6 GHz Concerns Unite Carriers, Public Safety, CII in FCC Letter
Friday, December 13, 2019 | Comments

Wireless carriers, public-safety and critical infrastructure industries (CII) associations, and others joined to remind the FCC of the detriments of allowing interference from unlicensed devices in the 6 GHz band.

An FCC filing said nearly 97,000 microwave links rely on the 6 GHz band for vital connections for mission-critical 9-1-1 dispatch and first responder communications, safely coordinating train movements, managing the electric grid, delivering traffic on commercial mobile networks and many other critical services.

Signatories to the letter to FCC Chairman Ajit Pai included entities that depend on these critical links and that are united and resolute concerning the following:
• The FCC should only adopt an unlicensed spectrum sharing regime in the 6 GHz band if it determines, based on the technical showings in the record, that unleashing hundreds of millions of unlicensed devices will not cause harmful interference to the microwave links — primary licensees — in the 6 GHz band.
• Unmanaged and untethered unlicensed devices pose an unacceptable interference threat, contrary to the unlicensed proponents’ studies that dismiss interference inevitabilities.
• Unlicensed operations in the 6 GHz band must be subject to a rigorous interference protection regime that includes positive control through automated frequency control (AFC).
• Any interference protection regime must undergo substantial testing, be proven in advance to prevent interference, and be capable of rapidly resolving any interference should it occur.

“The unlicensed advocacy campaign for the introduction of AFC-free low power indoor (LPI) and very low power (VLP) devices fails to demonstrate that incumbent licensees will be protected from harmful interference,” the letter said. “Their studies contain unreasonable assumptions, unsuitable methodologies and unsupportable conclusions. With nearly 100,000 fixed links and RLAN projections of nearly 1 billion unlicensed devices in the 6 GHz band, ‘low probability’ interference occurrences translate to thousands of inevitable, real-world harmful interference events. Even one or two (much less thousands) electric blackouts or disruptions to first responder communications that aren’t delivered are too many.”

The 18 signatories included the four nationwide commercial carriers and CTIA, several regional wireless carriers, the Association of Public-Safety Communications Officials (APCO) International, International Association of Chiefs of Police (IACP), National Sheriffs’ Association (NSA), International Association of Fire Chiefs (IAFC), American Association of Railroads (AAR) and several vendors, among other groups.

The full letter is here.

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