While the FCC is taking comments about how it should treat the superhigh spectrum bands, Apple is urging regulators to include more unlicensed spectrum bands in their plans.
It’s not asking for parity between licensed and unlicensed bands, but it says what’s currently been proposed far too heavily favors licensed technologies. One thing the commission could consider is permitting unlicensed technologies to share these superhigh bands with licensed services, according to Apple’s filing.
The commission already has proposed innovative sharing opportunities between fixed service, fixed satellite service (FSS) and unlicensed services in its Mid-Band Spectrum Notice of Inquiry, and such sharing mechanisms should be explored and implemented at the outset in the bands above 95 GHz, according to Apple.
The tech giant is also recommending that the commission establish larger unlicensed bandwidths. Thus far, the proposed unlicensed bands range from 1 gigahertz to 7.2 gigahertz wide—too narrow to enable optimal use of the type of technologies that are being developed today.
ETSI and the Electronic Communications Committee of the European Conference of Post and Telecommunications Administrations are working to advance new short-range radiodetermination applications that would operate between 120 GHz and 260 GHz and would require bandwidths of 20 gigahertz or more to function optimally. Existing forms of this kind of technology are central to various industries, including environmental protection, human safety and manufacturing, Apple said. Providing room to develop these technologies at higher frequencies with larger bandwidths has the potential to significantly improve the fidelity of these technologies, supporting applications that are feasible today, the company said.
Likewise, the ITU has started studying the use of spectrum between 275 GHz and 450 GHz for high-speed, short-range communications technologies, which would also depend on sufficient spectrum for very wide bandwidth operations.
“Therefore, while it is true that this spectrum is largely a ‘blank slate’ today, there are already concrete examples of likely uses for these bands that should be considered in the commission’s decision-making,” Apple stated.
Some commenters in the proceeding are advising the FCC not to move too fast on rules for the bands above 95 GHz because so much could change technology-wise and they don’t want to get stuck with rules based on old knowledge.
Apple said the FCC should avoid restrictive rules that would preclude the technologies that have begun to emerge and instead use known examples to inform its expectations about unknown future uses. “Prematurely restricting operations above 95 GHz—by, for example, creating only a few narrow unlicensed bands—without reliable information about the technical characteristics of future systems may also threaten future U.S. competitiveness in emerging wireless technologies,” the company said.