Industry Groups Ask FCC to Work with University of Michigan on 6 GHz Measurements
Monday, October 03, 2022 | Comments

In an ex parte letter to the FCC, six industry organizations asked the FCC to work with the University of Michigan on testing unlicensed 6 GHz indoors.

The university recently finished a Wi-Fi upgrade project in which it upgraded to a Wi-Fi 6E system with more than 15,500 indoor access points. The letter urged the FCC to use this new network to perform real world measurements of Wi-Fi 6E.

“As the commission knows, licensed incumbents in the 6 GHz band have consistently asked for actual operating data for Wi-Fi 6E,” the letter said. “In addition, there are ongoing disputes between unlicensed proponents and licensed incumbents about Wi-Fi 6E operating parameters — disputes that could be remedied by measuring data at this extensive Wi-Fi 6E system. As there is an active proceeding underway in which unlicensed proponents seek increases in Wi-Fi 6E power levels, the Commission has an opportunity and a responsibility to gather measured Wi-Fi 6E data prior to considering any changes to the existing rules.”

The groups said that all of the measured 6 GHz data so has relied on simulations and data provided by a vendor that were made on devices using an older Wi-Fi standard.

“Unlicensed proponents’ own data demonstrate that since 2018, when those measurements were taken, wireless data rates have increased three-fold and the density of Wi-Fi access points has increased four-fold. This new 15,500 Wi-Fi 6E access point network at the University of Michigan therefore represents a unique opportunity for the commission and all affected stakeholders to measure actual operating characteristics for Wi- Fi 6E.”

The letter suggested that the commission, the university and any interested stakeholders engagement in measurements using the network over a weeklong period.

“By proceeding in this fashion, the commission will be able to accurately model the performance of Wi-Fi 6E products based on current operations rather than outdated information from more than four years ago,” the letter said. “Supplementing the existing Monte Carlo simulations with real-world data would be the only technically sound approach to analyzing the interference environment in the 6 GHz band. Moreover, it would resolve ongoing disputes between licensed incumbents and unlicensed proponents about the proper parameters for Wi-Fi 6E to be used for modeling interference. Acting on the basis of outdated information on Wi-Fi operation, when actual measurements could easily be made and provided to the public record, would be inconsistent with sound engineering practices and could be considered by a court to be arbitrary and capricious.”

The letter was signed by the Enterprise Wireless Alliance (EWA), Utilities Technology Council (UTC), Edison Electric Institute (EEI), American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA).

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