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March 12, 2020

Cable, Google and Facebook’s Numbers Don’t Add Up .

Cable, Google and Facebook’s Numbers Don’t Add Up


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Doug Hyslop
Vice President of Technology and Spectrum Planning

It’s important that America leads in next-generation Wi-Fi development. We all agree on that. And to lead, we’ll need unlicensed spectrum in the 6 GHz band. We all agree on that as well.

Cable, Google and Facebook are demanding all 1200 megahertz in the 6 GHz band for free. That is twice the international consensus, and is more than four C-Band auctions worth of spectrum. It’s a lot.

When it comes time to justify that giant giveaway, that’s where the problems start. Instead of making a consistent, fact-based argument to support freeing up the entire 6 GHz band for Wi-Fi, they’ve generated reports that contradict each other.

In order to support taking the entire band, Cable, Google and Facebook tell us busy hour Wi-Fi data will grow to 36 GB per person based on a study from Quotient. That is remarkable growth: one person streaming 12 HD movies…all at the same time.

But then when they sit down to reassure policymakers that they can protect public safety and other existing users from interference, Cable, Google and Facebook provide a different study of future usage from RKF. Their message then: don’t worry about us interfering with 9-1-1 calls or broadcasters breaking news, Wi-Fi will only eat up a tiny 2 GB per person. You’ll barely notice us.

That’s an astonishing 1700% difference in future traffic.

So which is it? They can’t have it both ways. Do they need to better protect incumbents, or are they asking for more spectrum than they actually need?

The companies seeking such a windfall in spectrum access must answer those questions.

That isn’t the only fuzzy math going on in 6 GHz. Cable, Facebook and Google are also hoping policymakers turn a blind eye to the unlicensed spectrum made available by the FCC that they have simply chosen not to invest in.

In just the last few years the FCC has released roughly 30 gigahertz of new unlicensed spectrum. Yet, as they tell it, Cable, Facebook and Google haven’t gotten any new unlicensed spectrum in decades. Not exactly: Wi-Fi has simply chosen not to invest in any new bands in decades.

The 3.5 GHz CBRS band is a good example.

The Wi-Fi groups spent years steering the 3.5 GHz rules to support Wi-Fi. Indeed, the Wi-Fi Alliance applauded the FCC’s 3.5 rulemaking to “create additional unlicensed spectrum capacity…to support Wi-Fi technologies.”

As a result, Cable, Google and Facebook were given access to more than half that spectrum for free. How much of it do they plan to use with Wi-Fi? None of it.

Now, Cable, Google and Facebook have every right to decide where to invest, but you can’t claim you haven’t been fed in decades when you choose not to eat. If they are truly facing 36 GB per person of future traffic demand, it is hard to imagine foregoing even trying to leverage that 80 megahertz of mid-band spectrum. The wireless industry doesn’t have that luxury.

Fast forward to today, and Cable, Google and Facebook are telling us 600 megahertz in the 6 GHz band is not enough. In our view, freeing up the lower 600 megahertz of 6 GHz for unlicensed should be celebrated. The U.S. would be a runaway global leader and first mover on next-generation Wi-Fi. As long as incumbents are truly protected, that is a win-win-win scenario.

But Cable, Google and Facebook aren’t stopping there. They won’t settle for less than doubling that. This is contrary to international consensus and in the midst of a 5G mid-band licensed spectrum deficit. They’re demanding the full 1200 megahertz based on numbers that don’t add up.

We need to get this right. The math behind protecting incumbents and justifying 1200 megahertz don’t match, and that matters. Cable, Facebook and Google need to pick which math is right and update their proposal accordingly if they want the FCC to move forward.


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