Disagreements Remain in Reply Comments on 12.7 GHz NOI
Wireless carriers pressed the FCC to make the 12.7 MHz band available for exclusive-use licenses, but others continue to see it as potentially the next big sharing band, in reply comments posted Wednesday in docket 22-352. Band incumbents continue to raise concerns about their use of the spectrum. Replies were due Tuesday and largely tracked initial comments (see 2212130047). The FCC approved a notice of inquiry in October (see 2210270046).
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SpaceX said the upper 12 GHz band, which some refer to as 13 GHz, makes more sense as a target than the lower 12 GHz (see 2210130063). SpaceX noted it has spectrum in both bands. “Just as the Commission has moved quickly to explore the upper 12 GHz band, it should now complete this turn and finally shut down the insidious lower 12 GHz proceeding that is harming more Americans by the day,” SpaceX said: “While the record in this proceeding is still early in its development, it already shows that the Commission may be able to craft appropriate rules to share the band and protect adjacent bands.”
Dish Network said the upper band should be viewed as a “valuable complement” to the lower band. “Joining these two bands will supply more than one gigahertz of uninterrupted mid-band spectrum for high power two-way services, putting the United States in a leadership position for 5G and in the driver’s seat for 6G,” Dish said.
NAB said broadcasters must have access to at least part of the band. “Contrary to the unfounded assertions of some commenters, there are no readily available options for relocating all broadcaster operations -- and particularly broadcast mobile operations,” broadcasters said. “Stated plainly, if the Commission fails to preserve spectrum in this and other bands for broadcasters’ [electronic news-gathering] operations, the Commission will be making a conscious choice to reduce broadcasters’ ability to serve the public during times of crisis and frustrate the public’s ability to acquire information.”
The band is already used by satellites, and rule tweaks would mean more use, said Intelsat and SES Americom. “By contrast, terrestrial mobile use … would likely be slow and lackluster, given the lack of technical standards and prospects for global harmonization,” the satellite operators said: “Wireless industry commenters acknowledge the technical limitations of the 12.7 GHz band for terrestrial mobile use and agree with the Satellite Operators that the spectrum is more akin to the millimeter wave bands than true mid-band spectrum for terrestrial mobile operation.”
While not their first choice among candidate bands, carriers pressed for a focus on using the band for 5G and beyond.
“Clearing the 12.7 GHz band to the extent possible and making the spectrum available for licensed and high-powered use will provide the greatest potential for innovation and will aid the wireless industry in serving American consumers,” the Competitive Carriers Association said: “A licensing regime that promotes competition will encourage participation in the market by diverse carriers and promote spectrum access throughout the country, including in rural areas.”
“Allocating the 13 GHz band to unlicensed use or adopting a sharing mechanism comparable to the one employed in the 3.5 GHz band would inhibit innovation and investment in the band, as mobile broadband and other expanded services demand higher-power operations that make coexistence in a shared spectrum environment difficult,” said CTIA. UScellular urged the FCC to “maximize the utility of this largely unencumbered 550 megahertz of mid-band spectrum by authorizing terrestrial flexible-use operations in the 12.7 GHz band on an exclusive, geographic-area basis and offering licenses for this spectrum via competitive bidding.”
Clearing Possible
“Exclusive use of spectrum is possible in the 12.7 GHz band because non-federal incumbents can be relocated or accommodated through other mechanisms,” T-Mobile said: “Any federal operations that must remain in, or adjacent to, the 12.7 GHz band can be protected either through geographic exclusion zones and/or appropriate technical rules.”
The Wireless ISP Association sided with sharing as the best alternative. “Spectrum sharing techniques can unlock opportunities for all broadband providers -- mobile and fixed, large and small -- while protecting incumbent operations,” WISPA said: “For any portion of the band that the Commission ultimately decides to make available through competitive bidding, county-based licenses should be available to provide bidders, especially smaller companies, the flexibility to acquire ‘right-sized’ exclusive geographic areas that best fit their business models and targeted communities.”
“A sharing framework could greatly facilitate the Commission’s efforts to make more intensive and diverse use of the 12.7 GHz Band,” the Dynamic Spectrum Alliance said. “Despite arguments to the contrary from large mobile broadband service providers that prefer exclusive licensing that limits competition by restricting access to spectrum, the introduction of new licensing options supported by automated spectrum sharing technology has proven to be the best path to support the rapid deployment of new networks, competitive services, and innovative business models.”