November 8, 2020 — The future of the spectrum industry relies on engineers developing processes to squeeze the most out of each band of spectrum, said a panel of spectrum policy experts contributing to a Federal Communications Bar Association webinar on Thursday.
“There is no new, greenfield spectrum, there’s a finite amount,” said Colleen King, vice president of regulatory affairs at Charter Communications. “It’s a hard problem for engineers to solve.”
To clarify some of the foundational scientific principles behind spectrum management, spectrum engineers Rob Kubik, senior director of public policy at Samsung Electronics and Ronald Williams, division chief of the office of engineering and technology at the FCC, were present and exposed audiences to the formulaic process behind managing government and commercial spectrum.
The pair detailed the importance of planning, calculating, and researching, when setting out to build a telecommunications network, or other spectrum-based system.
“There are a lot of factors to take into account when designing a system,” said Kubik, “you have to calculate equations for each aspect of planning.”
“Engineers have to calculate all these numbers and formulas to come up with a synopsis of what is happening in an area,” to determine how a system will operate, added Williams. For example, engineers must calculate how much wattage is needed to push a signal through space.
Further, spectrum technologists must estimate propagation loss, which determines signal levels at a given receiver.
“When towers communicate with a mobile phone, there will be a loss of signal, depending on a number of factors such as distance, obstacles, and angles,” said Williams, adding that “propagation loss is always the most contentious part of analyzing any FCC proceeding.”
Further, engineers must ensure that all entities cooperate with one another.
“You must be cognizant of the existing technology,” said Kubik. “When managing spectrum, you should utilize the spectrum data base which logs who owns what resources.”
The U.S. Table of Frequency Allocations from NTIA offers a visual of how spectrum is currently allocated between the executive and legislative branches. (The National Telecommunications and Information Administration is part of the U.S. Department of Commerce):
“You have to coexist with existing laws, pertaining to allocation of use,” reiterated Williams.
During the second panel, which followed the more technical overview, Jamison Prime, associate chief in the Office of Engineering and Technology at the FCC, critiqued the layout of the Frequency Allocation Table for being misleading, saying that AM bands look big on the chart, but in reality, they are short. Prime also noted that the table does not account for unlicensed spectrum.
“Not all spectrum is created equally,” said Prime, “different spectrum is suited for different technology.”
For example, the CBRS band, in the 3.5 Gigahertz band, is unique from other bands due to the Spectrum Access System it utilizes. SAS is a frequency coordination system which mediates between those using the band at the same time.
The CBRS band is a “complex exciting band, in a good spot of spectrum,” said King. “People are excited about this band. Four times the average number of bidders bid in the CBRS auction.”
“Mid-band spectrum provides the best of all possible worlds,” said Therese Jones, senior director of policy at the Satellite Industry Association. “That’s why there is so much work in the C-band currently. Engineers are clearing up spectrum which used to be used for satellite operations for terrestrial 5G use.”
“Geostationary satellite operators are switching to utilize higher frequency spectrum, which will hugely increase capacity,” said Jones, adding that the reengineering process is extremely difficult for engineers.
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.”
Companies Clash Over Spectrum Sharing in 12 GHz Spectrum Band
Satellite service provider Dish, which is open to 12 GHz for mobile, recently signed a network sharing deal with AT&T.
July 19, 2021—While some experts believe that the 12 GHz spectrum band is a natural space for 5G to expand into, others remain unconvinced that doing so would not interrupt incumbent usage.
Broadband Breakfast convened a panel of experts on July 14 as part of its Broadband Breakfast Live Online event on “Spectrum for 5G, LEOs and the Future of the 12 GigaHertz (GHz) Band.”
Though the 12 GHz band has been used up to this point for low-earth orbit satellite networks, there has recently been debate over converting some of the band for terrestrial mobile use—a move that has frustrated some incumbents who assert that terrestrial mobile use would interfere with satellite services.
Eric Graham, the director of government and regulatory engagement for satellite provider OneWeb, described the effort to expand usage of the 12 GHz band as uncertain at best, arguing that new mobile devices operating in the band would create harmful and unpredictable interference.
“We use a very low level of power in the [non-geostationary-satellite orbit, fixed-satellite service] world,” Graham explained. “By the time the satellite signal reaches Earth from 1,200 kilometers away, that signal is very weak, and a terrestrial mobile device—your smartphone or other device—will wipe out that signal to the user terminal.”
According to Graham, there was a consensus at the conclusion of the reply comment round on this issue at the FCC. “Everyone had agreed that it was impossible for terrestrial mobile to coexist with the incumbents.” He stated that it has only been within the last year that proponents of expanding access to the band “found a way to create a study that purports to support coexistence.”
The argument for flexible use
Not everyone was convinced of Graham’s position, however. Co-founder and CEO of RS Access Noah Campbell argued that coexistence is not only possible but is vital to 5G deployment in the U.S. RS Access penned the first technical feasibility study that they argue proves that the 12 GHz band could host both mobile terrestrial devices and satellite services.
Cambell pointed out that the 12 GHz band is unique because it represents a significant swath of spectrum (500 MHz), despite only being licensed for one way service.
“In the context of 2021’s technology landscape that is absolutely insane,” he said. “[The FCC] would never license a frequency that way ever again. So, these are antiquated rules that really do not make sense from a technology standpoint, and do not make sense from a usage standpoint.”
Jeffrey Blum shared Cambell’s assessment of the 12 GHz. As the executive vice president for external and legislative affairs for Dish Network, Blum indicated Dish’s willingness to work with incumbents in the band.
“We do not want to fight, we want to share,” he said. Dish itself is a 12 GHz incumbent and has been operating satellites in the band since 1995 for over eight-million subscribers.
“We would not want to do anything at all to jeopardize our eight-million subscribers. We are confident that [[non-geostationary-satellite orbit, direct broadcast satellite], and mobile terrestrial uses can coexist.”
In fact, on the day of the live event, Dish announced a 10-year, $5-billion network sharing deal with AT&T to bolster its fledgling 5G network, according to a regulatory filing.
The deal would see AT&T provide support for Dish’s Boost Mobile by providing it with voice and messaging services. To do this, AT&T would be able to use bands of spectrum to which Dish holds licenses—both for their own use and Boost Mobile’s.
If the rules are successfully changed by the FCC, this would include the 12 GHz band.
Dish was able to obtain mobile wireless assets as part of a regulatory deal to approve the T-Mobile-Sprint merger that was completed last year.
In June, Dish announced a deal with Dell Technologies to launch the 5G network based on open radio access network and cloud technologies. Dish began accepting sign-ups for its 5G network that month.
Blum also struck back against the press’s title of the “Battle of the Billionaires.” He stated that DISH does not view the situation that way, and that this effort should only be viewed as a method to update outdated rules.
He pointed to all the technological advancements that have been made since the rules were originally established and, coupled with the need for the U.S. to lead 5G deployment, “the importance of 5G and 5G leadership to our country is essential,” Blum said.
The FCC still must make a decision regarding the 12 GHz band. Though Acting Chairwoman Jessica Rosenworcel has historically been supportive of spectrum sharing initiatives, she has not yet publicly indicated whether she would support such an initiative in the 12 GHz band.
Our Broadband Breakfast Live Online events take place every Wednesday at 12 Noon ET. You can watch the July 14, 2021, event on this page. You can also PARTICIPATE in the current Broadband Breakfast Live Online event. REGISTER HERE.
Wednesday, July 14, 2021, 12 Noon ET — “Spectrum for 5G, Low-Earth Orbit Satellites and Sharing the 12 GigaHertz (GHz) Band”
The 12 GigaHertz (GHz) band of radio frequency spectrum has emerged as a flashpoint in the debate over 5G services versus satellite technologies. Proponents of spectrum sharing believe now is the time to open up the 12 GHz band for more intensive broadband uses. But some satellite services are very much opposed. And the Federal Communications Commission is currently considering the arguments. Come to the July 14 session of Broadband Breakfast for a roundtable discussion on the future of the 12 GHz band.
- Eric Graham, Director of Government and Regulatory Engagement for North America, OneWeb
- V. Noah Campbell, Co-founder and CEO, RS Access, LLC
- Jeffrey Blum, Executive Vice President, External and Legislative Affairs, DISH
- Other panelists have been invited
- Drew Clark (moderator), Editor and Publisher of Broadband Breakfast
Eric Graham joined OneWeb in 2019 and is the Director of Government and Regulatory Engagement for North America, with a focus primarily on the United States and Canada. Prior to joining OneWeb, Eric spent 12 years in the terrestrial telecommunications industry (wireless and fiber) as Senior Vice President for Strategic Relations with C Spire. He has appeared as a witness before several committees of the United States Senate and United States House of Representatives, participated in numerous Federal Communications Commission panels and working groups, and has been a delegate at meetings of various international standard setting groups around the world.
V. Noah Campbell founded RS Access in 2018 to acquire spectrum in the 12.2-12.7 GHz band in the United States and to operate wireless networks serving a wide variety of constituents throughout our markets, which comprise approximately 15% of the US population. RS Access’ service is designed to ensure that customers can affordably acquire MVDDS point-to-multipoint connections to augment existing network architectures. Campbell, a wireless industry entrepreneur, also founded Radio Spectrum Group, LLC and MSD Capital, L.P.
Jeff Blum serves as DISH’s Executive Vice President, External & Legislative Affairs, overseeing public policy, regulatory and government affairs in Washington, D.C. He has been with DISH since 2005. Before coming to DISH, Jeff was a partner at the Los Angeles firm of Davis Wright Tremaine, where his practice focused on copyright, First Amendment and anti-piracy litigation. He currently serves as Vice-Chairman of the Satellite Broadcasting and Communications Association (SBCA) as well as serving on the boards of INCOMPAS, the Computer & Communications Industry Association (CCIA) and the Broadband Internet Technical Advisory Group (BITAG).
Drew Clark, Editor and Publisher of Broadband Breakfast, also serves as Of Counsel to The CommLaw Group. He has helped fiber-based and fixed wireless providers negotiate telecom leases and fiber IRUs, litigate to operate in the public right of way, and argue regulatory classifications before federal and state authorities. In addition to representing public and private providers on broadband issues, Drew is actively involved in issues surrounding interconnected Voice-over-Internet-Protocol service, spectrum licenses, robocalling including STIR/SHAKEN, and the provision of video franchises and “over-the-top” copyrighted content.
- OneWeb’s 12 GHz Reply Comments to the FCC
- DISH’s 12 GHz Reply Comments to the FCC
- RS Access’ 12 GHz Reply Comments to the FCC
- 12 GHz for 5G’s Reply Comments to the FCC
- Valuing the 12 GHz Spectrum Band with Flexible Use Rights
- Assessment of Feasibility of Coexistence between NGSO FSS Earth Stations and 5G Operations in the 12.2 – 12.7 GHz Band
- Two New Studies Show a Win-Win in 12 GHz Band for Consumers and American 5G Leadership
- 5G for 12 GHz Coalition Calls on FCC to Act Swiftly on Record Showing Robust Engineering Data, Public Support for Unleashing 12 GHz Band for 5G
- Groundbreaking Study Shows 12 GHz Band Will Supercharge 5G Deployment
As with all Broadband Breakfast Live Online events, the FREE webcasts will take place at 12 Noon ET on Wednesday.
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