Report Highlights Link Between Spectrum Policy and National Security

A new report published by the Center for Strategic & International Studies (CSIS) warns that absent a heightened focus on our national spectrum policy, "[t]he security of the United States as a market democracy is at stake." In the simplest of terms, online activity is only as secure as the underlying apps and network infrastructure over which it occurs. If that software and hardware is to come from trusted sources, policymakers must foster an environment in which America's mobile marketplace maintains a powerful say in global technology development, "especially as autocratic nations seek to dominate."

In Part 1 of "Concrete National Security Benefits of Spectrum Allocation for Commercial 5G," CSIS Strategic Technologies Program Senior Fellow Clete Johnson identifies two "difficult technical feats" that the U.S. must and can accomplish if it is to achieve the scale necessary to drive technology development down a secure and trusted path. The first is to better harmonize frequency use, as "[t]he more that U.S. spectrum use is harmonized with that of allies and global markets, the more scale trusted suppliers have for secure technology development." The second is to allocate sufficient spectrum so that capacity does not constrain the economic might of American consumers.

Harmonizing the frequencies allocated to 5G (and successor standards) is essential to achieving economies of scale because technology development is frequency specific: equipment developed for one band typically cannot be used in other bands. As the report points out, however, "the United States is becoming a mid-band spectrum 'island,' operating largely outside the core globally harmonized spectrum bands. If this trajectory continues, the U.S. technology ecosystem will be confined to a U.S.-only spectrum 'dialect' that lacks global influence and scale."

Allocating sufficient spectrum to satisfy growing mobile broadband demand, meanwhile, maximizes the economic ability of 350 million American consumers to shape global technology decisions. As the report explains:

U.S. wireless companies need sufficient spectrum resources to collaborate with like-minded nations in innovating and manufacturing advanced wireless technologies and components – including chipsets, software, radios, and more – for use in both the commercial and federal sectors…. The existing disparity between U.S. licensed mid-band spectrum allocations as compared to the rest of the world has become a major national security challenge, as it has created a platform for China to shape the near-term and future technology environment to its strategic advantage.

The report proposes several ways to address this situation. They include:

• Reframing the spectrum deficit as "an optimization challenge, not a scarcity problem."
• Moving from a "zero-sum" mindset that pits government and commercial uses against each other to a collaborative environment that promotes "static" and, in the longer term, "dynamic" spectrum sharing solutions.
• Restoring the FCC's spectrum auction authority.
• Aggressively pursuing harmonization opportunities, which may include the 7/8 GHz band, so that America speaks the same "frequency 'language'" as its allies.

The report's forthcoming Part 2 primarily will focus "on the importance of agile spectrum management capabilities in the context of electronic warfare."

Recon Analytics' Report Critiques the CBRS Shared Spectrum Approach

A report was released by Roger Entner of Recon Analytics on November 14, titled "CBRS: An Unproven Spectrum Sharing Framework." There is a decade-long technical debate about whether spectrum bands ideally suited for commercial wireless services can or ought to be designated for use on an exclusive licensed basis or instead be shared by federal agency users with licensed commercial users and unlicensed users. For the 3.45-3.55 GHz band spectrum license auction, which was conducted by the FCC earlier this year, 100 MHz of spectrum was cleared for exclusive commercial use by licensees. By contrast, Citizen's Band Radio Service (CBRS) spectrum in the 3.55-3.7 GHz range is shared by government incumbents, priority access licensees (PALs), and General Authorized Access (GAAs) users.

Entner's report generally favors the exclusive licensed use approach to spectrum and criticizes the spectrum sharing approach undertaken for the CBRS band. The report, along with reactions to the report, is worth considering as the discussion continues regarding the proper allocation of the lower 3 GHz spectrum band and others for repurposing to commercial wireless services.

FCC Takes Action to Unleash Wi-Fi 6E, Wi-Fi 7

On November 2, 2022, the FCC's Office of Engineering and Technology (OET) announced that it had conditionally approved 13 Automated Frequency Coordination (AFC) systems designed to enable shared use of the 6 GHz band between licensed and unlicensed devices.

By preventing harmful interference to incumbent licensed microwave links, AFC will make available 1200 MHz of high-value, mid-band spectrum to Wi-Fi 6E devices operating at standard power levels – which, in turn, will deliver to consumers increasingly faster speeds, lower latency, and better coverage.

Source: Wi-Fi Alliance®

The consumer popularity of Wi-Fi is both immense and steadily growing. Consequently, existing unlicensed spectrum in the 2.4 GHz and 5 GHz bands long has been subject to overcrowding. More capacity, particularly contiguous swaths able to support wider Wi-Fi channels – and, thus, faster speeds – was needed.

In response, the FCC in April 2020 adopted a Report and Order opening the 6 GHz band to flexible unlicensed use, including Wi-Fi.

A December 28, 2021, post to the FSF Blog reported that the D.C. Circuit largely upheld that agency action in AT&T Services, Inc. v. FCC.

The following day, FSF President Randolph May in a Press Release heralded that decision "because of the way the court broadly viewed the exercise of the Commission's core spectrum management responsibilities" and for "emphasizing the considerable degree of deference to be accorded to the FCC regarding technical spectrum management matters."

Integral to the Commission's conclusion that unlicensed devices can operate at standard power levels in the 6 GHz band both indoors and outdoors without causing harmful interference to incumbent licensed users is the role to be played by the AFC spectrum use coordination system.

(By contrast, the agency determined that indoor-only devices could operate safely at lower power levels without AFC. As a result, such devices are available today in the retail marketplace as well as from broadband Internet service providers.)

By paving the way for testing to begin, OET's conditional approval of 13 AFC database systems represents a noteworthy step forward in wireless networking – not only Wi-Fi 6E, but also Wi-Fi 7, the under-development successor specification recently demonstrated for Commissioners and agency staff by Intel Corporation and Broadcom Inc.

As those companies described in a slide deck filed in ET Docket 18-295 and GN Docket No. 17-183, Wi-Fi 7 expands network capacity by a factor of 5, latency by up to a factor of 100, and further improves coverage.