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24 GHz Concerns

Spectrum Horizons Order Seen Headed for Easy Approval, but Questions Expected

The draft report and order opening spectrum above 95 GHzfor new commercial technologies is expected to be approved 5-0 by commissioners Friday, with few if any tweaks, FCC and industry officials said. Many questions remain about the treatment of passive bands in the “spectrum horizons” order, and those concerns are likely to surface during the discussion Friday, the officials said. Other questions could be on spectrum policy and spectrum enforcement. House Science Committee leaders raised similar concerns about the 24 GHz auction that starts Thursday.

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Changes are unlikely on the horizons item because the R&O has been negotiated with NTIA. That agency didn't comment.

A particular focus is footnote US246 to the U.S. table of allocations, which protects passive users of spectrum. “No station shall be authorized to transmit in the following bands” the footnote states, then lists 23 bands, 10 of which are above 95 GHz. The issue already surfaced in the 24 GHz band, to be auctioned starting Thursday, government officials said. The issue is “amplified above 95 GHz because there are so many more passive allocations,” one official said.

Punctuating the 24 GHz concerns, House Science leaders sent letters to the FCC Wednesday seeking a delay in the auction. They cited concerns with Earth observation sensors used for weather and climate forecasting, which use adjacent spectrum. Legislators wrote the agency's five members.

The water vapor channel is critical to weather sensing, monitoring, forecasting, and warning, and understanding climate patterns,” said Chairwoman Eddie Bernice Johnson, D-Texas, and ranking member Frank Lucas, R-Okla., in a news release. “Any interferences with this channel would therefore seriously impact public safety.” The two emphasized they support 5G: “However, advancements in telecommunications should not come at the expense of the safety and security of the American people.”

Tomorrow’s 24 GHz auction is an important step towards securing American leadership in 5G,” an FCC spokesperson said Wednesday. “The FCC’s rules for this band went through the standard interagency coordination process, provide the necessary protection for other spectrum bands, and have been on the books since 2017. It is therefore perplexing to be asked to postpone this auction the day before it is going to start.” Other nations competing with the U.S. to be first to 5G “would undoubtedly be pleased” with a delay, but “the FCC will move forward as planned so that our nation can win the race to 5G,” the spokesperson said.

Meanwhile, similar issues are arising on the spectrum horizons order.

Everything here is tied to NTIA, so realistically, they can’t change anything without NTIA approval,” said consultant Michael Marcus, a former FCC engineer and longtime proponent of opening the bands above 95 GHz. “What we’re hoping is they will say, 'In the future, we will address A, B and C,'” Marcus told us. Most of the time that the FCC releases a first R&O, it at least tees up next steps, he said.

The mmWave Coalition group of companies and universities raised concerns on US246 and other issues in a March 5 filing in docket 18-21. The group urges “an alternative formulation of US246 to protect vital passive systems, without a bright-line ban on additional innovative uses of the spectrum that could be shown not to harm such passive operations.” The coalition warned “the impact of the US246 prohibitions above 95 GHz is much more severe than in lower spectrum” and “the opportunity cost associated with this total ban was not considered when this approach was chosen decades ago.” The coalition said the FCC instead should move toward a “transparent, performance-based protection goal” based on ITU recommendations for protection of passive systems. The group's members include Nokia, NYU Wireless and GlobalFoundries.

Josep Jornet, associate professor of electrical engineering at the State University of New York in Buffalo, also raised US246 concerns. "In current spectrum allocations, passive allocations have a negligible impact at lower bands but have a major impact” above 95 GHz, he said. Jornet said the university applied for an experimental license last year for lab tests using 220-260 GHz spectrum.

The initial license said no tests could be done at 226-231.5 or 252-252 GHz, Jornet said. “There was no dialogue between the applicant and FCC or NTIA before this license was issued with this condition.” Those frequencies are used for satellite-based sensing of atmospheric ozone, but “the only satellite presently taking such measurements was” in a non-geostationary orbit and "not even visible from our campus most of the day.” he said. In the end, the school got a second license with an attachment that specified it couldn’t transmit in the two bands when the NASA Aura satellite “is within horizon-to-horizon view of the testing location,” he said.