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CTIA Sees Delay Attempt

Boeing Trying to Claw Back V-Band From FCC Spectrum Frontiers Plan

The 37.5-40 GHz bandwidth is in a growing tug of war between 5G proponents and satellite operators. While Boeing in a white paper is pushing for spectrum sharing with satellite services in the V-band, including 37.5-40 GHz, CTIA in an email to us questioned the company's "newfound interest in this spectrum," coming days after the FCC issued its spectrum frontiers NPRM white copy (see 1606240026). CTIA said the Boeing white paper is "merely their attempt to seek delay and elevated rights, rather than to provide service for Americans. We are confident the FCC will see through their eleventh-hour proposal intended to delay and will move forward quickly to make available the high band spectrum that fuels our 5G mobile leadership.”

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Boeing is asking the FCC for approval of a low earth orbit constellation of more than 2,900 satellites operating in V-band, including 37.5-40 GHz (see 1606230050). “It may be premature to adopt spectrum access rules” that could preclude satellite deployments using the 37.5-40 GHz band, Boeing said. Instead, it said, the FCC should consider a Further NPRM setting up spectrum access rules specifically for the millimeter wave band. The spectrum frontiers NPRM expected to be voted on at the FCC's July 14 meeting would have satellites operate on a secondary basis in the 28 and 37/39 GHz bands (see 1606240026).

"There will always be disagreements over the particulars of any spectrum sharing regime," emailed Information Technology and Innovation Foundation Telecommunications Policy Analyst Doug Brake to us. "The technical weeds are thick and slightly different assumptions see very different predictions. While the exact scope of licenses and technical rules are left unknown in the fact sheet, the important point is that compromise is within reach. This will put the United States on firm footing to lead in 5G."

The FCC “need not and should not be forced to make a choice between terrestrial 5G and satellite broadband services” in millimeter wave bands, Boeing said. It said such technologies as beam forming and phased-array antennas that make broadband millimeter wave systems possible also would allow 5G/satellite co-primary spectrum sharing workable.

In its white paper, Boeing painted its V-band sharing proposal as being an offspring of Chairman Tom Wheeler’s Satellite Leadership Dinner address in March in which he pushed for satellite and wireless joint plans for spectrum sharing in the upper bands (see 1603090057), with the company saying it “took this message to heart.” It also said the spectrum frontiers NPRM, with its focus on U.S. leadership in the global 5G market, gives short shrift to more competition in the broadband market -- a shortcoming that could be addressed by “ensuring that spectrum access rules in this and other [millimeter wave] bands enable the full implementation of satellite and terrestrial broadband offerings.”

Allowing receive-only user terminal operations in the 37.5-40 GHz band would have "de minimis impact to future 5G operations," Boeing said. Terrestrial wireless interests have pegged the 28 GHz band as a priority of initial 5G deployment, but the record "is neither complete nor clear" for terrestrial systems' designs on 37.5-40 GHz band, Boeing said. The company said spectrum sharing considerations are considerably different in satellite earth station uplink bands, like 28 GHz, than in downlink bands like the millimeter wave bands.

The company said co-primary sharing of V-band by satellite and terrestrial 5G can be done if the FCC first removes its ban on receive-only satellite user terminals in the band and lets satellites downlink in the 37.5-40 GHz band at the power flux density levels already adopted by the ITU for this spectrum, dropping the tighter limits the U.S. goes by. It said the FCC should adopt "certain reasonable operating provisions ... to govern 5G deployment," including base station power limits, disclosure of base station locations, use of power control and sidelobe isolation/beamforming requirements.

The 37/39 GHz bands, as well as 28 GHz, "are critical" to satellite operators needing to meet broadband needs, ViaSat CEO Mark Dankberg told Commissioners Mike O'Rielly, Ajit Pai, Jessica Rosenworcel and Mignon Clyburn or their aides and FCC staff including Office of Engineering and Technology Chief Julius Knapp in a series of meetings, said ex parte filings (see here, here, here, here and here) in docket 14-177 posted Tuesday. According to the company, Dankberg said the satellite industry needs spectrum sharing that would let 5G and satellite "develop simultaneously." The company sought to require satellite receivers using the 28 GHz spectrum be protected from aggregate 5G uplink interference. It said ViaSat-2 and -3 gateways should be allowed continued deployment on a protected basis, and that 37/39 GHz receive earth stations be allowed "robust deployment" and permission for 28 GHz user terminals to transmit without interference when 5G isn't operating nearby.

There have been "a rush of opportunistic ... earth station filings" with the FCC in recent months, jeopardizing the primary rights upper microwave flexible use (UMFU) licensees would receive, CTIA said in a filing posted Wednesday in docket 14-177. It said that since the release date of the FCC's spectrum frontiers NPRM, there have been 44 applications for new or modified earth station terminals in the 27.5-28.35 GHz band -- a total filed "over the course of many years" before the NPRM. The FCC's extending FSS "operation rights" only to licensed FSS incumbents or those that had pending applications as of the date of the spectrum frontiers NPRM adoption would give UMFU licensees some certainty and cut down speculative filings, CTIA said.