Commenters Sharply Disagree on Wi-Fi Alliance's 6 GHz Waiver Request
Comments were sharply divided on a waiver request by the Wi-Fi Alliance of rules for the predictive propagation models that an automated frequency coordination system must employ in the 6 GHz band (see 2303210039). The alliance asked to be able to incorporate building entry loss (BEL) in its AFC model for specifically identifiable “composite devices” designed to operate in both low-power indoor (LPI) and standard power modes.
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Comments were posted Thursday in docket 23-107 and reflect the continuing divide over whether the FCC should further liberalize its rules for the band. In a Wednesday filing APCO opposed the waiver (see 2304050052). The Office of Engineering and Technology sought comment last month (see 2303210039).
“The Waiver Request completely and utterly fails to address the waiver criteria established by OET for the AFC approval process,” Southern Co. said. The request is also “premature as OET has not approved any” AFC equipment “or even established the final protocols for their operation,” the utility said: The alliance also hasn’t shown it will be able to guarantee that a standard power device “would indeed remain indoors or how it will manage the countless numbers of indoor operations that would not be subject to BEL attenuation losses.”
“Allowing the Wi-Fi Alliance’s AFC system to account for BEL for composite indoor-only devices is a dangerous approach to be taking at this time, particularly given the mountain of evidence that LPI devices are certain to cause interference and considering that composite indoor-only devices will operate at higher power than those LPI devices,” the Utilities Technology Council said. AT&T also urged denial, citing earlier comments in docket 21-352.
Many Wi-Fi advocates urged approval of the waiver request. Allowing AFC systems to account for BEL would “appropriately recognize” that indoor-only 6 GHz devices pose a reduced risk of harmful interference to fixed service links “compared to outdoor unlicensed 6 GHz operations,” NCTA said. AFC systems using BEL “will become increasingly important as composite devices become the deployment norm and the Commission grants AFC system operators final approval for commercial operation,” the group said.
“Our organizations strongly believe that the ultimate benefits of the 6 GHz band to consumers and the economy will largely hinge on the Commission adopting higher power levels for indoor use -- where 80 percent or more of the nation’s total mobile device data traffic flows over Wi-Fi -- a choice that will determine whether the typical household and small business can distribute the gigabit connectivity enabled by Wi-Fi 6E without the added cost and complexity of multiple routers or repeaters,” said the Public Interest Spectrum Coalition. The filing was signed by the Open Technology Institute at New America, Public Knowledge, Consumer Reports, the Center for Rural Strategies, the American Library Association, the Schools Health Libraries Broadband Coalition, the Benton Institute for Broadband & Society, Access Humboldt and X-Lab.
Tech companies said the request meets FCC requirements for a waiver because it presents “special circumstances” that “warrant a deviation from the general rule” and the “deviation will serve the public interest.” Accounting for BEL for indoor standard-power access points “will promote efficient use of the 6 GHz band, while protecting incumbent users from a significant risk of harmful interference,” said Broadcom, Cisco Systems, Google, Hewlett Packard Enterprise, Intel, Microsoft and Qualcomm. Several of the companies also filed separate comments.
Federated Wireless said granting the waiver wouldn't pose a risk to 6 GHz incumbents. Composite devices are “required to comply with all rule parts, including Product Form Factor requirements for LPI devices, and thereby, cannot operate outdoors,” Federated said: “AFC systems are capable of distinguishing such Composite Devices from other [standard power] devices by virtue of the device’s FCC certification authorization and can, therefore, selectively apply BEL to determine permitted power levels for 6 GHz devices certified as Composite Devices.”