSS system, Boeing said.
However, the company said it's confident that the vast majority of its NGSO FSS earth station receivers would be able to withstand transmissions from 5G base stations operating at a maximum power limit of 62 dBm.
Boeing has said its NGSO system eventually would consist of a total constellation of 2,956 NGSO FSS satellites, but initially it will consist of 1,396 low earth orbit (LEO) satellites operating at an altitude of 1,200 kilometers.
In one of its ex parte filings this week, CTIA said that since the commission's Spectrum Frontiers NPRM came out, various parties have filed 44 applications for new or modified earth station terminals in the 27.5-28.35 GHz band. The organization pointed out that Boeing filed a petition in order to launch a satellite system in millimeter wave bands after the commission formally announced its intentions to consider new rules for the 37 and 40 GHz bands and other millimeter wave spectrum in the tentative agenda for its July open meeting.
CTIA submitted Google Earth images showing the number of satellite earth station locations prior to the Spectrum Frontiers NPRM and after the NPRM was released, illustrating significantly more applications since Oct. 22, 2015.
The association said that while the satellite industry has had decades to launch and deploy earth stations in the millimeter band spectrum, they're participating in an effective "gold rush" in terms of eleventh-hour FSS applications. Under the proposed framework, existing FSS operations would be afforded certain protections.
- see this Boeing filing (PDF)
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