UTC Raises Concerns as FCC Conditionally Approves 6 GHz AFC Applications

The FCC Office of Engineering and Technology conditionally approved AFC systems proposed by Broadcom, Google, Comsearch, Sony Group, Kyrio, Key Bridge Wireless, Nokia Innovations, Federated Wireless, Wireless Broadband Alliance, the Wi-Fi Alliance, Qualcomm, Plume Design and Red Technologies, said a public notice in Thursday’s Daily Digest. All must now be tested, both in the lab and through public trials, following a streamlined process. Amdocs filed and later withdrew an application.

OET didn’t outline a timeline for testing. “OET will approve for commercial operations those AFC systems that successfully complete testing,” the notice said.

“American businesses and households rely on Wi-Fi for work, school, access to healthcare, and connecting with friends and family,” said FCC Chairwoman Jessica Rosenworcel: “We are moving forward on our plan to open doors for next generation, faster, better Wi-Fi -- including Wi-Fi 6E and laying the groundwork for Wi-Fi 7. This is good news and real progress.”

“How in the world did we get here?” asked David Hattey, consultant at Lockard & White, on the UTC webinar. “I’ve been working with the FCC for over 40 years, and I’ve never had a situation get to this level,” he said. The FCC has faced continuing pressure from the Wi-Fi industry to act on AFC, which it has “now done,” and to move forward to authorize higher-power indoor units indoors and very low-power use outdoors without AFC, and “that’s a little bit disturbing,” he said.

UTC and others made dozens of filings before the FCC’s 6 GHz order was approved in 2020, but the filings had little effect, Hattey said. Major companies submitted analyses to the FCC “that, based on history and the scale of these businesses, the FCC believed in,” he said: “We tried to refute these analyses, and fell on deaf ears. We did not make any progress at all.” The simulations were based on faulty inputs and algorithms, he said.

The Wi-Fi industry’s analysis remains a “black box,” Hattey said: “They never showed us the outputs, never showed us the algorithms. … There’s a set of analyses out there that we know are fundamentally wrong, that say there’s no issue here.”

Next Steps

UTC is working with the Department of Energy on neutral testing to validate testing by utilities that has raised interference concerns, said UTC General Counsel Brett Kilbourne. “Simulations are good in some contexts, but real-world tests are the gold standard,” he said. UTC is looking for “fall back” spectrum, possibly by seeking access to the 7 GHz band for links that need to move, he said. UTC is also working with a multistakeholder group, promoted by the FCC in the 6 GHz order, he said. “One of the key issues there is getting interference complaints resolved on a timely basis,” he said.

“UTC is just as hopeful as the FCC that AFC will actually work,” Kilbourne said: “Unfortunately hope is not a strategy.” Commenters on the applications “made really great points” but the FCC “just uniformly” dismissed them, noting the approvals were conditional, he said. The FCC didn't comment.

The AFC notice said the FCC decided to move forward despite concerns raised by various commenters on the applications filed in December (see 2112220070).

“We find that the information provided by the AFC applicants in their proposals and in their supplemental filings is sufficient to conclude that their proposed AFC systems will likely comply with the Commission’s rules,” the PN said: “We note that many of the requirements specified in our rules are straightforward to meet, such as the information the AFC systems are required to receive from standard-power devices, the length of time information will be retained, and the requirement to obtain technical information from the Commission’s licensing database on a daily basis.”

The FCC declined “to delay the conditional approval of the proposed AFC systems because of perceived insufficiencies in industry-developed test plans for standard-power devices,” the notice said: “Because the AFC system applicants are not manufacturers of standard-power devices, it is not within their purview to demonstrate how standard-power devices will comply with the Commission’s rules or describe how these devices will be tested; that function falls to the Commission’s equipment approval process.” The notice also dismissed security and other concerns.

In December, the U.S. Court of Appeals for the D.C. Circuit upheld the 2020 order in what has been seen as a big win for the FCC (see 2112280047).

“As expected, the commission again rejected the same sort of make-weight complaints by AT&T, Verizon and the utility industry that the D.C. circuit rejected last year,” said Michael Calabrese, director of the Wireless Future Program at New America. “The PN is welcome news for consumers and venues that will benefit from the huge boost in Wi-Fi capacity that next generation Wi-Fi will make possible, especially for schools, homes and businesses in underserved areas,” he said. Calabrese said the notice offers “a streamlined plan” for both lab and real-world testing, “which are the final hurdles that remain.”

“This is an important step in the process to authorize 6 GHz standard power unlicensed operations, which will unlock the full potential of Wi-Fi 6E and future Wi-Fi generations,” emailed Alex Roytblat, Wi-Fi Alliance vice president-worldwide regulatory affairs. “The FCC took another crucial step forward in making the economic and innovative potential of Wi-Fi 6E a reality, while laying the groundwork for Wi-Fi 7,” WifiForward said in a statement: “The 6 GHz band and the implementation of AFCs will unleash innumerable new use cases for the next generation of Wi-Fi.”