Dish Network may control the lion’s share of the 12.2-12.7 GHz spectrum, but it’s the second largest holder of the spectrum that’s knocking on the FCC’s doors, urging the U.S. to consider unleashing 500 megahertz of contiguous mid-band spectrum for 5G.
Granted, the 12 GHz band wasn’t always considered mid-band spectrum, the definition of which has shifted in recent years as operators started using millimeter wave, or high-band, spectrum for 5G. But the government itself has referred to it as mid-band spectrum, so it’s not that big of a stretch, according to V. Noah Campbell, founder of RS Access, which holds about 15% of the spectrum.
Campbell and his associates paid a visit to the Federal Communications Commission (FCC) in early October (PDF) and met with FCC Wireless Telecommunications Bureau staff at Mobile World Congress Los Angeles last month to discuss the 5G opportunity for 12 GHz (PDF).
“I think this could be the next iteration of the C-band, but in a lot of ways, it’s a lot easier,” Campbell told Fierce Wireless. That’s because there are only a few stakeholders and terrestrial licenses are already there.
RS Access’ acquisition of the 12 GHz band spectrum stems from a relationship with MSD Capital, a private investment firm established in 1998 to exclusively manage the assets of Dell Technologies CEO Michael Dell and his family. MDS America, which is no relation to MSD Capital, acquired 80 licenses back in the 2004-2005 timeframe. RS Access, with backing from MSD Capital, entered into a spectrum lease and related asset purchase agreement with MDS America in 2018.
So far, RS Access has deployed 300 links across 60 active markets, and it has a wide variety of customers, according to Campbell. Its primary vendor is Cambridge Broadband Networks Ltd. (CBNL). But like the MVDDS Coalition of which Dish is a part, RS Access is lobbying for rule changes to allow for two-way, mobile communications in the band. The coalition, representing multichannel video and data distribution service (MVDDS) stakeholders, in 2016 filed a petition to get the FCC to initiate a rulemaking that would allow licensees to use the spectrum for 5G.
Granted, Dish has its hands full with the prospect of becoming a fourth facilities-based operator if the T-Mobile/Sprint deal transpires. Dish agreed not to sell its AWS-4 or 600 MHz spectrum holdings under certain conditions and will get 14 MHz of Sprint’s nationwide 800 MHz spectrum as part of that deal.
Fierce reached out to Dish to see if it had any comment related to the 12 GHz band and was directed to its most recent FCC filings on the issue.
Analysts from the investment firm New Street Research published a report over the weekend on the prospects for the 12 GHz band, saying they've always seen a reformed 12 GHz band as a good candidate for 5G in the U.S. However, it remains highly dependent on Dish's game plan. As the dominant MVDDS licensee, Dish's plans for 12 GHz terrestrial licenses will be the key determinant of the 12 GHz road map, they noted.
Push back from AT&T, OneWeb
Other current stakeholders in the band include AT&T for its DirecTV services and others. AT&T has argued that the MVDDS Coalition’s attempts to get mobile, two-way operations in the band would lead to significant harm to Direct Broadband Satellite (DBS) service, an assertion the MVDDS community says isn’t accurate. Satellite companies also have been opposed to changes in the band that would favor the MVDDS community.
OneWeb during a meeting with FCC Commissioner Geoffrey Starks last month (PDF) reiterated the importance of the 12.2-12.7 GHz band to certain satellite operators, saying the 12 GHz band is allocated to NGSO FSS operations on a co-primary basis and is critical for the provision of next-generation, NGSO-based connectivity services and applications to U.S. consumers.
Multiple NGSO operators, including OneWeb, have launched satellites and begun constructing network infrastructure that will use the 12 GHz band, which it says stands in stark contrast to licensees of MVDDS, who “continue to camouflage their failure to utilize the 12 GHz band in hopes of successfully reaping a spectrum windfall.”
RS Access has told the commission that it believes expansion in the band for incumbent 12 GHz and MVDDS licensees can be accomplished without harming other existing incumbent operations that have a co-primary status in the band. Intelligent network management principles, including the use of a Spectrum Access System (SAS) similar to those used in the Citizens Broadband Radio Service (CBRS) band, could be applied to the 12 GHz band.
According to RS Access, the 12 GHz band is the only frequency below 24 GHz that possesses the large channel bandwidths that wireless operators need to deliver on the promise of 5G performance. Such spectrum will be essential to support smart cities, transform industrial sectors and deliver new performance and capabilities to consumers and enterprise customers.
Based on what’s been circulated, the vendor community has been very receptive, according to Campbell. “When you think about what you could do with 500 megahertz of contiguous radio spectrum, you could create two 250 MHz channels, or you could create five 100 MHz channels,” he said. Today, the talk around C-band is doing 20 MHz channels. “We could do five 100 MHz channels.”
The FCC is currently challenged with how to come up with a solution for releasing C-band spectrum for 5G, and it’s under pressure to find mid-band spectrum and to find it fast. Whether the 12 GHz band meets its criteria is worth watching.
Article updated Nov. 4 with commentary from New Street Research.