Southern Company Asks FCC Not to Change 6 GHz Rules Without Rigorous Testing
Tuesday, January 12, 2021 | Comments

In a letter to the FCC, Southern Company asked to FCC to refrain from taking any actions that expand unlicensed use of the 6 GHz band until after rigorous testing of unlicensed use has occurred.

In April, the FCC adopted an order that allowed unlicensed use in the 6 GHz band. The order allows two types of unlicensed devices: standard power devices that are managed using an automatic frequency coordination (AFC) system and low power devices that that do not require an AFC but can only be used in indoors.

Critical infrastructure organizations, such as Southern Company, have been especially concerned about the low-power devices, arguing that it will be impossible to fully ensure those devices will only be used in indoors and that interference caused by those devices could interrupt critical microwave links. A variety of critical infrastructure organizations including the Edison Electric Institute (EEI), the Utilities Technology Council (UTC), the National Rural Electric Cooperative Association (NRECA) and the American Public Power Association (APPA) has asked the U.S. Appeals Court for the District of Columbia to remand the rules back to the FCC for stronger interference safeguards.

In its letter, Southern Company noted that Congress expressed concern about unlicensed use of the 6 GHz band. In the recently enacted Consolidated Appropriations Act of 2021, Congress expressed particular concern about how the unlicensed use would affect the nation’s electric system. The act directed the FCC to provide a report to Congress on its progress in ensuring rigorous testing in relation to unlicensed use within 90 days of enactment of the act.

“Congress’ concerns regarding testing are especially significant given the results of initial field tests conducted by Southern Company and CTIA in the fall of 2020, which showed that transmissions by both low-power indoor devices and outdoor very low-power devices caused harmful interference to an actual 6 GHz fixed service link,” the letter said.

Southern said it has submitted many filings to the record of the new 6 GHz rules highlighting the dangers of unlicensed interference to critical microwave links. Based on its studies, Southern Company asked the FCC to refrain from taking any more actions with the band until after rigorous testing of unlicensed use has been performed.

Southern Company also urged the FCC to use its authority under Section 2.945 of its rules to seek a sample from any low-power indoor device equipment manufacturer that seeks to have it equipment certified.

“Requiring a testing sample would be consistent with the precedent established by the commission when responding to congressional inquiries in 2016 regarding the impact of LTE-Unlicensed (LTE-U) technology on unlicensed Wi-Fi operations,” the letter said.

Those sample devices could then be used as part of the rigorous testing that Congress required in the appropriations act. This will allow the FCC to determine if the unlicensed devices can coexist with existing 6 Ghz operations without causing harmful interference.

“Indeed, as some parties have already received certification for unlicensed 6 GHz devices, these manufacturers could be the initial parties to provide samples to the commission for the testing requested by Congress,” the letter said.

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