LAS VEGAS, Nevada, October 18, 2019 – The Wireless Internet Service Provider Association annual conference opened here this week with optimism, a record turnout of more than 2,200 attendees, and lots of discussion about wireless radio frequencies.
The theme of this WISPAPALOOZA conference, “Spectrum of Possibilities,” plays off the fact that radio frequency spectrum seems to underlie just about every decision that these wireless internet service providers make.
And with two or three or three significant bands of spectrum under active negotiation by and with the Federal Communications Commission, merely keeping track of all the spectrum-related activity of concern to WISPs is no small task. This article aims to present a summary of these major spectrum matters.
As scrappy entrepreneurs that bring wireless broadband to many parts of the country that are ignored by big broadband providers, WISPs have a strong independent streak – and a traditional hesitancy to engage in the sort of Washington lobbying that is par-for-the-course for wireless spectrum.
“It is a great time to be a WISP,” association CEO Claude Aiken said Tuesday at the conference kick-off. “This is our time to shine, to show America our integral role in delivering new possibilities to our local communities.”
Aiken, who stepped into his leadership role at WISPA just over a year ago, noted important progress in how WISPs are treated by the FCC. “Policymakers and the marketplace are awakening to the possibility that through WISPs, bridging the digital divide could be achieved more quickly and cost-effectively than with the traditional players. That the WISP model of broadband deployment is undeniably potent and effective.”
WISPs role as providers of fixed broadband in rural America
Consider all the hype seen in the broadband word about the so-called “fifth generation,” or 5G, technology standard. It’s being promulgated by the “big four” (soon to be big three) wireless carriers: AT&T, Verizon, and a combined T-Mobile/Sprint.
These wireless giants provide “mobile” wireless service, meaning that you can get service with your cellular phone wherever you are. These much-discussed 5G standards generally pertain to newly emerging technologies for transmitting and receiving mobile wireless signals at significantly higher speeds and lower latencies. But the technologies currently available for these mobile services are nowhere near their marketplace hype.
Instead of offering mobile service, WISPs generally provide of “fixed” wireless, meaning that they transmit broadband signals from a tower to an internet device that stays in one location, such as a home broadband connection. Those services generally operate in different frequency bands than those of mobile broadband.
Nearly 2,000 WISPs serve six million Americans with broadband, often in hard-to-reach rural areas that traditional telecom players have chosen to ignore. These WISPs, including about 800 that are members of WISPA, generally employ fewer than 10 individuals, have been in business for about 15 years, and risk their own private capital to bring service to their customers.
Their vital role in bridging the rural digital divide is increasingly being recognized, including with a scheduled keynote appearance by Michelle Christian, the national director for rural affairs for the U.S. Small Business Administration.
WISPA members bullish about future spectrum prospects
Yet in spite of all the bull surrounding 5G, WISPA members are bullish about their future prospects.
Why? Because WISPs, which are frequently confronted with regulatory, capital, and local infrastructure challenges, are often adept at innovating connectivity solutions in the most unforgiving circumstances.
WISPs have traditionally made use of unlicensed spectrum, or spectrum that is available for anyone to use without charge. The most popular unlicensed bands are located at 900 MegaHertz (MHz), 2.4 GigaHertz (GHz), and 5 GHz on the spectrum dial. Because they use no-cost unlicensed spectrum, they are able to beam broadband to far-flung localities at prices that WISPA officials say are 15 percent of the cost to wire regions for fiber service.
But with spectrum being the scarce “fuel” for a WISP’s business, the unlicensed bands aren’t enough to keep up with growing demand. Hence the buzz and discussion at WISPALOOZA here centered on three specific spectrum proceedings in Washington.
The first of these is the Citizens’ Broadband Radio Service, which operates in the 3.5 GHz band, or specifically from 3550 MHz to 3700 MHz.
A second proceeding of key interest to WISPA members is the C-Band, or the segment of spectrum from 3.7 GHz to 4.2 GHz.
Most spectrum is classified as either licensed, meaning that it is effectively privately property, or unlicensed. But over the past decade or so, the FCC has trended toward a new model of spectrum sharing. Under this approach, advances in radiofrequency technology transmission permit a range of uses with the same spectrum.
Unlike the fully unlicensed bands in which most WISPs operate, both CBRS and the C-Band will be shared or “lightly licensed.” Additionally, these so-called “mid-band” services have capacity for higher broadband data transport without requiring the line-of-sight that is required in high-frequency transmissions.
That’s why the mid-band provides new opportunities for WISPs that have been heretofore lacking.
An unusual start to the CBRS, or Citizens Broadband Radio Service
What is now called CBRS is considered the 150 megahertz of spectrum being made available from 3550 MHz to 3700 MHz. The band brings together a weird range of different sorts of wireless uses: Defense Department radar systems, a so-called “Fixed Satellite Service” for space-to-earth radio stations, and now WISPs.
Beginning in 2005, the FCC revised its rules to open up the portion from 3650 MHz to 3700 MHz. Under the licensing scheme adopted at that time, the FCC issued an unlimited number of non-exclusive nationwide licenses for commercial use – provided that the WISP seeking to use the license registered their base station with a spectrum coordinator.
The registration was necessary to enable an FCC-designed spectrum coordinator to manage potential interference with the satellite-to-earth stations. The 8,000 WISPs currently using 3.65 GHz (which means the same thing as 3650 MHz) has provided the experimentation necessary for the FCC to take the next step in CBRS evolution in 2015.
Four years ago, the agency created rules for the shared use of 3550 MHz to 3700 MHz. There will be a three-part structure for the 150 megahertz worth of spectrum: (1) Incumbent users, which are largely Defense Department and satellite users; (2) a series of “Priority Access Licenses” that are going up for auction by the FCC on June 25, 2020; and the (3) General Authorized Access tier that will allow WISPs to operate throughout the 3500-3700 MHz band, so long as they do not cause harmful interference to incumbent users or to PAL licensees.
Advances is spectrum sharing have given the agency confidence that, through the intermediate role of a Spectrum Access System, harmful interference between the different sorts of uses can be avoided. On September 16, 2019, the agency announced five SAS administrators – Amdocs, CommScope, Federated Wireless, Google, and Sony – that will automatically detect transmissions from those Defense Department radar system, or from the earth-to-space stations, and tell WISPs to quickly switch frequencies.
The system of spectrum sharing has led to the launch of commercial services dubbed OnGo.
For WISPs, the promise of CBRS is that it allows them two separate bites at the apple. They’ve already been able to make use – without pay — of the General Authorized Access from 3650 MHz to 3700 MHz; soon, they’ll be able to do so in a wider band, from 3500 MHz to 3700 MHz.
But if WISPs find that area to be too crowded, they can make a bid in Auction 105 next June for a Priority Access License. The big debate here has been about the size of the license areas. WISPs want small geographic license areas, whereas the big three wireless carriers want large, metropolitan area license regions.
The 2015 FCC rules would have created PALs in each Census tract. Although the 2017 changes considered shifting to Partial Economic Areas, which are 178 times larger than Census tracts, FCC Chairman Ajit Pai compromised on county-sized license areas. However, the FCC is considering make them bigger again.
Each PAL will be a 10 megahertz channel within the 3550 MHz to 3650 MHz region. No more than seven PALs will be issued an any one county, and a licensee could aggregate up to four PAL channel within that county. This last rule is designed to keep any bidder – such as one of the big three carrier carriers – from dominating a particular county.
With 3,323 county-based license areas at 7 PALs each, 22,631 lots of spectrum will be up for auction in CBRS. Experts say that could raise $15.6 billion for the U.S. government.
C-Band, further in the future, will benefit from spectrum-sharing successes
While CBRS is a clear and present opportunity for WISPs, C-Band is a more distant but potentially equally providential dream.
The whole notion of centralizing this new opportunity for WISPs in the mid-band is that it provides the opportunity for mass-produced equipment using the global LTE standard for fixed wireless providers. And the spectrum-sharing successes at 3650 MHz provide the template for doing spectrum sharing in more bands.
The next opportunity is likely to be immediately above CBRS in the C-Band, which sits at 3.7 GHz to 4.2 GHz. WISPA and others asked the FCC to devote this band to spectrum sharing in 2017, and over the summer, they filed a study funded by Google and Microsoft which showed that reducing exclusion zones from 150 kilometers to 10 kilometers would be sufficient to protect fixed-satellite service earth stations from harmful interference.
That, in turn, could allow more than 80 million Americans to have new options for high-speed broadband. Although satellite providers and video programmers oppose the Google-Microsoft-WISPA proposal, the providers at WISPAPALOOZA were optimistic that time is on their side. Further success with CBRS will provide a framework for extending the spectrum-sharing model into the C-Band.
Other spectrum areas under discussion include the former Educational Broadband Service
Although there are many other spectrum bands under discussion – including a crowded 6 GHz band, a licensed 11 GHz band, and the lightly licensed “millimeter wave” band at 70/80/90 GHz – the mid-band opportunities generated the most buzz and interest.
In fact, the way that the CBRS and C-Band interact with another significant chunk of spectrum in the mid-band — the 2.5 GHz Educational Broadband Spectrum — creates an additional possibility. Specifically, the EBS is located from 2496 MHz to 2690 MHz. Here, the FCC has come under considerable criticism for taking the “educational” out of EBS.
But FCC defenders say that the number of educational institutions taking advantage of EBS licensing are really quite limited. In a separate action of the summer, the FCC has committed to auctioning off EBS spectrum before year-end 2020.
These 194 megahertz of spectrum that make up the EBS band have their original as television licenses, and typically operate in a circular area around a 35-mile radius from a center point. About half of the licenses across the country are unassigned, and they are primarily in rural areas.
Ironically enough, the biggest holder of EBS spectrum is the wireless carrier Sprint that is being subsumed into T-Mobile. Through lease agreements with educational institutions, Sprint holds about 90 percent of the 2,190 active EBS licenses.
The main item to be addressed by the FCC prior to the finalization of this auction is the so-called “priority window” that is being granted to native American tribes to make use of EBS spectrum.
Most WISPs haven’t begun to focus on opportunities in the 2.5 GHz band because of the tight time-frame surrounding the CBRS auction that is coming up in June 2020. But, paired together – and coupled with the C-Band opportunity a few years down the line – these mid-band options provide new fuel for the “Spectrum of Possibilities” that await the WISP industry.
About the author:
Drew Clark, the Editor and Publisher of BroadbandBreakfast.com, is a nationally-respected telecommunications attorney at The CommLaw Group. He has closely tracked the trends in and mechanics of digital infrastructure for 20 years, and has helped fiber-based and fixed wireless providers navigate coverage, identify markets, broker infrastructure, and operate in the public right of way. If you are interested in tracking legislative, judicial or regulatory developments impacting the regulation and regulatory status of broadband services in Congress and the states, contact Drew Clark at email@example.com.
House Democrats Introduce Bill to Free Up Mid-Band Spectrum for Auction, Flexible Use
The bill would ensure adequate mid-band spectrum is available for commercial use to expand broadband availability.
WASHINGTON, September 30, 2021 – Reps. Mike Doyle, D-Pennsylvania, and Doris Matsui, D-California, have introduced a bill that would free up new airwaves for wireless broadband use by the public, which the representatives claim would mean faster speeds and more responsive networks.
The Spectrum Innovation Act, unveiled Wednesday and referred to the House Committee on Energy and Commerce on which Doyle is the chairman, will “make available additional frequencies in the 3.1-3.45 GHz band for non-Federal use, shared Federal and non-Federal use, or a combination thereof, and for other purposes.”
The bill comes after Congressman Doyle told Broadband Breakfast last month that spectrum provisions in the Senate-passed infrastructure bill – which is slated to be voted on in the House on Thursday – deviated from the “traditional process” and that he planned to “look at that.”
Among the spectrum rules outlined in the infrastructure bill is the ability of federal officials to seek out spectrum frequencies for federal use, and to shovel money from the Spectrum Relocation Fund toward to the Defense Department for the “purpose of research and development, engineering studies, economic analysis, activities with respect to systems, or other planning activities.”
The affected spectrum in this case would be the 3.1 to 3.45 GigaHertz (GHz) band, a key mid-band series of radio frequencies that includes some federal users, that is the subject of this new bill.
“In addition to up to 200 megahertz of spectrum auctioned for mobile broadband, this bill will help usher in new, innovative wireless uses through opportunistic and other flexible spectrum uses,” Congressman Doyle said.
“For the United States to remain the pacesetter in wireless broadband, we must continue to ensure innovators have a reliable spectrum pipeline,” said congresswoman Matsui in a press release Wednesday.
“We stand at a pivotal moment in the development and deployment of next generation networks; the Spectrum Innovation Act will unleash the economic potential of this valuable mid-band spectrum and give us the tools necessary to meet the communications challenges of tomorrow,” she added.
The bill would require that an investigation be launched into even more frequencies within the bandwidth that could potentially be freed up and sold at auction.
A number of industry associations and public advocacy groups praised the bill.
“The Spectrum Innovation Act of 2021 will greatly benefit consumers by making a very large band of prime spectrum available to help fuel the world’s most robust 5G wireless ecosystem,” said Public Knowledge and the Open Technology Institute at New America in a joint statement.
“We commend Chairman Doyle and Representative Matsui for taking a holistic approach that recognizes the value of making spectrum available both by auction and through shared use by smaller broadband providers, schools, critical infrastructure and literally thousands of individual enterprises on a local basis. This is the policy framework for mid-band spectrum that is most likely to spur 5G competition and innovation, while also ensuring that critical military radar systems can continue to use the band without undue risk of harmful interference.”
The NCTA — Internet and Television Association and the Cellular Telecommunication and Internet Association also came out to voice support for the bill.
Dish Requests Temporary Authority to Use 600 MegaHertz Band Licenses for 5G Test in Las Vegas and Denver
Dish said it needs non-contiguous 600 MHz band licenses to test open-RAN 5G network in two markets.
WASHINGTON, September 9, 2021 – Dish Network is asking the Federal Communications Commission to grant it a temporary license to use 600 MegaHertz (MHz) spectrum band licenses owned by another licensee for 5G tests in Las Vegas and Denver.
Dish said in a Wednesday submission to the FCC that Bluewater Wireless II, the owner of the 600 MHz spectrum band in question, has consented to allow Dish to use the spectrum under a regime called a special temporary authority.
Dish said it requires Bluewater’s spectrum licenses in the two cities to test and validate equipment for its 5G broadband network, using open radio access network technologies. The company said it needs the licenses to test carrier aggregation, where using its own licenses would be insufficient, because the two spectrum blocks cannot be contiguous.
“DISH anticipates needing more low-band spectrum in some markets to meet customer demand in the future,” the company said in its submission. “When and if additional 600 MHz spectrum becomes available, either when the Commission auctions unassigned spectrum or through future partnerships, DISH plans to use carrier aggregation at the market level to combine multiple 600 MHz assets to add capacity and improve data throughput speeds.”
“Grant of this STA will deliver important public interest benefits,” the company added. “In particular, the STA will enable DISH to put to use certain spectrum licensed to Bluewater that is not yet deployed.”
The test will end no later than the end of this year and the spectrum will only be used for testing and not for commercial purposes, Bluewater added in a letter to the FCC consenting to the arrangement.
The Denver-based company said it completed its first fully open RAN-compliant network communication in December 2020.
Dish announced that it was taking sign-ups for its 5G service in June, with the first city to get its so-called Project Gene5is being Las Vegas, Nevada.
Dish secured mobile wireless assets in a deal that allowed T-Mobile to absorb Sprint and entered the market in 2020 with the purchase of Boost Mobile and Ting Mobile. Dish has been widely expected to deliver wireless service that would add competition back in after the acquisition of Sprint.
The company announced this month that it is also purchasing Gen Mobile, a pre-paid and low-cost mobile service company, through its Boost brand.
Earlier this year, Boost bundled its K Health telehealth service in with its mobile service.
SpaceX, Engineers Clash over Whether 12 GigaHertz Band Can Be Shared with 5G Operators
Competing submissions to the FCC show the friction over valuable mid-band spectrum.
August 10, 2021 – Research commissioned by RS Access showing the mid-band 12 GHz spectrum, a band used by satellite service providers, can be shared with 5G operations has elicited a scathing rebuke by SpaceX — and the engineering firm behind the study is responding in kind.
The FCC is currently studying the possible sharing of the band between satellite providers and mobile wireless carriers for 5G. Broadband Breakfast held a panel discussion in July, which included arguments for and against the spectrum’s flexible use. RS Access’ V. Noah Campbell mentioned the technical study in question during the session, by RKF Engineering Solutions, LLC.
In a filing to the Federal Communications Commission last week, however, SpaceX alleges RKF’s technical study is a “fatally flawed” analysis that washes over the interference consequences that will allegedly happen if the spectrum is shared with 5G operations.
To address interference concerns, the engineering study drew three main conclusions: low-earth orbit satellite user terminals, which SpaceX’s Starlink fleet uses, can reject 5G signals; technology used by mobile wireless networks will direct energy toward handsets, not satellite terminals; and 5G networks will be used largely in higher population areas, whereas Starlink will focus on low-density, largely rural, areas. It also said that without coordination, interference possibilities will affect less than one percent of next-generation satellite operator terminals.
But SpaceX said these conclusions assume that the 5G build-out will only occur in urban areas and limit the next-generation satellite service providers from operating in those areas. The company said while Starlink is “designed to optimize for rural areas initially, it will provide service in urban areas.” It also claims that there will be interference suffered by the satellite terminals on the ground to cause disruptions in service, and ultimately, thousands of customers could be impacted.
SpaceX notes that the $900 million it won in December from the FCC’s $9.2-billion Rural Digital Opportunity Fund – which is currently being reassessed due to complaints of possible overbuilding – backs the fact that urban coverage is part of its agenda.
The company said it has over half a million back orders in its first six months of beta testing its Starlink service with only a third of its LEO fleet deployed (it has over 1,400 satellites launched). It also said it has applied to increase the number of licensed user terminals to 5 million.
RKF engineering firm responds
But RKF said in a filing to the FCC on August 9 that SpaceX misread the study to “find harmful interference where none may exist.” It said the study finds that a 5G network with zero coordination among users of the spectrum would impact fewer than one percent of next-generation satellite terminals. With coordination, such possible interference incidences would be reduced even further, it adds.
RKF, founded in 2001 and known by the last name initials of its founders Phil Rubin, Ted Kaplan, and Jeff Freedman, said this is the only engineering study of its kind in the FCC docket and no company has refuted it.
Other complaints in the Tuesday filing include RKF’s claim that its study did not say that the 5G build-out will only occur in urban areas, noting that the study surveyed less populated areas and found that demand is greatest in more densely populated areas. It also said its study does not preclude SpaceX from operating in any part of the country. It added that SpaceX operations in urban areas with 5G networks is “still readily achievable.”
“SpaceX’s inexplicable response to our rigorous, data-driven engineering study on coexistence in the 12 GHz band is so egregiously inaccurate that we as a firm felt it needed a direct response,” David Marshack, chief operating officer of RKF, said in a statement to Broadband Breakfast.
“Though our firm has often been called on to perform analyses in Commission proceedings, rarely has our firm engaged directly in the FCC docket on its own behalf. But in multiple Commission filings, SpaceX has impugned RKF’s integrity with baseless allegations and brazen misrepresentations that have made engaging on the record necessary.
“The engineering analysis clearly shows that coexistence between satellite and terrestrial 5G in the 12 GHz band is highly feasible,” the statement added. “Any claim to the contrary is a misunderstanding of our findings which show that a 5G network with zero coordination would impact fewer than one percent of NGSO terminals.”
Dish Network — the beneficiary of mobile wireless assets from the T-Mobile-Sprint merger and which is using said assets to develop its 5G network – said in a January filing that it hopes the commission would find a way to open the band for 5G use.
Since the other satellite-using C-band spectrum has already concluded its auction, the supply of critical mid-band spectrum for 5G is diminishing. Last month, RS Access filed a study by Roberson and Associates with the FCC claiming that the 12 GHz spectrum is “highly favorable for 5G, resembles lower-mid band frequencies, and can rapidly accelerate 5G deployment nationwide.”
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