Editor’s Corner—Spectrum bands above 24 GHz: lots of love for licenses

Monica Alleven editor's corner

Perusing the FCC’s 137-page document circulating on the spectrum bands above 24 GHz, it’s clear that not everyone is going to be pleased with how it turns out. Then again, it doesn’t look like there’s anything too shocking, either.

The document—and get ready for this—is titled “Second Report and Order, Second Further Notice of Proposed Rulemaking, Order on Reconsideration and Memorandum Opinion and Order.”

That'a a mouthful, but in it, the FCC spells out what commissioners are considering for their Nov. 16 open meeting. Basically, it will make available an additional 1,700 megahertz of high-band spectrum for flexible terrestrial wireless use in the 24 GHz and 47 GHz bands and maintain spectrum allocations adopted in the 28 GHz, 37 GHz and 39 GHz bands, with a few modifications to rules that were previously established.

There are a lot more details in the package. Clearly stated on the cover is the fact that it does not constitute any official action by the commission, but is offered in the interest of letting the public know what’s going on and the scope of the issues under consideration. So, some of it is probably going to change. But here are a few things that stand out, as proposed.

  • The document calls for adopting Partial Economic Areas (PEA) as the size for Upper Microwave Flexible Use Service (UMFUS) licenses for the 24 GHz band. The commission says it’s trying to harmonize the regulatory environment of the various millimeter wave (mmW) bands as much as possible, and using PEAs as the license area is consistent with existing rules for the 39 GHz band. The size of these licensed areas is often a point of contention between the bigger carriers that typically want larger licensed areas and smaller carriers or WISPs that want smaller areas, like those based on census tracts.
  • As posited, the FCC is declining to adopt a Part 96-style or Spectrum Access System (SAS)-based framework for the 24 GHz band. While some folks speculated that the SAS-based system that’s being done in the 3.5 GHz Citizens Broadband Radio Services (CBRS) band would be applied to other bands, that doesn’t appear to be happening, at least not yet. The thinking is that the 3.5 GHz band is unique because its incumbents are mostly federal (Navy) military ship-borne, high powered radar users and the 24 GHz and other bands don’t require such a complex coordination scheme. Plus, they’re probably waiting to see just how the so-called “experiment” turns out at 3.5.
  • The document also says it’s declining to adopt the proposals from Microsoft to authorize unlicensed use in the 24 GHz band, saying the band is being studied internationally for mobile use and it’s close to other licensed bands. “We have already made a further seven gigahertz of spectrum available for use by unlicensed devices in the 64-71 GHz band, and we are not convinced that additional unlicensed spectrum is needed in the mmW bands at this time,” the document stated.

    Side note: CTIA, the Competitive Carriers Association (CCA) and T-Mobile each requested that the FCC allocate the upper five gigahertz of the 64-71 GHz band for exclusive licensed use instead of allowing unlicensed operations throughout the entire band. But the commission is saying that it’s affirming the decision to authorize unlicensed operations across the band. “Petitioners have provided no explanation as to how they would make use of this band as a licensed band, and they mostly repeat arguments previously considered and rejected” by the commission, according to the document.
  • In the 47.2-48.2 GHz band, the plan again calls for using geographic area licensing using PEAs because the FCC figures that this will facilitate access to spectrum and faster deployment of service in the band. Again, it doesn’t see the need for a SAS kind of system, given the band doesn’t involve sharing among multiple classes of users. And it’s consistent with licensing for the 39 GHz band.
  • The FCC has decided thus far that it’s unnecessary to set preauction limits on the amount of spectrum an entity may acquire at auction in the bands proposed for flexible terrestrial wireless use. “In addition, we seek comment on whether there is a need to review mmW band holdings (24 GHz, 28 GHz, 37 GHz, 39 GHz and 47 GHz) on a case-by-case basis when applications for initial licenses are filed post-auction to ensure that, while providing flexibility to bidders and assigning licenses to those who value them most, the public interest benefits of having a threshold on mmW spectrum applicable to secondary market transactions are not rendered ineffective.”

Also of note: The commission isn’t playing the unlicensed vs. licensed spectrum amounts game. Regulators rejected comparisons in the record of the amount of spectrum used by unlicensed vs. licensed services, given that spectrum characteristics vary at different frequencies. Others agree that it’s not an apples-to-apples comparison.

At a WifiForward event in Washington, D.C., that was webcast this week, Harold Feld, senior vice president at Public Knowledge, said he thinks the Wi-Fi industry has done a lousy job in fighting for more unlicensed spectrum and used some analogies that sparked amusement.

“CTIA has this down to a science. They’ve got a great answer: ‘more.’ That’s always the answer,” to ask for more spectrum, he said. “It whitens your teeth, freshens your breath and solves all your connectivity problems.”

What the Wi-Fi industry needs is stronger industry advocates, according to Feld. Wi-Fi is now essential to everybody and the industry needs to say: “You know that spectrum crunch you’ve been talking about? Well, we’ve got one in unlicensed as well,” he said. “I am hoping that we are seeing a shift in this mentality, that we’re starting to see an appreciation for an unlicensed spectrum pipeline as well as a licensed spectrum pipeline.”

During the same panel session, Charla Rath, vice president of wireless policy development at Verizon, said Verizon supports what the commission is doing with the Priority Access License (PALs) in the 3.5 GHz band, but it’s also a big believer in the General Authorized Access (GAA) part of the band as being a way to use LTE Advanced with carrier aggregation to meet the needs for uplink and downlink video streaming. And there’s no need to wait for 5G—these are LTE Advanced techniques that can be deployed before 5G is fully commercialized in a significant way.  

So that’s it, a quick rundown on the draft being circulated ahead of the meeting later this month, plus a few random observations. It’s just skimming the surface, so take a look at the full document here (PDF). Happy reading. – Monica | @fiercewrlsstech