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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.

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Dish President and CEO Erik Carlson

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.

Assistant Editor Ahmad Hathout has spent the last half-decade reporting on the Canadian telecommunications and media industries for leading publications. He started the scoop-driven news site downup.io to make Canadian telecom news more accessible and digestible. Follow him on Twitter @ackmet

Spectrum

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.

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SpaceX head Elon Musk

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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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.

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Screenshot from Broadband Breakfast Live Online episode on July 14.

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.

See “Satellite Operators and Broadband Entrants Vie for Primacy as FCC Debates the 12 GigaHertz Band

Panelists:

  • 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.

Panelist resources:

WATCH HERE, or on YouTubeTwitter and Facebook

As with all Broadband Breakfast Live Online events, the FREE webcasts will take place at 12 Noon ET on Wednesday.

SUBSCRIBE to the Broadband Breakfast YouTube channel. That way, you will be notified when events go live. Watch on YouTubeTwitter and Facebook

See a complete list of upcoming and past Broadband Breakfast Live Online events.

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Spectrum

Spectrum Decisions Becoming Increasingly Important for Future: FCC’s Simington

FCC Commissioner Nathan Simington said focus on spectrum decision will become increasingly important for digital success.

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FCC Commissioner Nathan Simington

July 13, 2021 — Carefully crafting a cohering spectrum policy is crucial in today’s digital marketplace, which is becoming increasingly reliant on wireless technology, Federal Communications Commissioner Nathan Simington said in a recent Hudson Institute event.

“Given that Wi-Fi, 5G and other wireless technology encompass an ever-increasing spot in the economy, I think it is imperative that we continue to get spectrum policy right by anticipating the needs of industry and consumers and the evolution of tech to the wireless space,” he said at the event, held in late June.

Simington stated his commitment to involving all relevant federal government agencies in discussions about future spectrum decisions.

“I feel that coordination with other executive branch agencies is key to a cohering national policy that allows for private industries to succeed without encumbering existing stakeholders in the executive branch,” he said.

Simington compared the process of future telecommunications regulation to the idea of attempting to build a skyscraper in New York instead of one in a rural area, making the point that working within the constraints of existing infrastructure is a new challenge.

“No matter where you want to build, you’re going to have to deal with prior efforts,” he said. “There’s a lot of history.”

In previous events with the Hudson Institute, Simington had spoken similarly about spectrum usage and its immense increase over the course of the pandemic, arguing that receiver standards that were adequate in the past may not be equipped for the future of radio spectrum.

More can be expected from Simington on this topic in the coming months; since being appointed in December of 2020, he has made spectrum policy a focus.

“Some of the most vital open issues the commission can address [are] physical network security, trade issues, spectrum policy and closing the digital divide,” he said.

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