Satellite Interests Oppose Use of Lower 12 GHz Band for Fixed Wireless

SpaceX continues to oppose use of the lower 12 GHz for fixed wireless. “The Commission previously rejected proposals for high-powered fixed services in the 12 GHz band because of harms to consumers of satellite service,” SpaceX said, saying proponents have the responsibility to show the band can be safely shared. “Twenty years ago, the Commission clearly concluded that two-way fixed services could not coexist with satellite services in the band, and as such limited terrestrial licenses through a series of prophylactic rules designed to protect consumers of satellite services,” the company said.

Rather than reallocate the upper 12 GHz band to terrestrial services, expand satellite use of it to support the industry’s rapid growth, the Satellite Industry Association said. Outside the U.S., where there aren’t limits restricting the spectrum to gateways for non-geostationary orbit use or international systems for geostationary use, the upper 12 GHz band is used “much more extensively” for satellite services, it said. The FCC could make more intensive use of the spectrum by lifting those satellite restrictions, especially since there are no standards and no equipment ecosystem to support any near-term rollout of new terrestrial services in the band, it said. Intelsat, SES, Eutelsat, Hispasat and Ovzon echoed the call for lifting the satellite restrictions on the upper band. Intelsat has a pending application for a 216-satellite medium earth orbit constellation that would use the band (see 2111050001).

OneWeb warned that expanded licensed use of the lower 12 GHz band will cause significant interference to NGSO FSS deployments. It said that upper 12 GHz terrestrial operations should be subject to limits that will protect lower 12 GHz satellite receivers from adjacent band interference. Pointing to the protections the FCC required for terrestrial use of the C band, it said the distinctions between earth station deployments in the two bands "require more nuance than simply transferring an existing policy into a new band."

Citing its analysis showing terrestrial mobile emissions in the upper 12 GHz band will degrade its DBS receivers in the lower 12 GHz band, DirecTV urged further technical studies. Dish Network said it believes satellite and terrestrial service can coexist in the band, but the FCC can take an incremental step by allowing point-to-multipoint fixed service in the lower band. Doing so won’t cause harmful interference to incumbents, it said. Such an authorization coming before Dec. 1 would let states consider lower 12 GHz band fixed services in their broadband equity, access and deployment proposals to NTIA, it said. Saying the lower band also could be used for fixed wireless access on tribal lands, Dish said it would make up to 100 MHz of contiguous lower 12 GHz band spectrum available for free to tribal entities -- “a private sector initiative that will be a win-win for all sides.”

Microsoft sided with satellite interests opposing FWA in the band . “As the Commission has found, NGSO receivers are extremely sensitive to harmful interference from terrestrial users,” Microsoft said: “Very large separation distances are required to ensure that NGSO FSS systems are not undermined. This would effectively preclude new terrestrial outdoor operations in urban areas and other populated locations where ‘qualifying NGSO receivers’ have been deployed.” Sharing is unworkable because of the “very large exclusion zones” needed to protect satellite operations, the company said.

Proponents of terrestrial use of the lower 12 GHz urged the FCC to act.

The proceeding is “an exceedingly rare chance to add massive amounts of mid-band spectrum to the nation’s pipeline while also paving the way for new, American-controlled technology as 5G and 6G services become globally standardized,” said RS Access, a leading proponent of changing the rules for the lower 12 GHz. Currently, licensees operate under “archaic existing operating constraints dating from the pre-iPhone era,” the company said. RS Access noted the explosive growth of fixed-wireless access, limited in some cases by a lack of spectrum: “One need not look further than recent reporting from wireless carriers reflecting major gains in subscribers to FWA services.”

“Taking immediate action to modernize the rules in the 12.2 GHz band and make spectrum available for fixed wireless service offers the promise of reliable and affordable connectivity for U.S. consumers and increases the ability of the Commission to address the digital divide,” said Incompas, another leader of the 5G for 12 GHz Coalition.

The Competitive Carriers Association said the lower and upper bands “have strong potential for FWA use” by its members. “Such two-way fixed services leveraging 4G and 5G networks are of interest to most CCA members, and FWA service offerings are exhibiting strong growth in consumer demand in CCA member service areas as a competitive home broadband alternative,” CCA said.

Sharing Urged

Public interest groups, led by Public Knowledge and New America’s Open Technology Institute, urged sharing of the lower 12 GHz band, managed by a system modeled on citizens broadband radio service rules. They proposed a primary tier protecting incumbent satellite operations, a priority access tier allowing expanded FWA use and “a third tier of coordinated general authorized access on an opportunistic, non-interfering basis.” The public interest groups also urged giving tribal areas priority access to the band. “This proceeding provides an excellent opportunity for the Commission to take another innovative leap forward in spectrum management policy to fuel the nation’s wireless future,” they said.

The Wireless ISP Association called for sharing in the lower and upper bands. “Preserving the status quo through an over-reliance on exclusive-use licensing would perpetuate spectrum warehousing by keeping spectrum away from prospective users and consumers, especially in rural areas where it can be more challenging to deploy service and where the sparse population may discourage investment,” WISPA said: “The cost of maintaining an antiquated ‘no sharing’ model would be high -- consumers would continue to lack access to broadband services, congestion in other bands would continue to proliferate, and innovation would be stymied.”