Comprehensive nationwide study, based on a detailed engineering analysis, demonstrates the feasibility of unleashing 12 GHz for 5G deployment while coexisting with other services in the band.

The creation of flexible-use licenses for two-way mobile broadband in the 12.2-12.7 GHz spectrum band could represent over $1 Trillion in U.S. consumer welfare.

Today, RS Access, LLC submitted comprehensive Comments and studies to the Federal Communications Commission (FCC) in response to its Notice of Proposed Rulemaking, showing that Americans will benefit tremendously from unleashing 12 GHz for 5G mobile use. The filing includes two groundbreaking studies – a detailed analysis of the technical feasibility, performed by RKF Engineering Solutions, LLC, and an economic analysis of the public-interest benefits by The Brattle Group, Inc.

RKF Engineering Analysis

The engineering analysis that RS Access entered into the record was produced by RKF Engineering, a preeminent engineering firm with decades of experience in modeling Radio Frequency environments in collaboration with leading telecommunications companies and global regulators. It is the most comprehensive analysis of coexistence between 5G and Non-Geostationary Orbiting (NGSO) satellite broadband systems to date – modeling a nationwide 5G network¹ and a scenario with a generous estimate of 2.5 million future NGSO user terminals² – and finds that coexistence is not only feasible, it is easily managed with very little impact on future consumers.

“This comprehensive, nationwide engineering study demonstrates that unleashing 12 GHz for 5G deployment and coexistence with other services in the band is highly feasible,” said David Marshack, COO of RKF Engineering. “This is the ‘win-win’ that the FCC has been looking for in this band.”

The study estimates that a nationwide 5G network may impact fewer than one percent of NGSO terminals. The impact on hypothetical NGSO users would be very small and mitigation solutions to make coexistence even easier are readily available through proven techniques such as channel selection and coordinating siting. These solutions are easy to implement while NGSO services are nascent, with a minimal number of actual subscribers.

“With the C-band auction complete, there is little other mid-band spectrum available for licensed flexible use,” said Tom Peters, former Chief Engineer of the Wireless Telecommunications Bureau at the FCC. “This analysis is by far the most comprehensive ever performed on the band and showed interference of less than one percent, should the FCC adopt new technical rules for terrestrial deployments.”

According to the report, enhancing flexibility in the 12 GHz band is not a zero-sum choice between broadband and terrestrial operations. RKF Engineering’s computational analysis considered millions of cases and found interference will be negligible. The analysis used the latest parameters for NGSO operator SpaceX, including modifications of the Starlink license approved by the FCC on April 26, 2021.

The engineering analysis found several factors that limit the potential for interference:

• Unlike the LEO systems envisioned in the past, Starlink user terminal antennas will utilize higher look-angles and have good rejection of terrestrial signals,
• Terrestrial base stations will use beamforming, which focuses energy towards the handsets being served, not satellite terminals. Handset power is low due to power control, and point-to-point links in the band will be highly directional,
• The tendency of 5G networks to be used largely in areas of higher population density, while Starlink terminals will primarily be in lower-density areas.

The Brattle Group Economic Analysis

A separate economic analysis entered into the record by RS Access shows that a coexistence solution would allow consumers to reap the benefits of 5G, DBS, and NGSO services in the 12 GHz band with a social-welfare benefit that is between $264 billion and $1 trillion. Conducted by Coleman Bazelon and Paroma Sanyal of the Brattle Group, a highly recognized, global economics firm, the study carefully considers a wide variety of factors, including how the 12 GHz band may be used in networks, recent auction data and the current and future U.S. and global spectrum landscape.

“Introducing flexible-use licenses for two-way mobile broadband in the 12.2-12.7 GHz band will meet a need for more spectrum to support U.S. telecom competitiveness” said Dr. Coleman Bazelon, lead economist of the report. “It’s a clear win-win for consumers; a rules update and coexistence framework would address the rapidly evolving use cases for this spectrum and an explosion in demand for mobile 5G services.”

The study found that the 12 GHz band has extraordinary utility due to its propagation characteristics, spectral efficiency, capacity, potential channel sizes, and use cases for small cells, fixed wireless, and backhaul. It estimates that the value of the 12 GHz band if enabled for terrestrial 5G use ranges from $27 to $54 billion.

“CTIA’s 2020 Annual Survey reported U.S. wireless subscriber growth increased by 20 million for a total of 442.5 million subscribers,” said Dr. Bazelon. “The 12 GHz band offers the FCC an opportunity to reorient its rules toward a future that will best serve the public interest.”

Unlike other FCC spectrum reviews that faced technological and political challenges, there are no federal encumbrances in the 12 GHz band, and the FCC can expand 5G broadband in the band without harming satellite stakeholders’ interests.

The benefits for America of accelerating 5G deployment in the band are clear, RS Access looks forward to working with the FCC to make those benefits a reality.

About RS Access

RS Access holds eighty spectrum licenses in the 12 GHz band and operates wireless systems across sixty U.S. markets. The company services clients in various niche and underserved areas, helping a range of customers connect. Deployments range from wireless services at public safety training facilities and educational institutions to veteran organizations and municipalities.

About RKF Engineering Solutions

RKF is a boutique engineering firm concentrating innovative engineering solutions for long-range wireless communications. Since its founding in 2001, the company has been a key pillar for numerous government and commercial clients around the world, providing critical regulatory, advocacy, systems engineering, and software development expertise and capabilities supporting satellites and terrestrial networks as well as high-altitude platforms and Earth Stations in Motion

About The Brattle Group

The Brattle Group answers complex economic, regulatory, and financial questions for corporations, law firms, and governments around the world. We aim for the highest level of client service and quality in our industry. We are distinguished by our credibility and the clarity of our insights, which arise from the stature of our experts; affiliations with leading international academics and industry specialists; and thoughtful, timely, and transparent work. Our clients value our commitment to providing clear, independent results that withstand critical review. Brattle has over 400 talented professionals across three continents.

¹ The study models a nationwide 5G network of 50,000 macrocells and a Starlink deployment of 2.5 million user terminals. The 5G network includes an additional 90,000 small cells and 7,000 backhaul links, and further generously assumes that every 5G macrocell in the network has 30 simultaneously active handsets, supported using beamforming, while every small cell supports 5 simultaneously active handsets. The base stations are deployed throughout the country, focusing on urban areas but including many small towns outside the major metropolitan areas.

² The Starlink terminals use the parameters of SpaceX’s third modification, including a minimum elevation angle of 25°. The study assumes that the Starlink terminals are adopted in all areas of the country, but most aggressively in areas with limited options for internet service. This is modeled by placing 1.7 million terminals in areas that were eligible for RDOF support, while 0.8 million were placed outside RDOF-eligible areas.