Comments came due Monday in the FCC’s inquiry into how it should handle the 12.7-13.25 GHz band, and as one can imagine, it’s getting an earful.

The commission is considering how it can encourage more efficient and intensive use of the band, dubbed by some as the 13 GHz band, and whether it’s suitable for mobile broadband or other expanded use. It’s currently being used by various incumbents, including for Broadcast Auxiliary and Cable Television Relay Services, Fixed Microwave Service and Fixed Satellite Service.

Let’s go: 5G for 12 GHz Coalition

One of the groups very familiar with the 12 GHz band – albeit the lower part of the band, from 12.2 to 12.7 GH – is the 5G for 12 GHz Coalition.

The organization is primarily interested in maximizing the lower 12 GHz band for two-way terrestrial and 5G mobile and fixed services, but it also supports the agency’s efforts to expand opportunities for additional operations in the 13 GHz band.

According to the coalition, making the 12 GHz and 13 GHz bands available for 5G is critical to the country’s leadership goals. Adding 500 megahertz of 12 GHz spectrum and 550 megahertz in the 13 GHz band would allow the U.S. to overtake several international competitors, including China, and put the U.S. back into a global leadership position when it comes to 5G.

Dish Network is part of the 5G for 12 GHz Coalition. Dish told the commission that it’s all well and fine that they update the rules for the 13 GHz band, but it wants to see some action on the entire 12 GHz band. Dish and the 5G for 12 GHz Coalition have been embroiled in a battle with SpaceX and others over how the 12.2-12.7 GHz spectrum gets allocated.

RS Access has been with Dish in its pursuit of the lower 12 GHz band for 5G.

RS Access CEO V Noah Campbell said he’s impressed by the FCC’s aggressive pursuit of identifying new mid-band frequencies that can support U.S. 5G leadership. He told Fierce this week that he’s hopeful the upper 12 GHz will be combined with the lower 12 GHz to create a contiguous 1,000 upper mid-band spectrum that could be put to use rather rapidly. “It’s potentially a game-changer for capacity,” he said.

CTIA: Make it licensed

CTIA previously said that it wants to see the band allocated for exclusive-use licenses that the major U.S. wireless carriers could use for their services. Likewise, the nation’s biggest carriers are discouraging the commission from adopting any kind of shared usage in the 13 GHz band, saying an exclusive-use, licensed framework is the best way to go.

CTIA pointed out that three blocks of lower mid-band spectrum offer the greatest potential for 5G expansion: the lower 3 GHz band (3.1-3.45 GHz); the mid 4 GHz band (4.4-4.94 GHz); and the 7/8 GHz band (7.125-8.4 GHz).

But it’s not turning its back on this or any other spectrum. CTIA said the 13 GHz band is particularly suitable for exclusive use licensing, as it already has primary fixed and mobile allocations and limited federal users, which makes it easier to expeditiously repurpose the band. Plus, the majority of incumbent uses can be efficiently accommodated through relocation, according to the organization.

Others say: Make it shared use

The Open Technology Institute (OTI) at New America and Public Knowledge (PK) said a shared-licensed framework would be a particularly good fit for the 13 GHz band if the commission decides not to relocate incumbent services to other bands.

A shared-license framework that includes both priority access licenses and opportunistic use can also enrich and diversify the nation’s developing 5G wireless ecosystem “in a way that specifically meets the needs of smaller wireless ISPs, innovators, community anchor institutions and the tens of thousands of individual enterprises that will choose to customize their own private IoT, neutral host or access network,” according to OTI and PK.

Federated Wireless, which is a Spectrum Access System (SAS) administrator for the 3.5 GHz CBRS band, recommends the commission consider a similar multi-tiered licensing framework for the 12.7-13.25 GHz band to protect the incumbents while offering access to new users. Federated offered up several ways the FCC could develop such a framework.

Hold on a minute

While the 13 GHz band is considered mostly unencumbered with fewer federal users compared to other bands, the National Telecommunications and Information Administration (NTIA), which oversees federal spectrum matters, said there are a variety of federal uses of 12.7-13.25 GHz and adjacent bands, as well as commercial uses that are important to federal missions.

Therefore, NTIA is concerned about the potential for harmful in-band and adjacent-band interference if the 12.7-13.25 GHz band were repurposed as contemplated in the FCC’s Notice of Inquiry (NOI). NTIA said before the FCC reaches any conclusions here, there needs to be additional technical analysis to evaluate the effects of repurposing the spectrum.

NTIA said its adjacent-band concerns are mostly with the 13.25-13.75 GHz band, which is primarily a federal band with both military and scientific uses.

Meanwhile, the National Association of Broadcasters (NAB) said the FCC must ensure that broadcasters retain reliable access to spectrum to cover live events and breaking news. NAB acknowledged that it may be possible to repack broadcaster operations in the 13 GHz band into a smaller portion of the band, but it wants to make sure broadcasters don’t have to bear any costs associated with relocation.

Also in the “hold it” camp are satellite players like Hispasat S.A., a Spanish satellite communications operator and content distributor. Hispasat said the agency should refrain from any action to repurpose the 12.7-13.25 GHz band for terrestrial mobile broadband and instead find ways to increase spectrum available to satellite operators that are seeing increased demand for their services.

The FCC received more than 30 comments on the topic. Another round of input is expected, with reply comments due to the FCC by January 10, 2023.

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