No doubt, the wireless industry is ready to celebrate the Senate committee on Commerce, Science and Transportation's approval of the Mobile Now Act, which is designed to boost the development of 5G by making more spectrum available for commercial use and reducing red tape for building networks.
That's a big win, and FCC commissioners yesterday praised the senators' work to make more federal spectrum available for private use when they appeared at a Senate committee hearing. But the FCC still has a lot of work ahead in the millimeter wave space. After perusing some of the comments the FCC received on its Notice of Proposed Rulemaking (NPRM) for spectrum bands above 24 GHz -- which henceforth shall be referred to as the "Spectrum Frontiers" rulemaking -- I feel compelled to contribute my own informal "amicus brief" to the process.
Clearly, the commissioners and their staff will have to balance a lot of interests in order to come up with a workable set of solutions for this high-band spectrum. No doubt, they will be able to accomplish this. Chairman Tom Wheeler has promised the proceeding will be completed this summer, and if he's able to pull off the crazy-sounding 600 MHz incentive auction/reverse auction, this Spectrum Frontiers rulemaking should be a breeze.
Meanwhile, here's some food for thought.
I. Introduction and Summary
Last year, the FCC kicked off its NPRM, proposing new flexible use service rules in the 28 GHz, 37 GHz, 39 GHz and 64-71 GHz bands. Comments on the NPRM were due last month, and plenty rolled in. Pretty much everybody applauds the commission for taking steps to make more of this high-bandwidth spectrum available. There was a time, even a few short years ago, when skeptics didn't think millimeter band spectrum would be worth much to wireless operators. Researchers at places like NYU Wireless proved them wrong, and now U.S. operators are talking about how they need low, middle and high band spectrum. Any spectrum at all, pretty much, anywhere.
II. The record shows the carriers are at odds with entities like Google, Microsoft, the Open Technology Institute at New America, Public Knowledge and Federated Wireless, so there's that.
These parties are pushing for a Spectrum Access System (SAS) or similar mechanism in the 37 GHz band. But the biggest U.S. wireless carriers and CTIA really don't like the idea of handling millimeter wave spectrum, especially in the 37 GHz band, like it's being handled at 3.5 GHz. They say the SAS is an untested concept. CTIA opposes the adoption of any "use it or share it" requirements, and companies like AT&T say the FCC should resist calls to overly complicate the proceeding with "burdensome and untested" licensing approaches. Imposing an interoperability mandate, for example, would only stifle innovation and increase costs, according to AT&T.
Naturally, wireless carriers say the FCC should apply the same licensing paradigm, covering large geographic areas, to mobile services in the mmWave bands that it historically applied to other mobile spectrum bands. Others, like O3b, believe such an approach would deter innovation, throttle investment and leave spectrum unused in vast areas of the country. (See how the "innovation" argument gets applied by both sides?)
III. Satellite companies do not want to see mobile operations authorized in the 28 GHz band.
The 28 GHz band is one that some commissioners are pushing for the U.S. to pursue for 5G sooner rather than later. But companies like O3b and Boeing are arguing that the best approach would be to decline the authorization of mobile operations in the 28 GHz band and identify other mmWave bands for "green field" mobile deployments. Ob3 argues that if the FCC does authorize 5G mobile operations in the 28 GHz band, those operations should be secondary to existing and future site-licensed fixed satellite service (FSS) earth stations and to the fixed service.
The point is, the FCC will need to balance the needs of a lot of different stakeholders. We haven't even talked about Sprint's concerns with the proposed 47 dBuV/m field strength limit at the geographic border of the licensing area and the formula for converting field strength to power (it's P(dBm) = E(dBuV/m) + G(dBi) – 20 Log F (MHz) – 77.2.) But that's a problem for another day.--Monica