Apple wants the Federal Communications Commission to make sure that plenty of the so-far unlicensed, very high spectrum bands from 95 GHz to 3000 GHz stay as they are: unlicensed. In a comment with the FCC on May 2, Apple asked the FCC to make sure there’s enough unlicensed spectrum at those frequencies to enable future innovation.
“Historically, the U.S. has been a leader in wireless innovation due, in part, to its willingness to open new spectrum,” said Apple in the comment to the FCC, urging the agency to “either support the innovative companies working to develop future wireless technologies by allowing for substantially wider unlicensed bands, or pursue other strategies to preserve regulatory flexibility in recognition of the difficulty of making predictions about the future path of technology.”
Apple reminded the FCC of several international efforts that are already contemplating uses for the bands, from organizations such as ETSI and the International Telecommunications Union. ETSI and the Electronic Communications Committee of the European Conference of Post and Telecommunications Administrations have a short-range radio-determination application operating between 120 GHz and 260 GHz at 60 gigahertz bandwidths. “Existing forms of this technology are central to various industries, including environmental protection, human safety, and manufacturing,” said Apple.
The ITU is also working on high-speed, short-range communications between 275-400 GHz that will need wide-bandwidth spectrum for operations, Apple noted.
“Providing room to develop these technologies at higher frequencies with larger bandwidths has the potential to significantly improve the fidelity of these technologies, supporting applications that are infeasible today,” said Apple.
“Fortunately, the [FCC’s Notice of Proposed Rule Making] generally advances these goals. However, a subset of its proposals could impose rules that hamstring market-based innovation,” Apple added, going on to say that “the proposed band structure intersperses relatively narrow unlicensed bands with substantially more licensed spectrum, thereby capping the width of unlicensed bands and substantially limiting unlicensed engineering opportunities.”
Apple praised the commission for seeking to take a balanced approach to future spectrum allocation and enable future technologies, but expressed concern about potential conflict with the aforementioned international efforts in the spectrum and overall limitation of unlicensed opportunities.
“While it is true that this spectrum is a largely ‘blank slate’ today, there are already concrete examples of likely uses for these bands which should be considered in the Commission’s decision making,” Apple said, but went on to add that “prematurely restricting operations above 95 GHz—by, for example, creating only a few narrow unlicensed bands—without reliable information about the technical characteristics of future systems may also threaten future U.S. competitiveness in emerging wireless technologies.”
“By proposing that only a small fraction of the spectrum it allocates should be available for unlicensed use, the Commission reduces the band’s potential to support new innovation and growth,” Apple argued. “It also undermines the balance between specificity and generality that the Commission seeks as a means to avoid the costs and inefficiencies of misallocating spectrum. We therefore recommend that the Commission increase the fraction of the spectrum that it opens to unlicensed spectrum. It need not achieve parity between licensed and unlicensed bands, but the current approach far too heavily preferences licensed technologies.”
