One of the panels at this week's INCOMPAS Policy Summit was about the future uses of the 12 GHz spectrum. INCOMPAS, or the Internet and Competitive Networks Association, is a trade group representing internet, streaming, communications, and technology companies.
Between 12.2 GHz and 12.7 GHz, lies 500 megahertz of highly sought after spectrum that is becoming a battleground between three tech heavyweights — Charlie Ergen, CEO of Dish Network, Michael Dell, CEO of Dell Technologies, and Elon Musk, CEO of SpaceX and creator of the Starlink satellite internet service.
The INCOMPAS panel was comprised of Michael Calabrese, Director of Wireless Future Project at Open Technology Institute at New America, V. Noah Campbell, Co-Founder and CEO of RS Access, LLC, Harold Feld, Senior Vice President at Public Knowledge, and Alison A. Minea, Director and Senior Counsel of Regulatory Affairs at Dish Network. The panel was moderated by Drew FitzGerald, a reporter at the Wall Street Journal.
A hunger for spectrum
Panel members discussed the recent auction of spectrum licenses within the C-band that has so far raised $80.9 billion! That auction, which concluded on January 15, 2021, made licenses for 280 megahertz of spectrum lying between 3.7 and 3.98 GHz available. Proponents claim this spectrum is critical for enabling smart cities, connected factories, and virtual reality gaming. Verizon is rumored to have been a major buyer.
On January 12, 2021, the Federal Communications Commission (FCC) issued a Notice of Proposed Rulemaking (NPRM) that seeks comment on new ways to use the 12 GHz band while protecting those already using it from potential interference.
Current users of the 12 GHz band are Dish and DirecTV, which use the band for their Direct Broadcast Satellite (DBS) television services. Electromagnetic waves within the 12 GHz band propagate farther than millimeter waves, and the 12 GHz span is almost twice as broad as the C-band.
Licenses for the 12 GHz band were last auctioned back in 2004 and 2005, which is two years before the first iPhone was released on June 29, 2007. Since then, demand for mobile spectrum has skyrocketed.
Can't we all share?
The FCC's NPRM seeks comment on a proposal to make more spectrum within the 12 GHz band available for 5G. The Internet satellite providers SpaceX and OneWeb have opposed this proposal.
Late in 2020, SpaceX received $885.5 million from the FCC's Rural Digital Opportunity Fund (RDOF) to aid in its deployment of Starlink satellites. Starlink will deliver internet connectivity from a fleet of Low Earth Orbit (LEO) satellites, bringing broadband to more than 5.2 million unserved and underserved homes and businesses. SpaceX is required to cover a total of 642,925 locations across 35 states.
The FCC last wrote rules for the 12 GHz band back in 2002, and spectrum within the 12 GHz band is currently licensed to Direct Broadcast Satellite (DBS) operators, such as Dish Network and DirecTV, non-geostationary orbit (NGSO) satellite systems, such as Starlink, and fixed service providers.
Over the last several years, with more and more people "cord-cutting," Dish's subscriber base has dwindled significantly, however, the company is attempting to enter the lucrative 5G race. Panel member Harold Feld actually described Dish as the fourth cell phone carrier after Verizon, AT&T, and T-Mobile. Dish would like to use the 12 GHz spectrum it already owns for 5G.
The other player in this mashup is Dell Technologies' CEO Michael Dell, who is partnered with RS Access. In 2018 RS Access bought licenses within the 12 GHz band that cover around 15% of the U.S. population, and they hold a total of 80 licenses.
Currently, rules for the 12 GHz band specify that it can only be used for one-way communication, such as from a satellite down to a receiver, however, both Ergen and Dell are pushing the FCC for rule changes that would allow it to be used for two-way wireless communication and 5G.
Back in 2016, Dish petitioned the FCC to allow for the sharing of the DBS spectrum with 5G services. Currently, Dish holds 12 GHz band licenses that cover around 75% of the U.S. population.
Dish Senior Counsel Alison Minea told the panel that Dish hoped the NPRM would lead to more use of the 12 GHz spectrum for 5G. She reiterated that Dish had purchased spectrum licenses within the band at auction, and that Dish owned the terrestrial rights and would defend those rights.
Is sharing even possible?
Campbell pointed out that the C-band auction proved the enormity of the demand for mid-band spectrum as opposed to millimeter bands, and that the 12 GHz band is unique in its position between the 6 GHz and 24 GHz bands.
Campbell also said that the 12 GHz band must be used more intensively, with the potential for five hundred 100-megahertz channels. Campbell made the point that the band could be used for point-to-multipoint communications.
Harold Feld said that the FCC is taking a fresh look at all the ways the 12 GHz band could be used, and that over the last 10 years, there have been significant advances in the way spectrum can be shared.
Feld also pointed out that most use cases, such as point-to-point, point-to-multipoint, and two-way communication, weren't known when the FCC's rules were originally written.
What makes the 12 GHz band such a unique opportunity is that it is not very crowded, and it has no government users. Michael Calabrese said that he hoped the NPRM would soon be formally published in the Federal Register so that public comment can begin.
Calabrese said he considered the biggest issue to be co-existence and shared use between DBS and satellite internet providers. It is not currently known how satellite internet would affect DBS and 5G small-cell services, and those restrictions could limit how satellite internet antennas are placed.
Feld said he expects these issues to be vetted by the FCC's Office of Engineering and Technology (OET), and that questions won't be resolved until all the stakeholders provide more precise engineering information.
Feld pointed out that the new satellite internet receivers are very nimble, they can switch among bands and orient themselves to catch passing satellite clusters. This makes them more resistant to creating potential interference.
The urban-rural divide
Satellite internet won't have much of an effect on urban locations, however, it has the potential to have a huge impact on rural areas. Panel members concluded that it is necessary to check every spectrum band to see whether changes in technology have made them more viable. Now, more than ever, we must make the most productive use of spectrum.
Alison Minea said that Dish isn't giving up on its satellite TV service, and they don't think that sharing spectrum with terrestrial two-way communication, such as 5G, will degrade their service.
Feld said he thought it would take 18 months for the FCC to create new service rules, and V. Campbell reiterated the need to get the frequency to market more rapidly.
More people are working from home, more children are learning remotely, meetings are being conducted over Zoom, and telemedicine is becoming more common. The need for broadband internet has never been greater, the only question is: Who is going to provide it?