No Wireless Consensus on U.S.' WRC-23 IMT Allocation Position

Qualcomm urged the FCC to adopt view A, which proposes broad studies looking at 7.125-15.3 GHz for IMT, with the ultimate goal of having an agenda item ready for WRC-27. “Identifying spectrum availability for 6G in a timely fashion is vital in supporting the U.S. wireless industry and the R&D already underway by American companies and effectively maintaining U.S. global leadership in wireless innovation and deployment,” Qualcomm said: “Geopolitical and economic considerations require that now, more than any other time, the United States champions WRC-23 positions that reflect our national interests and priorities.”

CTIA also supported view A. “There is a pressing need for the U.S. to solidify its support for WRC-23 proposals, particularly those that will create new identifications for IMT use in the lower mid-band range, which offer the greatest potential for meeting the needs of additional 5G deployments by wireless operators,” CTIA said. It emphasized the significance of the upcoming Inter-American Telecommunication Commission (CITEL) prep meeting: “This will be the last opportunity for the U.S. to advance its 5G spectrum proposals that could become regional proposals, which provides the U.S. the flexibility it needs domestically to establish a 5G pipeline.”

The U.S. is at risk of falling behind China and other nations on mid-band for IMT, Verizon warned. “The Commission should support identifying additional spectrum for IMT in the maximum number of bands possible, including, among others, the 4.8-4.99 GHz, and the 10.0-10.5 GHz bands, and future study of 7.125-15.35 GHz range,” the carrier said. Study of the mid-band for 6G needs to start now, said AT&T, which also supports view A: “Historically, new generations of mobile broadband technologies have been deployed in bands newly assigned for such use, and it often takes a decade to repurpose bands for mobile broadband.”

View A “appropriately seeks to study a large frequency range,” the Wireless Infrastructure Association commented. View A “reflects the near-term need for frequencies for the next generation of wireless technology and “at this point there has been enough research and development to have sufficient information about 6G to start the planning process,” WIA said.

5G Americas also supported view A. “6G could require wide, contiguous bandwidths -- such as 500 MHz, to deliver immersive, artificial intelligence-rich applications at scale,” 5G Americas said: “Spectrum in the 7.125–15.35 GHz range has the bandwidth required to meet 6G sensing requirements and allow for more cost-effective radiofrequency circuit design to enable new 6G use cases.”

Samsung Electronics America endorsed instead the more narrowly tailored view C. “This view would provide a more focused range of bands for study under the proposed agenda item and would avoid identification of spectrum” for IMT “that would overlap with spectrum in use by an existing mobile application” ultra-wideband, Samsung said. The 7.7-9.3 GHz range “should not be a part of the scope of ITU study or other future spectrum reallocation discussions,” the company said.

The UWB Alliance similarly supported the more limited proposal. “The use of UWB is expanding rapidly, supporting a robust ecosystem delivering products providing significant value,” the alliance said: “The UWB industry seeks to preserve and enhance the usability of the available spectrum."

Satellite

Don't propose a WRC-27 Agenda Item to review the Ku- and Ka-band EPFD limits governing the co-existence of nongeostationary satellite orbit (NGSO) systems with geostationary (GSO) networks, said Viasat, EchoStar/Hughes, Intelsat, Inmarsat and DirecTV. "Billions of dollars have been invested in existing and planned Ku- and Ka-band GSO-based networks and services in reliance on the existing EPFD framework," they said. The current framework "does not 'overprotect' " GSO networks from NGSO interference, they said.

EPFD limits "should reflect modern operating circumstances" and let NGSO systems use shared frequency bands while also protecting GSOs, SpaceX said, supporting a future agenda item to review and update the Ku- and Ka-band EPFD limits. "The existing provisions are spectrally inefficient and unnecessarily constrain the ability of [NGSO] systems to meet growing demand from consumers for high-speed, low-latency broadband," it said. The EPFD framework for the Ka and Ku bands was developed with out-of-date technology and protection assumptions and needs updating, said Amazon's Kuiper. Kuiper said the proposed use of 17.1-19.7 GHz for IMT "threatens to disrupt" fixed satellite service (FSS) operations.

Any future agenda item on IMT needs an explanation from IMT interests of why the more than 15 GHz identified for IMT at WRC-19, most of which still isn't being used in most of the world, can't meet existing and developing IMT needs, Inmarsat said. Inmarsat said the proposal to consider 18.1-19.7 GHz "is particularly unsuitable considering the varied and ubiquitous deployment of receiving Earth stations in the band." It argued against support of considering inter-satellite links within mobile-satellite service allocations in portions of the L and S bands, as such an allocation "would disrupt the existing, stable GSO and NGSO MSS sharing framework that has fostered growth and innovation of critical services in these bands for many years." It urged support of allowing use of the 1645.5-1646.5 MHz frequency band for distress, urgency and safety communications as part of maritime distress and safety service modernization.

The Satellite Industry Association backed a move toward allowing use of the 12.75-13.25 GHz band for aeronautical and maritime earth station uplinks to GSO FSS satellites. Pointing to growing demand, SIA also urged allowing NGSO FSS communication with those earth stations via 17.7-18.6 GHz, 18.8-19.3 GHz, and 19.7-20.2 GHz downlinks and 27.5-29.1 GHz and 29.5-30 GHz uplinks. Rather than support consideration of allocating 7.125-15.35 GHz for IMT, use WRC-27 to narrow and refine the proposed frequencies" and allow time for IMT-2030 standards development before identifying a more reasonable set of bands for study at WRC-31, it said.

Don't support studying the 8025-8400 MHz earth exploration satellite service downlink spectrum for IMT as a future agenda item or support including that X-band spectrum among proposed new mobile satellite service allocations, EESS operators said. They backed supporting inter-satellite link (ISL) spectrum allocations in the 27.5-30 GHz band and the future agenda item proposal relating to the use of the C band for ISLs. Behind the EESS submission were Atlas Space Operations, Fleet Space Technologies, HawkEye 360, Iceye, Lunasonde, Maxar Planet Labs and Spire Global.

New ISL deployments can't be allowed to interfere with incumbents, OneWeb said, urging those deployments be restricted for earth exploration satellite service, space research service space operations service and industrial, scientific and medical purposes. It said 7.125-15.35 GHz is already heavily used by fixed satellite service and fixed service deployments, and considering any part of the range for IMT "must carefully consider the potential impacts and avoid disrupting these essential services." The WRC-23 study cycle already has agenda items related to IMT that could result in more spectrum being identified, it said. "Decision-makers should focus on optimizing the use of existing spectrum resources and carefully evaluate the real demand for additional IMT spectrum before considering further allocations at detriment of other critical industries," it said.

EchoStar/Hughes said that while it supports deferring study of 7.125-15.35 GHz to WRC-31, it opposed study of 12.2-12.7 GHz band for potential identification to IMT. It backed the study and development of technical, operational and regulatory measures for use of 37.5-39.5 GHz and 40.5-42.5 GHz downlinks and, 47.2-50.2 GHz and 50.4-51.4 GHz uplinks by aeronautical and maritime earth stations in motion (ESIM) communicating with GSOs.

"Unless and until more spectrum is made available for ESIM operations, satellite providers may struggle to address customers’ on-the-go connectivity needs," Intelsat said, backing an ESIM allocation in the 12.75-13.25 GHz band. It urged against support of studying an MSS allocation in the C band. "The availability of C-band spectrum for FSS use has already been curtailed dramatically, and any additional MSS allocation in the band would further disrupt long-standing incumbent FSS operations," it said.

Globalstar doesn't intend to operate ISLs, and allocating the 1610-1618.725 MHz/2483.5-2500 MHz band for ISLs could result in extensive inter-satellite traffic and threaten substantial harmful interference to Globalstar’s licensed MSS offerings, it said, opposing future study. Any updates of protection of GSO networks from MGSO systems need to ensure that direct broadcast satellite operations in the 12 GHz band are protected and don't circumvent the FCC's ongoing 12 GHz proceeding Dish Network said.