Telecom companies debated the details of a national spectrum strategy across hundreds of pages of new filings, arguing over topics including spectrum sharing, transmission power limits and 6G.
In lengthy filings with the White House's NTIA, Verizon, Qualcomm, Samsung, Charter Communications, Lockheed Martin, SpaceX and dozens of other telecom players offered plenty of feedback on the Biden administration's efforts to create a national spectrum strategy.
To be clear, the comments were issued before the Biden administration released its 26-page national spectrum strategy in November 2023. Instead, they were filed in response to a request by the NTIA in March 2023 for commentary on a possible strategy.
Regardless, the companies urged the White House to release more spectrum for commercial operations – but they offered wildly different perspectives on how that spectrum should be released. For example, Comcast urged regulators to pursue unlicensed and shared-spectrum scenarios, while AT&T wrote that "without primary, exclusive license rights, a network cannot offer service that is certain to be free of interference and interruption."
The filings also helped shine a light into some companies' spectrum strategies. For example, AT&T mentioned interest in spectrum in the 12GHz range, while T-Mobile did not. Charter, meantime, again noted its desire for spectrum in the lower 37GHz band. And SpaceX disclosed that it's using spectrum in the E-band (71-76GHz and 81-86GHz) in a way that it said could pave the way for a "light-licensing approach" to spectrum usage.
Meanwhile, Lockheed Martin – the biggest defense contractor in the US – offered perhaps the clearest look yet at the ongoing debate over the lower 3GHz band. That spectrum band "is currently home to mature, national security critical capabilities for which there is no international (or propagation) equal," according to Lockheed. Such commentary appears geared to stop efforts to free up that band for 5G operations.
Collectively, the filings with the NTIA reflect the depth of the disagreements among 5G network operators and others in the telecom market. They also set the stage for an ongoing discussion over the implementation of the Biden administration's national spectrum strategy.
The CBRS band
A number of companies cited the 3.5GHz CBRS spectrum band in their filings. That band, opened to commercial operations in 2019, sports a unique sharing setup that allows both unlicensed and licensed users to share the band with the US Navy.
According to some commentators, that kind of sharing should be extended into other spectrum bands. "As with CBRS, opening the lower 3GHz band for shared use will promote competition by making spectrum available to a wide diversity of users and use cases," Comcast wrote.
But AT&T, UScellular and others argued that the CBRS band remains underutilized, in part because of the FCC's power limits on transmissions in the band.
"A cell site equipped with CBRS will provide a usable connection to approximately a 1.5 km radius. In contrast, a similarly designed site using C-band will provide customer benefit up to a distance of 9 km. That's six times the distance, and over 40 times the area covered by using full power spectrum," wrote UScelluar.
And Verizon – which has undertaken a relatively expansive CBRS deployment – also complained of the band's characteristics. "Verizon and others have leveraged CBRS to augment capacity where and when it is available but are not deploying CBRS for primary coverage at scale," the company wrote. "Verizon believes that dynamic spectrum sharing has potential for localized and enterprise uses, but to date, it only allows for low-power, preemptible service and does not enable the assured access and wide-area capability that is fundamental to full-fledged wireless service."
AT&T, for its part, argued for "network grade" spectrum, or spectrum that is licensed on an exclusive basis, not shared, and that can be broadcast at higher power levels.
The lower 3GHz band
The 5G industry has been clamoring for the US military to release part or all of the lower 3GHz band for 5G. However, the US military currently uses that spectrum in part for radar, and by some estimates it would cost up to $120 billion to move Department of Defense (DoD) radar operations off the 3.1GHz-3.45GHz band in order to free it up for exclusive commercial 5G operations. Officials from the DoD, the 5G industry and others have been looking at the issue, but a report on whether and how to free up that spectrum for commercial uses has not been released publicly.
"The lower 3GHz band ... provides a large bandwidth and reliable range of coverage, making it ideal for 5G use," T-Mobile wrote.
And CTIA – the main trade association for 5G network operators, argued for "licensed, full-power commercial wireless use" of the band.
But others insisted the band be released on an unlicensed basis, and potentially shared with the US military. "A dynamic sharing model in 3.1-3.45GHz, similar to proven success of CBRS in the 3.5GHz band, could maximize users and efficient use of limited midband spectrum. Spectrum sharing in this band could also bring this spectrum to market quickly and cost-effectively, and provide a viable alternative to relocating federal users in the band or requiring new devices or equipment for incumbents," Amazon wrote.
None of those positions is a surprise, though. Amazon is using the CBRS band for its private wireless network offering. T-Mobile, meantime, has built its entire 5G business on high-powered, licensed spectrum, and has eschewed CBRS.
Lockheed, for its part, called for a Real-Time Spectrum Management (RTSM) spectrum-sharing system: "A system that allocates spectrum to authorized users and coordinates their access in frequency, time and geographic area," the company explained.
But AT&T argued that the DoD ought to develop systems that can work around commercial operations, rather than the other way around. "If DoD is not already developing such technology, then it is being grossly negligent in failing to provide its warfighters a key capability they need to conduct electromagnetic spectrum operations overseas with agility," the company wrote. "Such a warfighting capability would have the tremendous ancillary benefit of greatly simplifying the task of sharing midband spectrum domestically with full power 5G network operations."
7GHz
A number of companies expressed their interest in the 7GHz band. That's one of several bands named in Biden's spectrum strategy as suitable for possible commercial uses, from wireless broadband to satellite operations to drone management.
T-Mobile, AT&T and Verizon all specifically mentioned a desire for a slice of spectrum between 7.125GHz and 8.5GHz. T-Mobile said the band's "higher capacity could help serve densely populated areas with 5G use cases."
But others, including Charter and Comcast, urged regulators to release that spectrum in an unlicensed scenario.
Indeed, the WiFiForward trade association opined that the 7GHz band ought to sit next to the 6GHz band for unlicensed operations including Wi-Fi. "The next-generation Wi-Fi 7 standard will introduce 320MHz channels (already being standardized internationally) to power the growing number of devices, deliver even faster speeds, and support the increasingly data-intensive telemedicine, telework, digital learning, AR, VR and XR applications," the association wrote. "Those channels will require more spectrum than currently available in 6GHz to meet these demands. An unlicensed approach (and potentially shared licensed use) would allow government users to stay in place and avoid exorbitant clearing and equipment costs, while also facilitating rapid commercial and consumer access to critically needed spectrum and supporting expansive US economic growth."
That position is noteworthy considering the 5G industry is bemoaning the FCC's 2020 decision to allocate the 6GHz band for unlicensed operations like Wi-Fi.
6G
Finally, equipment vendors like Nokia, Samsung, Ericsson and Qualcomm urged regulators to free up the spectrum they hope will support new 6G equipment. Although 6G technology isn't expected to hit the market until 2028 at the earliest, vendors are nonetheless hoping to develop demand for their future equipment.
"6G will be ready for deployment before the end of the decade, but we need to act now to meet domestic demand and keep pace with the pace of innovation among our global partners and rivals," Nokia wrote. "The US should strive to open up to 2GHz of new spectrum in 7-15GHz range for commercial use to maintain US technology leadership and meet domestic user demand."
Added Samsung: "Samsung is actively researching the entire spectrum of key 6G enabling technologies, including core radio technologies for new frequency bands (e.g., 10-15GHz in upper midbands and around 140GHz in the sub-THz range), new channel coding, new waveforms, next generation network architecture, and utilization of AI across various entities in the whole communication network."
And Qualcomm mentioned its interest in 6G too, but also added its voice to the chorus of support for spectrum sharing. "By opening to sharing a frequency band exclusively held by the federal government, federal government users can take advantage of the most advanced wireless technologies, chipsets, and equipment that industry develops for commercial operations in the band, thereby improving federal operations and making more intensive use of the shared spectrum bands. Encouraging all spectrum stakeholders to work collaboratively on spectrum sharing is a successful way forward," the company wrote.
This article was updated on January 9, 2024, to make it clear that the comments to the NTIA were filed before the Biden administration issued its national spectrum strategy in November 2023. A previous version of this article incorrectly reported that they were filed in response to that strategy.
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