NWCC Offers Support of Petition to Stay Unlicensed 6 GHz Use
Monday, June 27, 2022 | Comments

The National Wireless Communications Council (NWCC) filed an ex parte letter with the FCC expressing support for requests for reconsideration and stay of 6 GHz unlicensed use.

The petitions were filed by a variety of groups including the Utilities Technology Council (UTC), Edison Electric Institute (EEI), International Association of Fire Chiefs (IAFC), the Association of Public-Safety Communications (APCO) International and the National Public-Safety Telecommunications Council (NPSTC). The petitions ask for new rules for 6 GHz low-power indoor (LPI) devices, further testing of standard-power devices and a stay on equipment certification of those devices.

“The joint petition reflects new information on the record regarding the results of real-world testing of commercially available 6 GHz devices that calls into question assumptions in the 6 GHz report and order regarding the threat of interference to fixed incumbents, including public safety, utilities and numerous other entities, from both LPI and standard power devices,” the NWCC filing said.

NWCC said that it agreed with the petitions that should interference occur, it would be difficult to trace and mitigate against it, which could interrupt critical communications and threaten public health and safety.

“As the joint petition points out, with essential services at stake, the Commission should not rely solely on models and Monte Carlo simulations,” the NWCC’s letter said. “Accordingly, the commission should conduct independent, real-world tests of devices to determine the extent to which new rules are needed to prevent unlicensed devices from causing harmful interference to incumbent licensees.”

NWCC also said it agreed with the petitions that the FCC needs to clarify what obligation automatic frequency coordination (AFC) systems have to protect incumbents and correct interference.

“At the time the joint petition was filed, details of the AFC testing process had not yet been provided, including specific information regarding the parameters of AFC functionality,” the NWCC’s letter said. “This lack of clarity remains, despite AFC system operators providing initial proposals and answering subsequent questions from the Office of Engineering and Technology. Therefore, clarification is needed from the commission regarding the parameters and the process for AFC system authorization to ensure that AFC systems are effective at preventing interference to licensed microwave systems.”

The NWCC’s letter also expressed concern about costs that incumbents in the band might incur, including monitoring, detecting, identifying and reporting interference.

“Accordingly, the commission should develop a mechanism by which incumbent licensees will be able to recover the costs of monitoring and reporting on interference resulting from unlicensed use of the 6 GHz band,” the letter said. “Given that hundreds of millions of 6 GHz LPI devices are expected to be in use this year, and there will be no way to quickly shut down these devices if they do in fact cause harmful interference to these vital fixed communications links, it is necessary for the commission to revisit the 6 GHz rules to ensure unlicensed 6 GHz devices will not cause harmful interference to licensed microwave systems. NWCC requests expedient action by the commission on the pending stay request and joint petition.”

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