March 27, 2020
Refilling the Licensed Mid-band Fuel Tank .
It’s no secret that America needs more licensed mid-band spectrum to power the 5G economy over the next decade. Just this week, a new report said the U.S. needs to effectively double its licensed mid-band spectrum—above and beyond the C-band and 3.5 GHz—just to keep pace with leading countries, let alone lead the world.
The FCC has done a remarkable job getting us in a position with the 3.5 GHz and C-Band auctions to get 350 megahertz of spectrum to U.S. operators with no time to lose. We wish we could pause and celebrate those historic wins, but the world keeps moving the goalposts. We see countries like Japan (1000 megahertz) and South Korea (600 megahertz) pushing all of us to find more.
Before we move forward on giving away some of the only obvious near-term options to unlicensed, we need to quickly develop a holistic plan to keep up with global rivals to foster the 5G economy.
Finding What’s Next for Mid-Band.
Under Chairman Pai’s 5G FAST Plan, the FCC has worked diligently to deliver 350 megahertz of mid-band airwaves by moving forward with auctions of the 3.5 GHz and 3.7 GHz bands this year. This is a great accomplishment.
Our challenge is that the average amount of licensed mid-band spectrum in other leading nations is projected to exceed 660 megahertz in the next two years. We need a roadmap to effectively double the amount of licensed mid-band spectrum we have all worked so hard together to access this year.
Policymakers have really only two clear opportunities to refill that fuel tank right now: the lower 3 GHz band and the 6 GHz band. Because those two swaths of spectrum are the most likely near-term options, policymakers should view the bands as intertwined. A decision made in one band will have direct consequences in the other.
The Uphill Challenges in Lower 3 GHz.
Congress wisely directed NTIA to evaluate the feasibility of commercial use in the 3.1 to 3.55 GHz band. It is a band (particularly the upper portion) being used globally, and is a ripe target for future commercial use. We eagerly await the release of that report, which was due Monday.
While we appreciate the burden faced by NTIA and its sister agencies, we are losing precious time when it comes to exploiting the lower 3 GHz band for licensed use to keep up with the rest of the world. We certainly applaud the FCC for moving forward on what it can do to free up 250 megahertz of spectrum in that band; an active partner within the Executive Branch could make that a reality.
We are simply not making the progress on federal spectrum that other nations are today. The Pentagon recently indicated that it “needs that” spectrum and is only “willing to share it.” A preliminary NTIA report released in January similarly did not provide a clear path forward to future 5G services.
We need a real plan to make commercial access to the lower 3 GHz band a reality—and in a manner that makes sense for 5G operations. That means this key spectrum asset should look more like the C-band—and not 3.5 GHz—in terms of licensed, cleared spectrum and permitting full-power commercial operations. The goal should be to clear at least a portion of the band for full-power 5G operations to better serve rural and suburban areas in particular.
We need to be bolder when it comes to finding the means to move critical government users and clear spectrum—just like the rest of the world is doing. We are confident if everyone rolls up their sleeves, we can find win-win situations from government and commercial users as we have done for 30 years. Let’s do that … and soon. We can come out of this with stronger government and commercial systems.
The 6 GHz Hedge.
We look at mid-band spectrum from 3 GHz to 7 GHz with a global target in mind. That is the lens we bring to the 6 GHz conversation. 1,200 megahertz is so much spectrum: it’s more than four times the C-Band auction and more spectrum than wireless providers gained access to in its first thirty-plus years of existence.
Yet the FCC is poised to give away 1,200 megahertz of free access to 6 GHz to unlicensed interests next month. Given where we are right now on lower 3 GHz and the lack of readily available alternatives for future licensed spectrum, we think a more judicious tiered approach is warranted.
The 6 GHz band offers a unique opportunity for the U.S. to lead the world in next-gen Wi-Fi deployment. We fully support that as long as incumbents are protected. The key issue is how much and when. That is where the dispute lies right now.
Despite repeated attempts, Cable, Facebook and Google have failed to justify they need all 1,200 megahertz right now. We’ve shown how the studies put forth by Cable, Facebook, and Google use wildly different estimates of future spectrum demands in one scenario (36 GBs/person when asking for more spectrum) compared to another (2 GBs/person when attempting to rebut the real—and still unresolved—interference concerns). That’s an astonishing 1700% difference.
They also have failed to identify a single other nation giving away more than the lower half. Cable, Facebook, and Google’s own report (Quotient) says that the U.S. has 20% less demand for new unlicensed spectrum for Wi-Fi as compared to other nations. Yet they still ask for twice as much as other countries like France, Germany, Spain, Sweden, and the United Kingdom are considering.
Nor have they suggested the harm in giving access to 6 GHz in two tranches by moving forward on the first half now. The wireless industry has been pushing for at least consideration of licensing part of the 6 GHz band for the past three years. We simply don’t need to make a call on the whole band now.
A Mid-Band Plan.
Mid-band spectrum has become the backbone band of the world’s 5G spectrum strategy. The United States needs a plan for the next three years, and we think there should be four components of the FCC’s strategy.
- Auction the CBRS and C-Band spectrum this calendar year.
- Make the lower portion of 6 GHz band available for Wi-Fi—with effective interference protections in place—while exploring the opportunity to make the upper portion of the band available for licensed use as a potential alternative.
- Develop a concrete plan with the Administration and Congress with real deadlines on what’s next for licensed mid-band, including a meaningful plan to make the lower 3 GHz band available for commercial use on terms that will allow robust 5G deployments.
- The FCC should then revisit—well in advance of the 2025 timeline Cable, Facebook, and Google say they will be spectrum constrained—the top portion of the 6 GHz band within the context of that broader plan.
This a prudent approach to keep all options open for a balanced spectrum policy going forward.