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Broadcasters, Satellite Concerns

Disagreements Continue on Best Use of 13 GHz Band

Disagreements remain about whether the upper 12 GHz band can be reallocated for exclusive-use licenses, as carriers hope, in reply comments in docket 23-352. Some wireless commenters ignored the proceeding on the lower 12 GHz band (see 2309110061) and filed only on what is also called 13 GHz. Broadcasters and the satellite industry continue to raise objections (see 2308140046).

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Initial comments “overwhelmingly note that the 13 GHz band represents a valuable complement to, though not substitute for, mid-band spectrum and is well-suited for the data-intensive uses next-generation technologies will require,” CTIA said.

CTIA countered NTIA comments that the FCC must protect federal facilities, including radioastronomy observatories operated by the National Science Foundation (see 2308110037). “As an initial matter, the use by NSF of the 13 GHz band is unallocated,” the wireless group said: “The radio regulations clearly state that such use cannot claim protection from harmful interference -- and unallocated federal use of the 13 GHz band therefore should not be protected by the Commission.”

Although some incumbent broadcasters question whether the 12.7 GHz band can be cleared for wireless broadband and other uses and whether their operations should be sunset, their concerns are unfounded,” T-Mobile said: “Not only can they be relocated to other bands, but they can also make use of alternative technologies like 5G-supported services and fiber.” Concerns about interference to adjacent bands are “either not supported in the record or not backed by sound engineering analyses,” the carrier said.

Verizon said the band could be used for holographic communications, “the Internet of Senses,” extended reality, as well as “enhanced technologies and applications” including AI, edge-computing and the IoT. “The capacity characteristics of the 12.7 GHz band make it promising to support these advanced technologies and use cases, even as core mid-band frequencies continue to serve as an essential coverage layer for wide-spread wireless deployment,” Verizon said.

Broadcaster Objections

The FCC shouldn’t “rush to repurpose the band” and instead should “engage in deliberate long-term analysis of how best to utilize the band going forward,” said the Society of Broadcast Engineers. SBE said broadcast auxiliary service links must be protected if they can’t be relocated. “Fixed links are often the exclusive path for a station to deliver its programming to its broadcast transmitter … whether for a full service television broadcast facility or an associated TV translator to be able to reach the public over the air and especially in rural areas, or to reach a cable headend or make otherwise infeasible links through a spectrum-congested area,” the group said. Mobile BAS should be preserved within an exclusive block in the band, SBE said: “Mobile BAS is a crucial aspect of many broadcasters’ operations and the dissemination of timely breaking news, emergency, and local information to the public.”

Broadcasters cannot all be moved out of the 13 GHz band, NAB said. “The number of BAS licenses in the 12.7 GHz band is relatively small, but those authorized facilities are essential to broadcast operations, providing studio-transmitter links and other functions that, if interrupted, would prevent broadcasters from providing programming and emergency information to the public,” broadcasters said: “The reality is that, in many cases, broadcasters use the 12.7 GHz band precisely because other frequency bands are not available due to frequency congestion or regulatory restrictions.”

DirecTV warned of interference to its operations in the lower 12 GHz band. “All technical analyses submitted conclude that terrestrial mobile emissions in the 12.7 GHz band have the potential to cause harmful interference into adjacent satellite services in the 12.2 GHz band,” DirecTV said. The company said its own analysis found that terrestrial mobile emissions in the upper band “would create out-of-band emissions and blocking interference that degrades DBS receiver performance in the neighboring 12.2 GHz band.”

NCTA said sharing the band would allow for it to be more widely used, while protecting BAS and cable television relay service licensees. “A shared-use model would balance the important goals of making spectrum available for new uses, while protecting the important incumbent operations in the band,” NCTA said: “By contrast, exclusive-licensing proponents offer no realistic plans for protecting the operations of incumbent users while forcing them to relocate or repack to a small part of the band, which may not be possible in some cases.”

The Wireless ISP Association called for dynamic sharing of the lower and upper 12 GHz spectrum. WISPA said if the FCC decides against a shared use framework for 12.7 GHz, it should offer county-sized licenses. The Further NPRM proposes much larger partial economic area licenses, WISPA noted: “The record of this proceeding and the history of recent spectrum auctions demonstrate that PEAs are much too large for the service needs of the vast majority of potential users of the band, especially for providers of broadband in rural, unserved, and underserved areas.”