Perhaps not surprisingly, the latest round of comments in the FCC’s 6 GHz proceeding pits licensed spectrum interests against unlicensed and CTIA against a group of tech companies that includes Apple, Facebook and Google.
Last year, the FCC proposed rules to promote new opportunities for unlicensed use in portions of the 1200 megahertz of spectrum in the 5.925-7.125 GHz (6 GHz) band while ensuring that licensed services operating in the band continue to operate. Its Notice of Proposed Rulemaking (NPRM) (PDF) sought answers to a host of questions, including how an Automated Frequency Coordination (AFC) system would work. Reply comments were due earlier this week.
In its comments (PDF), CTIA noted that there is no licensed, flexible-use midband spectrum available above 3 GHz in the U.S.
“As such, CTIA believes there is no basis to designate the full 1.2 gigahertz of 6 GHz spectrum to unlicensed use,” the association said. “In light of evidence that substantial swaths of unlicensed spectrum lie nearly vacant, the Commission should adopt a balanced approach to the 6 GHz band, including a spectrum sharing regime for unlicensed operations in the lower portion of the 6 GHz band and a framework for licensed, flexible use services in the upper 6 GHz band.”
CTIA in its filing acknowledged that the group identified as the 6 GHz RLAN Group dismissed the notion of exclusive, flexible use licensing in the 6 GHz band, pointing to hurdles including identifying “a suitable destination band” and a “viable plan for compensating” incumbents. But CTIA said the national interest in 5G demands more thorough consideration. Plus, the commission and wireless industry have a long history of successfully repurposing spectrum.
Both CTIA and Ericsson observed that the 7.125-8.5 GHz band is one range of frequencies that could accommodate fixed service operations that are relocated out of the 6 GHz band. That band is currently allocated for federal use but is underutilized.
The RLAN Group, which includes Apple, Broadcom, Cisco Systems, Facebook, Google, Hewlett Packard Enterprise, Intel, Marvell Semiconductor, Microsoft, Qualcomm and Ruckus Networks, told the commission in its March 18 filing (PDF) that it should reject the efforts by CTIA and Ericsson to “upend” the commission’s proposed approach and displace federal users from the 7 GHz band, “somehow relocate 6 GHz incumbents to these new frequencies,” and auction a portion of the band. “This scheme is unworkable, unnecessary, and unsupported by other commenters,” the group said.
The RLAN Group goes even further, to say that neither CTIA nor Ericsson provide a concrete explanation of their plan.
“How will their proposed relocation occur? They do not offer any insights. What frequencies will displaced government systems use? There is no roadmap.”
For its part, the Wi-Fi Alliance argues that the record supports its request that the FCC adopt rules allowing unlicensed operations, including low-power, indoor-only devices, access to the entire 6 GHz band and allow standard-power operations in designated segments of the band subject to AFC.
“The need for additional spectrum capacity to meet the nation’s demand for Wi-Fi connectivity is acute and the 6 GHz band is uniquely able to satisfy that need,” Wi-Fi Alliance told the commission (PDF).