6 GHz License Exempt: Why the full 1200 MHz and why now?
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6 GHz
License Exempt:
Why the full 1200 MHz
and why now?
Dynamic
Apple Inc. Broadcom Inc. Cisco Systems Inc. Facebook Inc.
Spectrum Alliance
Hewlett-Packard
Google LLC Intel Corporation Microsoft Corporation Qualcomm Incorporated
Enterprise
3
SUMMARY
I. Introduction and
summary
6
II. Opening the full 6 GHz band for
license-exempt technologies is important
and necessary
6
A. The technology imperative for 1200 MHz
– current and future use cases driving
demand, density and high bandwidth
B. An allocation of 500 MHz in lieu of
the full 5925-7125 MHz is not sufficient 11
13 C. Social and economic benefits flow
from designating the full 6 GHz band to
license-exempt use
D. Wi-Fi technology, standards, and
interoperability are all in place today, ready
for regulatory action
17
18
The
opportunity
cost
F. With the right regulatory framework, FS
and FSS incumbents can continue and
grow their primary licensed uses
23
23
Apple, Inc., Broadcom, Inc., Cisco
G. Permitting license-exempt
Systems, Inc., Dynamic Spectrum
technologies throughout the full 6 GHz
Alliance, Facebook, Inc., Google LLC,
band is the best way to support both...
Hewlett-Packard Enterprise, Intel
25
Corporation, Microsoft Corporation,
and Qualcomm Incorporated
III. Countries should promptly adopt a
license-exempt model for the full
6 GHz band
August 2021
I. INTRODUCTION
AND SUMMARY
In the almost two decades since thermostats, sprinkler controllers, and
countries globally implemented the more. At work, Wi-Fi supports access
World Radio Conference 2003 deci- to enterprise networks for a range of
sion to open new spectrum in the 5 applications, supports a variety of
GHz range to license-exempt devices, data communications, and connects
there have been revolutionary chan- all types of devices including robots,
ges in Wi-Fi technology, use cases, and autonomous vehicles in warehouses,
demand. In a relatively short amount factory equipment, screens and whi-
of time, Wi-Fi technology has moved teboards. At play, there is not a sta-
from an amenity that helps make dium being constructed today that
broadband connectivity more use- does not have extensive Wi-Fi capa-
ful to an essential part of broadband bility for fans, vendors, and adminis-
delivery and an essential element in trative and team support. New uses
enabling businesses to get work done for Wi-Fi have also appeared to ad-
-driven in part by the rise to domi- dress rural or disadvantaged popu-
nance of mobile devices and the ex- lations, stemming from the need for
pectation of near-ubiquitous wireless low-cost infrastructure to help ex-
connectivity. In the home, Wi-Fi ena- pand services to the unserved. By any
bles multiple users to simultaneously measure, Wi-Fi is a massive success
access the Internet, fuels video strea- story that helps policymakers achieve
ming to smart TVs, connects applian- critical objectives in broadband poli-
ces to enable remote diagnostics and cy as well as in economic and social
repair, and powers security systems, policy areas.
Wi-Fi® is...
• The most commonly used wireless communications
technology
• The primary medium for global internet traffic
• A driver of $3.3 trillion USD in global economic value
• Growing, with more than 4 billion devices shipping
annually and 16 billion devices in use*
*IDC
Source: Wi-Fi Alliance
3
As companies and organizations that are device manufacturers, chipset ven-
dors and applications providers that rely on license-exempt, licensed, and sha-
red spectrum, we are excited to be part of a wireless industry that has done so
much to advance global quality of life and economic growth. A key part of our
job is to continue to innovate on the massive success already enabled by Wi-Fi.
To do that, license-exempt spectrum access to the entire 5925-7125 MHz band is
critical. This paper explains the technological reasons for this, and why recently
introduced competing proposals are poor alternatives in comparison to ope-
ning the full 6 GHz band to license-exempt technology.
This White Paper consists of several sections that explain the essential need for
availability of the full 1200 MHz from 5925-7125 MHz to support Wi-Fi and 3GPP’s
New Radio-Unlicensed.
• Opening the full 6 GHz band to license-exempt Radio Local Area Network
(RLAN) technologies is the best public policy choice for regulators globally.
The full 1200 MHz is needed to supply new technologies with the spectrum
necessary to deliver on current and emerging innovative use cases, now
and in the future. With just 500 MHz, license-exempt technologies will be
unable to support advanced use cases or support even routine consumer
and enterprise networking needs in a few short years.
• The social and economic benefits of moving forward with allowing licen-
se-exempt usage throughout the full 6 GHz band are many. Addressing
the digital divide, improving rural connectivity, accelerating economic
innovation, advancing energy efficiency through smart buildings and im-
proving quality of service are just a few benefits that regulators can look
forward to when they open the full 6 GHz band to license-exempt use.
• 6 GHz Wi-Fi technology is ready now. Standards are complete; interopera-
bility certification is open, and equipment is moving into the market today.
Benefits from spectrum use are available immediately.
• Failure to act brings with it large opportunity costs. Any benefit of reserving
a portion of the spectrum for a later decision on whether to allow IMT is en-
tirely speculative and essentially nonexistent. No IMT specifications are in
place nor is there any commercially available IMT equipment for this band.
Significant questions remain about technical feasibility of IMT use. One thing is
certain if IMT to allowed in the upper portion of the 6 GHz band: Delay, which
would result in immediate lost economic gains that would have accrued ins-
tead from opening the full 6 GHz band to license-exempt operations.
• License-exempt services in the 6 GHz band, operating under appropriate
regulatory conditions, enable incumbents to continue – and to grow –
their operations in the band while protecting them from harmful inter-
ference. Traditional wide-area IMT deployments in the band, however,
would likely require that incumbents be cleared and/or relocated.
• The best way to support 5G deployment in the 6 GHz band is to autho-
rize license-exempt use throughout the entire 1200 MHz of the band,
which supports mobile offload, 5G backhaul, and 5G NR-U operation.
4 6 GHz License Exempt: Why the full 1200 MHz and why now?
Republic of Korea
Costa Rica,
Guatemala,
Honduras Taiwan
1200 MHz
Jordan,
1200 MHz Consultation Qatar,
500 MHz Oman
500 MHz Consultation
TBD (early in process)
No formal activity yet
Source: Wi-Fi Alliance
This paper draws on the work of nume- As of today, regulators globa-
rous regulatory agencies globally that have
already designated the full 6 GHz band for lly have reached a remarkable
use by license-exempt technologies. Since and swift consensus with 6 GHz
the United States Federal Communications
Commission (FCC) released its decision in regulatory decisions covering
April 2020, and with the European examina- nearly 54% of the global GDP,
tion of coexistence with incumbents drawing
to a favorable close during the final months and nearly 42% of GDP having
of 2020 and into early 2021, global momen- opened or proposed opening
tum toward opening the 6 GHz band for licen-
se-exempt RLAN technology has been explo- the full 6 GHz band to
ding. Importantly, in February, Brazil was one
of the first Top 20 economies in Region 2 in
license-exempt use.
2021 to join the FCC in opening 5925-7125 MHz
to license-exempt technologies, while Repu- now pending to open the full band in Japan,
blic of Korea was the first in Region 3 in Oc- Mexico, Australia, Colombia, Qatar, Jordan,
tober 2020. Saudi Arabia boldly announced New Zealand, and Oman.
in March to its fellow Region 1 countries that Countries that have opened the lower 500
it also would open the 5925-7125 MHz band MHz for license-exempt use also have made
to license-exempt use. Canada’s Innovation, important contributions. The European Com-
Science and Economic Development (ISED) mission in June 2021 published its decision
soon followed in May, announcing that it is to open the band to license-exempt equip-
opening the full 5925-7125 MHz band to licen- ment after exhaustive study of the impact to
se-exempt use. Many countries have similar- fixed satellite uplink and to fixed microwave
ly been active in embracing license-exempt services. In both cases, the European process
use of the full 6 GHz band. Peru, Costa Rica, found that license-exempt equipment could
Chile, Honduras, and Guatemala have all fi- operate in the band without causing harm-
nalized changes to their Table of Allocations ful interference to incumbent users, provided
or to footnotes opening the full band as licen- that mitigation rules, such as limiting power
se exempt. Consultations or proceedings are levels, were applied. However, regulators –
5
and particularly those in countries Recently, the Wireless Broadband Allian-
outside Region 1 – should not assume ce commented that Wi-Fi usage grew
that a 500 MHz license-exempt desig- by 80% during the pandemic.
nation is sufficient or that Europe will in While those who were connec-
the future conclude that it is adequate. ted placed unprecedented demands
In a little more than a year, the world on Wi-Fi networking capabilities, too
has transformed to welcome a new ge- many children, families, and rural bu-
neration of Wi-Fi into the 6 GHz band. sinesses remain unconnected or ina-
As of today, regulators globally have dequately connected. As we have wit-
reached a remarkable and swift con- nessed globally, cellular technologies
sensus with 6 GHz regulatory decisions alone have not solved the connec-
covering nearly 54% of the global GDP, tivity problem for those outside the
and nearly 42% of GDP having opened reach of mobile networks or for those
or proposed opening the full 6 GHz band who cannot afford mobile subscrip-
to license-exempt use. This swift action tions. The lack of IMT identified spec-
is happening in part because govern- trum is not the reason so many com-
ments around the world have recogni- munities lack adequate connectivity.
zed the key role that robust broadband As policymakers prepare to consider
connectivity plays in the lives of their the opportunity presented by allowing
citizens, its importance to their econo- license-exempt use in the full 6 GHz
mies, and in supporting national 5G de- band, putting this spectrum to work
ployments. The Covid-19 pandemic has now to help people and economies
brought these realities into sharp focus. should be a top priority.
II. OPENING THE FULL 6 GHZ BAND
FOR LICENSE-EXEMPT TECHNOLOGIES
IS IMPORTANT AND NECESSARY.
A. The technology imperative for 1200 MHz – current
and future use cases driving demand, density and high
bandwidth
Delivery of broadband access is broadband access and quality. For
a continuously-evolving challenge. companies that develop equipment
Since broadband access was intro- and networks using license-exempt
duced to consumers in the 1990s, the spectrum, we must look ahead to fu-
use of broadband networks, the appli- ture use cases, applications, and de-
cations that run on these networks, mands that are not yet in the market,
the throughput capability of devices, and do our best to help create today
and the density of device deploy- the regulatory and technology envi-
ments continues in an unrelenting ronment that will address the expo-
upward trajectory. Most people’s ac- nentially increasing consumer and
cess to their fixed broadband network business requirements of tomorrow.
is through Radio Local Area Network Consumers, businesses, and gover-
(RLAN) devices such as Wi-Fi routers; nmental agencies around the world
thus, RLAN access and quality equals will be able to take full advantage of
6 6 GHz License Exempt: Why the full 1200 MHz and why now?
the technology evolution that industry has identi-
fied. Among other things, a wholly-new generation
of RLAN technologies in the 6 GHz band will be ena-
bled to address future networking needs for broad-
band access and beyond.
The last time a significant new designation of
license-exempt spectrum for RLAN technology was
made available was in the early 2000s, following the
2003 World Radio Conference. This activity opened
new spectrum bands in the 5 GHz range, which were
at that time optimal for earlier generations of RLAN
technology, such as Wi-Fi 4, and later, Wi-Fi 5. In the
almost two decades since that time, the equipment
used for broadband networking, use cases, and
applications, as well as engineering challenges to
meet demand, have evolved considerably. In addition,
the number of devices per user is proliferating. The
capability of those devices – in processing power,
screen resolution, streaming video support (now
at 4k/8k HD), camera performance, and antenna
Device evolution
requires improvements
in network capability iPhone 12 ProMax -
128,000 songs, up to
512 Gbps of memory,
a 6.7 inch screen with
iPhone 1 - 2,000-
a resolution of 2778
8,000 songs, up to
x 1284, and a more
32 Gbps of memory,
versatile camera
a 3.5 inch screen size
capability, powered
with a resolution of
by a vastly more
480 x 320.
powerful processor.
functionality to name a few – has increased
exponentially. Devices are deployed in increasingly
dense residential or enterprise environments, and
the broadband networks they connect to, whether
wired or wireless, are also greatly improving in
throughput and latency. But it is not simply the
relentless improvements in devices that is increasing
demand. New applications, such as consumer
gaming or enterprise Advanced Manufacturing,
demand low latency transmissions. An explosion
in Augmented Reality/Virtual Reality/Mixed Reality
(AR/VR/MR) technology is soon expected to impact
7everything from how we learn to how in developing Asia. However, variable
we work and play. While that capability pricing by market (at different
exists today, connectivity must expand purchasing price levels) could result
and improve for these services to be in a more affordable service offering.
placed into routine use by citizens and Similarly, community Wi-Fi models
businesses. As that occurs, devices could be deployed, such as those
will be produced at scale and will be being implemented by Hughes/
differentiated by use case. Express Wi-Fi in Indonesia and
Latin America where an individual
subscription supports time- or data-
bound service to potentially hundreds
Augmented Reality - digital informa- of users consuming small data
tion layered over the real world bundles (in the megabytes) through
“Many of our enterprise clients, es- a publicly accessible Wi-Fi access
point. Areas of limited subscriber
pecially in construction and medical
base may be opportunities for direct
sectors, are embracing AR headset de- or subsidized partnerships. -- ADB,
vices to provide hands-free enhanced Digital Connectivity and Low Earth
vision for planning, design and patient Orbit Constellations, ADB Sustainable
care and training,” says Sam Watts, Development Working Paper Series,
immersive partnerships director at April 2021.
immersive learning and development
studio Make Real. For rural and unserved areas, it is clear
that license-exempt technology is es-
AR is also beneficial for any industry sential to enabling affordable services.
that relies on planning and visualisa- To further illustrate the dilemma
tion, this includes almost any type of faced as license-exempt technology
design and conceptualisation needs. producers look to the future, take
“We have a number of onsite AR tools, an example where access points
using Microsoft HoloLens, to visualise (APs) must be deployed in a dense
configuration, such as a school,
construction when the real world is just
manufacturing plant, office, hospital,
a cleared, muddy plot,” Watts tells us. transportation hub, multi-tenant
--AR smartglasses in 2021: the devices, apps housing, or stadium. Each of these
and new tech coming, Wareable.com posted 14 locations increasingly relies on license-
June 2021 exempt spectrum for broadband
operations. As demand has increased,
Rural Internet access networks that Wi-Fi APs have been deployed more
use Wi-Fi (e.g., as part of a 60 GHz mesh densely, adding more capacity within
or TV White Spaces Network) and Wi-Fi the same overall network area. In
at the edge of satellite links and new general terms, the coverage area for
low earth orbit satellite constellations an enterprise indoor AP has decreased
are also evolving use cases that will from ~500-1000 meters2 in 2003, to
give regulators new tools to address ~250 meters2 by 2010, to as little as ~150
unserved or underserved populations. meters2 today. The practical limit of how
According to a recent review of the densely APs can be deployed has been
new low earth orbit constellations by reached due to the resultant increase
the Asia Development Bank: in radio frequency interference (both
co-channel and adjacent channel
At the current public beta pricing interference). The only way to add
level, Starlink’s $99 monthly plan is capacity in these situations is through
not affordable for many consumers the use of multiple wider channels of
8 6 GHz License Exempt: Why the full 1200 MHz and why now?160 MHz and 320 MHz, which would be reductions in efficiency and determinism
enabled by opening the full 1200 MHz of that in turn further negatively impacts
the 6 GHz band. voice and video quality. Wi-Fi 6 in
Forty (40) MHz channel sizes are the 6 GHz band (known as Wi-Fi 6E)
increasingly insufficient to address the is not required to interoperate with
steep growth in the number of devices any previous generation of 6 GHz Wi-
and higher bandwidth requirements per Fi technology because no Wi-Fi has
user. A typical two-stream client device yet existed in the 6 GHz band. The
can only achieve up to a 574 Mbps 6 GHz band would, for the first time,
data rate when operating in a 40 MHz eliminate outdated and less efficient
channel with Wi-Fi 6. When the channel radio access technology, permitting
width is increased to 80 MHz or 160 MHz, the far more spectrally-efficient Wi-Fi
the data rate is increased to 1.2 Gbps 6E (and above) to operate without the
and 2.4 Gbps respectively, fully enabling burden of legacy radio interoperability.
the “gigabit wireless” era. To retain This will dramatically improve the user
the current quality of service for users experience and spectral efficiency,
in the future, 80 MHz-wide channels which will promote the adoption of
are required; to increase the quality advanced Wi-Fi technologies.
of service, 160 MHz-wide (and larger) Considering all of these challenges,
channels are required. With those wide the license-exempt technology indus-
channels, the radios can get on and try concluded that Wi-Fi 5 and earlier
off the air more quickly, delivering the technology would soon be insufficient
high-bandwidth content users demand to deliver the required level of broad-
while maintaining the ability to share band and related capabilities in the
spectrum with other license-exempt near future. Industry’s response was
transmitters. Lack of wider channels twofold – 1) to develop new, advanced
would create a detrimental impact technologies and 2) to find mid-band
on real-time video services, and high- spectrum that could support the chan-
bandwidth immersive services such as nel widths required for these new tech-
AR/VR/MR will be starved of sufficient nologies.
capacity. There is no realistic possibility First, we redesigned technology to
of delivering multiple 160 MHz wide enable a new approach to address
channels on existing 2.4 GHz and 5 GHz dense networking, low latency, and
spectrum allocations, which are too higher-bandwidth needs. For example,
fragmented and which were allocated deployment of OFDMA as part of Wi-
in an era of now-outmoded generations Fi 6 fundamentally improves spectral
of RLAN technology. efficiency, enabling an AP to com-
To add to the engineering challenge, municate individual packet streams
radios in the 2.4 GHz and 5 GHz bands to multiple clients at the same time.
today consist of multiple generations In addition to adopting OFDMA, some
of equipment with a variety of less of the most important innovations in
spectrally-efficient capabilities. This is the Wi-Fi 6 generation of technology
a design necessity because networks are: (1) multi-user MIMO that allows
must be able to communicate with more downlink data to be transferred
older generations of radios. Therefore, at one time, enabling APs to concur-
technologies like Wi-Fi are always rently handle more devices and sup-
backward compatible with previous port uplink as well; (2) 160 MHz channel
generations of Wi-Fi operating in the utilization capability increases band-
same frequencies. The additional width to deliver greater performance
requirement of interoperability between with low latency; (3) Target Wake Time
Wi-Fi generations and the burden of (TWT) significantly improves network
backward compatibility results in further efficiency and device battery life, in-
9Band Channels BW
2.4 GHz
3 20 MHz 60 MHz of Spectrum &
1 40 MHz 3 Channels Allocated
25 20 MHz DFS
12 40 MHz
5 GHz 500 MHz of Spectrum &
6 80 MHz
25 Channels Allocated
2 160 MHz
5170 5330 5490 5730 5735 5835
MHz MHz MHz MHz MHz MHz
60 20 MHz
29 40 MHz 1,200 MHz of Spectrum &
6 GHz
14 80 MHz 60 Channels Available
7 160 MHz
5925 6425 6525 6875 7125
MHz MHz MHz MHz MHz
cluding for IoT devices; (4) 1024 QAM and 100 MHz channels of mid-band
modulation increases throughput for spectrum per operator to support 5G
emerging, bandwidth-intensive uses services, the next generations of licen-
by encoding more data in the same se-exempt technologies (e.g., Wi-Fi 7,
amount of spectrum; (5) transmit and 5G NR-U) also utilize wider chan-
beamforming enables higher data nel bandwidths. The additional 1.2 GHz
rates at a given range to increase net- of spectrum on which Wi-Fi 6E will run
work capacity; (6) addresses exces- provides a roughly equivalent num-
sive management overhead relative ber of 80 MHz channels in 6 GHz band
to prior generations; (7) supports “Out spectrum as there are 40 MHz channels
of Band” discovery of networks, further in the 5 GHz band. For the first time, 80
reducing management overhead; and MHz channel plans would be possible
(8) strict scanning rules prevent un- from a “best practices” perspective in
necessary use of spectrum (e.g., only dense deployments. Contiguous spec-
scans on a subset of the 6 GHz band trum would also support seven 160 MHz
channels). These innovations are a wide channels and multiple 320 MHz
generational improvement in Wi-Fi wide channels, which are expected with
technology, designed to take on the the next generation of Wi-Fi now going
demands that future devices, applica- through the IEEE standardization pro-
tions, and use cases will present. cess (i.e., IEEE 802.11be). The Wi-Fi Allian-
Second, to provide the spectrum ce has named Wi-Fi 6 devices enabled
needed to make these technologies for the 6 GHz band as “Wi-Fi 6E” devices.
practical, industry identified a large This is important not only because Wi-Fi
and contiguous allocation of spectrum, is always backward compatible to ear-
specifically 5925-7125 MHz, to support lier generations, but because Wi-Fi 6E
the wireless industry’s need to migrate devices are designed so that tri-band
to multiple wide channels. Just as the radios will be the norm, enabling legacy
cellular industry is migrating to 80 MHz support in the 2.4 GHz and 5 GHz bands
10 6 GHz License Exempt: Why the full 1200 MHz and why now?as well. With the full 6 GHz band, the RLAN are complete, these improvements will
industry can continue to play its important enable lower latency, higher throughput,
role in delivering broadband access, faci- and more deterministic networking capa-
litating the IoT, and enriching experiences bility (e.g., higher reliability or QoS) relative
at work, home, and play. to Wi-Fi 6E. These features provide a step
In fact, Wi-Fi 7, which is currently being function increase in terms of enabling Wi-
standardized in IEEE as 802.11be, relies on Fi to address immersive services with de-
access to the greenfield spectrum of the manding QoS requirements for a larger
6 GHz band to deliver its greatest inno- number and diversity of applications, de-
vations, which could include numerous vices, and use cases, in particular those of
improvements to make Wi-Fi even more industrial IoT. In addition, these improve-
useful to users and applications that are ments scale throughput capability to fu-
currently in draft form or under discussion. ture upgrades in access network capacity
While the need for 320 MHz-wide channels (e.g., 10G Fiber, DOCSIS 4.0, Fixed Wireless)
has been widely discussed, other innova- allowing the RLAN wireless network to evol-
tions are also important. This new genera- ve with the broadband access connec-
tion of technology will operate at 4096 QAM tions. However, if there is insufficient spec-
and permit “multi-link operation” that can trum available to make Wi-Fi 7 capabilities
use the 2.4 GHz, 5 GHz, and 6 GHz spectrum compelling to someone purchasing a new
bands simultaneously. Once standards AP, Wi-Fi 7 may not see widespread use.
B. An allocation of 500 MHz in lieu
of the full 5925-7125 MHz is not sufficient
If only 500 MHz of 6 GHz spectrum were no analyst projects that the curve will
made available, networks would effecti- flatten for the foreseeable future. That is
vely need to operate in a manner similar because the advantages of connectivity
to the scenario playing out in the 5 GHz continue to multiply: smart televisions
band today. Opening only 500 MHz of the that allow user choice in video streaming,
6 GHz band would require channel plans connected security devices from video
in dense deployments to continue relying camera doorbells to whole home
on 20 MHz or 40 MHz bandwidths. In coun- systems, and smart appliances that
tries allowing access to just 500 MHz, users allow manufacturers to download new
would not be able to take full advantage generations of software are examples of
of the benefits of Wi-Fi 6 (and eventually the types of new capabilities that were
Wi-Fi 7) in the 6 GHz band, lower service not in existence before the mid-2000s.
quality will be the norm, and congestion Nor are the coming challenges limited
will fall on users of Wi-Fi in enterprises, to consumers. Hospitals increasingly
schools, transportation hubs, and other rely on video and robotics. Schools at
public venues. all levels require connectivity to each
For consumers, congestion issues arise student’s laptop or tablet, and they are
as the number of high-demand Wi-Fi seeing increased demands on their
enabled devices in a home continues wireless networks from security systems
to multiply. Countries such as Japan, to remote learning. Whole industries
Korea, and the United States are already are transforming how they operate by
at 12-14 devices per capita, and the deeply integrating wireless technologies
continued integration of license-exempt into their business operations. Cisco has
technology into consumer durable goods projected that globally, machine-to-
promises that the number of devices in machine modules will account for 50%
a home will continue to grow. Indeed, (14.7 billion) of all networked devices by
112023, compared to 33% (6.1 billion) in
2018.
With only a 500 MHz allocation of 6
GHz band spectrum, spectrum cons-
Many types of equipment
traints will not, over time, support a are expected to support
good user experience particularly as
applications evolve toward new im- the entire 1200 MHz of the
mersive services. More devices would 6 GHz band, as the United
contend for airtime in the same fre-
quencies as IoT and cloud-based States, Brazil, Canada, Sau-
analytics proliferate. Users would have di Arabia, and the Republic
a very mixed experience where appli-
cations might work in some locations, of Korea are enabling the
such as within certain portions of their
home, and might not work well in other
band for such operations,
portions or in their businesses, public with many other countries
areas, and venues. Inconsistent band-
width delivery has consequences well expected to do so in 2021.
beyond consumer unhappiness – it
inhibits innovation generally and may
even stop developers from successfu-
lly creating and delivering new appli- to take advantage of that channel
cations. size. Opening all 1200 MHz of the 6
A “wait and see” approach, where 500 GHz band now enables countries to
MHz is allocated now and the balance realize a stronger and more diverse
of the band is allocated sometime in license-exempt ecosystem, which will
the future, is a poor option. As discussed benefit the entire nation when 6 GHz
further below, there is an opportunity applications and services are rapidly
cost for countries that decide on a deployed.
staggered approach to spectrum Many types of equipment are
allocation compared to nations that expected to support the entire
decide to designate 1200 MHz from 1200 MHz of the 6 GHz band, as the
the outset. One main drawback is the United States, Brazil, Canada, Saudi
opportunity cost of impaired use cases Arabia, and the Republic of Korea are
and inability to fully meet broadband enabling the band for such operations,
needs, especially in dense enterprise with many other countries expected
and urban environments where more to do so in 2021. Due to the need to
than three wideband channels (of limit manufacturing and logistical
160 MHz and greater) are required. complexity, most 6 GHz equipment
Countries that only designate 500 MHz will be designed to support the full
of 6 GHz band spectrum will be unable 1200 MHz, with firmware settings used
to reliably support high-throughput as necessary to limit operation to the
and low-latency applications in lower 500 MHz. Without the full 1200
all environments where those MHz available, consumers of 6 GHz
applications need to perform. When Wi- equipment would not benefit from the
Fi 7 standards are completed in about higher throughput and lower latency,
three years, industry will implement but would nevertheless pay for the
channels up to 320 MHz wide. Countries more complete technology that they
that only designate 500 MHz of 6 GHz are unable to use.
band spectrum for license-exempt Nor is there another spectrum band
use will not be able to fully experience available that compares to the 6
the benefits of applications built GHz band and can deliver the same
12 6 GHz License Exempt: Why the full 1200 MHz and why now?benefits. Most importantly, the 6 GHz logistics, agriculture, rural broadband,
band is adjacent to the 5 GHz band, higher education, hospitality, healthcare,
enabling easier deployment of tri-band and municipal. Standard Power
radios using 2.4 GHz, 5 GHz, and 6 GHz would operate in conjunction with an
band frequencies. From a consumer Automated Frequency Coordination
perspective, 6 GHz band frequencies will (AFC) geolocation database capability,
deliver a consistent experience similar which is aware of incumbent user
to that of the 5 GHz band assuming that operations and can safely authorize
reasonable power levels are adopted. Standard Power license-exempt use at
From a regulatory perspective, license- a particular location while protecting the
exempt radio systems are highly incumbents from harmful interference.
complementary to incumbent systems Because of this requirement to avoid
and can coexist given the appropriate and protect incumbent services, the
regulatory rules – and the incumbent frequency ranges or channels that will
systems are similar around the globe, be available at any particular location
which facilitates reasonably uniform will often be only a subset of the overall
sharing obligations on license-exempt spectrum that has been allocated for
devices as more countries open the 6 potential Standard Power use by the
GHz band. regulator. Importantly, the countries
Another important consideration for that have either already supported
countries initially authorizing only Low Standard Power or are actively studying
Power Indoor (LPI) and/or Very Low Power it, including the United States, Canada,
(VLP) operations in the 6 GHz band is South Korea, and Saudi Arabia, have all
preserving the opportunity for Standard moved to open the entirety of 5925-7125
Power (higher power indoor and MHz for license-exempt use in the Low
outdoor) license-exempt operations. To Power and/or Very Low Power modes
date, regulators in the US and Canada of operation. This allows for blocking
have concluded that authorizing or protecting certain frequencies or
Standard Power devices can be done channels at particular locations, while
in a manner consistent with protecting still yielding a sufficient number of wide-
incumbent fixed satellite services as bandwidth channels to support next-
well as fixed microwave through the generation RLAN services. Opening the
combined efforts of power levels, full 1200 MHz of the 6 GHz band to license-
projected number of outdoor devices, exempt use will provide the overall
and geolocation database controls spectrum needed to support Standard
on the RLAN networks. Standard Power Power under AFC control, whereas 500
use cases are particularly important MHz would be insufficient for Standard
to a number of deployment types and Power in the age of 80, 160, and 320 MHz
settings, including manufacturing, channels.
C. Social and economic benefits flow from designating
the full 6 GHz band to license-exempt use
Expanding spectrum availability for to play, particularly in offering low-
license-exempt technologies will help cost mechanisms for multiple users
governments everywhere address in a household to connect to the
improvements in broadband access Internet. License-exempt technologies
for their populations and help close are embedded in a wide array of
the digital divide. RLAN technologies client devices, from laptops to tablets
such as Wi-Fi have an important role and smartphones, that are part of a
13Digital Divide - Here and Now
Key Facts 2021 Digital Divide to be Overcome
Many rural and low-income communities around the world, including
4.7 billion + those in large urban areas, lack reliable, affordable access.
people use the Internet Global internet
penetration:
of schoolchildren (463 million) can not
35 billion access remote learning due to a lack of
devices 59.5% 31% necessary technological assets at home,
or because they are beyond the reach of
will be connected to
targeted programs
the Internet by 2021,
every minute.
75% of students not 1.3 billion
SOCIAL There are now 4.2 billion able to access remote
School-aged children
MEDIA social media users around the world learning, live in rural areas
can’t log on to internet
and/or belong to poorest
This figure has grown by at home
households
490 million
500 hours over the past 12 months,
13% Lack of coverage is one reason for this:
of video is uploaded to
delivering year-on-year
growth of more than: 47% 3.6 billion people Approximately 10% of the world’s people live
YouTube every minute, (47%) do not use the Internet. beyond the reach of a mobile network
by 2022, of all Internet 83% Social media users now
Traffic, video will 53% represent more than 53%
account for about: of the world’s population Globally only 55% of
55%
Women are 23% households have internet
less likely to have access
In 2021, Within the calendar which leads to to internet than men In poorer countries this
year, total data used for 49% 1200+ Exabytes 20%
drops to below 20%
Wi-Fi alone accounts for: or 1.2+ Zettabytes
Sources: Digital 2021 GSMA Medium UNICEF UN NEWS WBA
WBA believes technology has the ability to do a
tremendous amount of good and help humans thrive
and achieve things that once seemed impossible.
Click Here to Get Involved
Source: with World
Wireless Wi-Fi Day
Broadband Alliance
and help to bridge the digital divide.
Wi-Fi is the great equalizer.
highly-competitive market that offers broadband arrangements. The Digital
consumers a range of choices in device Divide issue is so large and diverse
capability and price. Wi-Fi is also used that it is unlikely to be solved by any
to deliver rural broadband in areas one technology. Regulators should
where commercial wireline or wireless advance all technologies that may
services have not been deployed. be capable of addressing the Digital
With backhaul spectrum capability Divide, including low-cost options
similar to that in the 5 GHz band, TV enabled by license-exempt spectrum
White Spaces, or 60 GHz mesh, Internet technologies.
service operators can offer broadband Allocating the entire 6 GHz band to
connectivity to households served by license-exempt use provides important
a Wi-Fi AP within the home. Similarly, economic benefits. The Wi-Fi Alliance
satellite broadband connectivity also has conducted exhaustive studies
enables Internet access to a consumer with Telecom Advisory Services of the
inside the home, by using a Wi-Fi AP to impact of Wi-Fi on global and national
reach the end device. economies, concluding that globally,
Ample spectrum for license-exempt assuming regulators open the full 6
use also gives market participants GHz band to Wi-Fi, the $3.3 trillion in Wi-
and governments new tools to reach Fi value to the world’s economy in 2021
unserved or underserved populations will rise to $4.9 trillion in 2025. The study
and can help provide low-cost examined ten sources of economic
14 6 GHz License Exempt: Why the full 1200 MHz and why now?Source: Wi-Fi Alliance
value, including: increased license-exempt technologies.
broadband coverage and It also requires policymakers
broadband speeds; reduction to think about the broadband
of costs by telecommunications future that is possible. This
providers; deployment of IoT, AR/ supports a larger point - the
VR, municipal Wi-Fi, and free Wi- economic value of Wi-Fi will
Fi hotspots; benefits of aligning continue to rise as all forms
with other major economies; of broadband connectivity
increased capacity for cellular continue to proliferate and
offload; and access to Wi-Fi increase in speed – whether
equipment. fixed broadband as seen in
These projections reflect both the above chart or satellites
global conditions now and such as the new low earth orbit
in the coming years. In this satellite constellations or 4G/5G
regard, this economic forecast terrestrial mobile.
is similar to a technological A growing group of leading
forecast, but it differs in one regulators that have similarly
important regard – it depends concluded that the benefits of
upon regulators to open the license-exempt technologies are
6 GHz band to obtain the important to their national interests.
benefits that flow from robust Among the key benefits cited are -
15CITC “Importance of WLAN use in the Kingdom and substantial amount
of Wi-Fi traffic, which was exemplified during the COVID-19 lock-
downs, and the emergence of a promising device ecosystem that
can be taken advantage of starting from 2021.
“Most importantly, as explained in the Notice and in this Order, we
believe that providing new opportunities for unlicensed operations
across the entire 6 GHz band can help address the critical need
FCC
for providing additional spectrum resources for unlicensed oper-
ations. Making the entire band available for these unlicensed oper-
ations enables use of wide swaths of spectrum, including several
160-megahertz channels as well as 320-megahertz channels,
which promotes more efficient and productive use of the spec-
trum, and would also help create a larger ecosystem in the 5 GHz
and 6 GHz bands for U-NII devices.”
”ISED continues to be of the view that releasing the entire 1200
MHz of spectrum will immediately unleash the full potential of
the 6 GHz RLAN technology. Moreover, making the full 6 GHz band
available for licence-exempt use as soon as possible will maximize
the social and economic benefits that Canadians will derive from
this spectrum. The increased demand for broadband Internet and,
consequently, the spectrum required to support Wi-Fi enabled
ISED devices and applications for remote working and virtual learning,
has been demonstrated over the past year with the COVID-19 pan-
demic. Notably, current Wi-Fi capacity and speeds are the main
constraint, even in homes with high-speed wireline connections,
when a family unit is utilizing numerous Wi-Fi enabled devices.
This discrepancy will only become more amplified as available
wireline speeds increase. The additional licence-exempt spec-
trum will provide the improvements needed in Wi-Fi throughput
for homes and businesses and reduce congestion between neigh-
bours living in close proximity. The additional spectrum will also
support the ability for small wireless Internet service providers to
provide cost-effective enhanced broadband connectivity in rural
and remote areas.”
Regulators in many economies have se-exempt technologies. Regulators
agreed with these views, with South should put their countries on the same
Korea, Brazil, Chile, Costa Rica, Hon- path to align with the growing consen-
duras, Guatemala, and Peru already sus that the full 6 GHz band should be
acting to open the full band to licen- available for license-exempt use.
16 6 GHz License Exempt: Why the full 1200 MHz and why now?D. Wi-Fi technology, standards, and interoperability are all in place
today, ready for regulatory action
Equipment is available to consumers and res that consumers can purchase devices
businesses as soon as license-exempt use is with the confidence that the device will work
permitted in the 6 GHz band. RLAN operations with their router and with other devices. Mul-
can be introduced with mitigations to ensure tiple product vendors are already announ-
that existing users are not adversely impac- cing Wi-Fi 6E devices that use super-wide 160
ted, enabling countries to maximize benefits MHz channels and uncongested bandwidth
from the band without enduring the hards- in 6 GHz to deliver multigigabit, low laten-
hips of relocating incumbents. Enterprise, in- cy Wi-Fi. Per the Wi-Fi Alliance, “Wi-Fi CERTI-
dustrial, and governmental needs today and FIED™ provides a standards-based approach
in the future also can be more easily met with for product vendors to introduce secure and
the new generation of technologies designed interoperable Wi-Fi 6E products throughout
to operate throughout the entire 6 GHz band. the world, helping to create a diverse device
ecosystem.” The first set of products already
Standards are ready have been certified for interoperability.
The IEEE has extended the latest Wi-Fi standard, 6 GHz license-exempt equipment is entering
802.11ax (also known as “Wi-Fi 6”) to include the the market
6 GHz band. The standard is complete and has
been published. In addition to the IEEE standard, The United States FCC published its test re-
Europe’s ETSI BRAN EN 303 687 has reached quirements for the 6 GHz band, and the first
a “stable draft”, providing further support for devices have completed test review and
standards-based deployments. 3GPP-based approval. Then, FCC Chairman Ajit Pai marked
licensed-exempt technologies are also in the certification of the first device in Decem-
standards development, with New Radio- ber 2020 with the following statement:
Unlicensed included in Release 16 covering the
full 6 GHz band. We expect Wi-Fi 6E to be over two-and-a-
In addition, both the Wi-Fi Alliance (for IEEE 802.11) half times faster than the current standard.
and WInnForum (for 5G NR-U) are engaged in This will offer better performance for American
projects to standardize the interfaces between consumers at a time when homes and
Standard Power APs and AFCs. Standardization of businesses are increasingly reliant on Wi-
the interface helps simplify AFC implementation Fi. During the COVID-19 pandemic, we’ve
because the two interfaces will be known and all seen how Wi-Fi has enabled everything
documented, creating built-in incentive for AFCs from work-at-home to telehealth to remote
to utilize the standards. Standard Power APs can learning to streaming and gaming. Wi-Fi 6E
be manufactured and used with the confidence will turbocharge each of these and more, and
that the equipment will interface with any will also complement commercial 5G networks.
standards-compliant AFC. Bottom line: The American consumer’s wireless
experience is about to be transformed for the
Interoperability testing is ready better.
The Wi-Fi Alliance has named Wi-Fi 6 pro- With 6 GHz equipment testing rules now
ducts capable of operating in the 6 GHz band available, manufacturers can proceed to test
as “Wi-Fi 6E” devices and released a certifi- equipment, and Telecommunications Certi-
cation plan for global interoperability as of fications Bodies that receive the test reports
January 2021. Interoperability testing has be- prior to the certification application procee-
come the hallmark of technologies that use ding to the FCC laboratory can begin their re-
license-exempt spectrum, because it ensu- view of manufacturer testing and begin inde-
17pendent testing. Dozens of successful 6 GHz National Radio Research Institute has an- equipment certifications have been comple- nounced its revision of the test method for ted, with significantly more expected this year. conformity assessment of radio equipment Similarly, in Europe, with the ETSI standard for the 6 GHz band. The Wi-Fi Alliance now reaching the stable stage, and with the first projects that 340 million Wi-Fi 6 (802.11ax) de- stage of the European process reaching vices will be sold in 2021 globally, with about completion, equipment is entering the Euro- 20% of them (or 68 million devices) 6 GHz- pean market as individual countries com- ready. Shipments of 6 GHz-capable Wi-Fi 6 plete steps to adopt the European findings devices are expected to ramp up very quickly into national rules. And, the Republic of Korea’s in 2022 and beyond. E. The opportunity cost of opening less than the full band to li- cense-exempt use RLAN is great, with very limited near-term bene- fits attributable to an IMT designation There is a real and significant opportunity identify 6 GHz as a pioneer band for 5G, and cost to countries from not opening the full 6 GHz the IMT community did not even mention the 6 band for license-exempt use. As described in GHz band for their 5G needs. Most importantly previous sections, the footprint of geographies from a cost-benefit analysis perspective, the that have already opened the full 6 GHz band IMT community did not advance the use of 6 ensure that there will be a global market for GHz frequencies beyond ensuring that 5G New license-exempt equipment that uses the Radio – Unlicensed (i.e. 5G NR-U) be specified full 1200 MHz, and a continued drive toward in its Release 16 for 5925-7125 MHz as Band global harmonization. The technology case for n96. In 2019, GSMA, in a publication directed to opening the 6 GHz band to license-exempt use operators about why they should care about is compelling; doing so generates important 5G, said this: social and economic benefits. Countries that fail to act or delay action will fall increasingly “5G networks require access to spectrum in behind in realizing the social and economic low, medium and high radio frequencies and benefits of license-exempt use. Equipment in larger contiguous blocks than previous mo- is ready for the market, with standards and bile generations require. Regulators that get interoperability testing in place. Consumer, as close as possible to assigning 100MHz per enterprise, industrial, and governmental needs operator in 5G mid-bands (e.g. 3.5GHz) and today and in the future can be more easily met 1GHz per operator in millimetre wave bands with the new generation of license-exempt (e.g., 26GHz and 28GHz) will best support ro- technology designed to operate throughout the bust 5G services.” GSMA, The 5G Guide: A Re- 6 GHz band. ference for Operators, April 2019. Some parties may argue that the portion of the band above 6425 MHz should be reserved Notably, GSMA did not raise the 6 GHz band for possible IMT use, or that IMT technologies frequencies, and failed to list the 6 GHz band “require” 6 GHz band spectrum, but the in its exhaustive appendix of “5G New Radio arguments do not stand up to scrutiny. The IMT Spectrum Bands.” The IMT community’s ac- community’s mid-band spectrum advocacy tions over the last decade on the 6 GHz band, for many years has focused on spectrum in or rather its inaction, speak far louder than GS- the 3 GHz range. For much of the last decade, MA’s recent hyperbolic press release descri- the IMT community has advised governments bing the allocation of 6 GHz for license-exempt globally that it is essential to make available use a “clear threat to 5G”. Regulators and poli- 100 MHz per operator in this 3GHz range to cymakers globally have gone to great lengths support 5G needs, administrations did not to provide the 3 GHz mid-band spectrum that 18 6 GHz License Exempt: Why the full 1200 MHz and why now?
the cellular industry has long said was
the critical enabler for 5G. The IMT in-
dustry should act to meet its promises
for 5G with the spectrum that has been
made available, not to claim that 6 GHz
licensed spectrum is suddenly critical
to enable 5G operations.
Today, the established path to mid-
band licensed 5G is through the 3
GHz band (roughly 3300-4200 MHz
globally). Most mid-band NR devices
have been announced for the 3 GHz
range (n77, n78) along with devices for
the 2500 MHz band (n41) and 2100 MHz
(n1). At 6 GHz, there is no New Radio
specification for standard FDD or TDD
3GPP technology, although 5G NR-U
has been specified for license-exempt
use in the 6 GHz band. Because of this,
there is neither infrastructure nor client
device equipment that can support
licensed New Radio in the 6 GHz
band. In contrast, there are mature
specifications for both LTE and 5G NR
for the 3 GHz range, and infrastructure
and client device manufacturers have
implemented support in a wide variety
of equipment already available in
the market. Radios supporting 5G NR
bands n77 and n78 in the 3 GHz range
are the path to instant mid-band
Source: GSA April 2021 5G as soon as 3 GHz band spectrum
becomes available, just as there is
a large and growing ecosystem of
equipment that can instantly leverage
designation of the full 6 GHz band for
Source: GSA April 2021 license-exempt use.
GSMA correctly recommends that
In addition to making policymakers and regulators “support harmonised
mid-band 5G spectrum”. With major markets, such
available further parts of as the U.S., Canada, South Korea, and Brazil, having
the 3.3-4.2 GHz band range allocated 5925-7125 MHz for license-exempt use,
for licensed 5G, countries these frequencies will not be harmonized for licensed
5G. Instead regulators are making decisions to
are also considering parts of allocate the 6 GHz band in a way targeted toward
the 4.4-5.0 GHz band range easing the mid-band deficit of license-exempt
spectrum around the world, keeping in mind that 5G
to provide even further mid- NR-U can also use these frequencies.
band IMT spectrum based Regulators around the globe agree that
on the existing 3GPP band withholding the upper 700 MHz of the 6 GHz band for
future consideration for IMT is inadvisable.
n79 ecosystem.
19• In Canada, “ISED is of the view that delaying the release of the spectrum would not
meet the policy objectives outlined in section 2, as it would hinder access to affordable
broadband services for Canadians in rural and urban areas and would negatively
impact the opportunities for innovation.”
• In Saudi Arabia, the CITC noted that it favored 3 GHz band spectrum, not the 6 GHz
band, for 5G mid-band needs, stating that its focus was on making 3 GHz band spec-
trum available for 5G. CITC noted “the substantial amount of licensed TDD mid band
spectrum already being made available for IMT and 5G…. CITC believes that this band-
width will be sufficient to cover the mid-band spectrum needs of IMT for the fore-
seeable future.…The existing mid-bands for exclusive IMT use have robust ecosystems
already as well as superior propagation characteristics. If mobile operators want to
access the 6 GHz band, they can do so on a license-exempt basis using NR-U (which
3GPP has defined as band n96).”
• In Brazil, one commissioner explained that “IMT operators wanted us to give a part of
this spectrum for licensed use, arguing that it was important for 5G. If we wanted to do
that, we would have to wait until 2024 to start the discussion about that and maybe
in 2027 we would have the deployment. Considering the moment that we are in right
now, considering the pandemic, considering the need for connectivity for everyone
for the recovery of the economy, considering all of that, we understood that we could
not wait until 2024 or 2027 to start using this frequency band. That’s so important. We
decided to start using it right now, because right now we have the equipment, we
have a Wi-Fi 6E ecosystem. If we waited more than six years to take this decision, these
are six years that we lose all the innovation, all the revenues, all the development this
frequency band may bring to our economies.”
• In the United States, the FCC declined the “requests that we repurpose substantial
portions of the 6 GHz band for new licensed services in place of new unlicensed
operations and existing incumbents. Most importantly, as explained in the Notice and
in this Order, we believe that providing new opportunities for unlicensed operations
across the entire 6 GHz band can help address the critical need for providing
additional spectrum resources for unlicensed operations…. Repurposing large portions
of the 6 GHz band for new licensed services would diminish the benefits of such use to
the American public.”
Consistent with these observations, narrowband fixed link transitions
many jurisdictions have opened the were completed properly, which then
full 6 GHz band to license-exempt would allow for coexistence to be
use. It also is important to understand studied, these countries requested
the status of and reasoning behind that the initial license-exempt study
European action on the 6 GHz band. be restricted to 5925-6425 MHz.
Europe’s 2017 decision to evaluate the Other countries, however, proposed
lower 500 MHz of spectrum was based opening the full 6 GHz band to license-
on genuine but parochial concerns by exempt use or suggested 5925-6725
a few countries, mostly those that were MHz for the scope of the coexistence
in the process of migrating narrowband study. European regulators opted
fixed links from other bands into the for a “lowest common denominator”
upper portion of the 6 GHz band. To approach, resulting in the initial study
conserve regulatory administrative of 5925-6425 MHz. When the European
resources and to ensure that these Commission issued a final revision
20 6 GHz License Exempt: Why the full 1200 MHz and why now?to the study mandate to reflect the should be used for IMT. Their mandate on
compromise, it said: that matter is silent.
In any event, the approach that
Based on the results of the compa- European regulators used to define
tibility and coexistence studies cove- the boundaries of their study in 2017
ring the 5925-6425 MHz band to be has no bearing on the rest of the world.
carried out under this Mandate, the The rationale was internal-to-CEPT
relevant harmonised technical condi- decision-making and should not serve
tions should enable the coexistence as a limiting factor on how any other
with other systems in this and adja- country studies the 6 GHz band. Nor
cent frequency bands. should it cause other countries to fall
short of adopting the best public policy
Thus, once coexistence rules were outcomes possible.
established for the lower portion of the
band, regulators have completed a In fact, no country has designated
relevant portion of the work that would the 6425-7125 MHz spectrum for IMT.
be needed for a study of the upper Therefore, there is an absence of
portion of the band. Fully understanding consensus among the world’s regu-
the Mandate’s meaning requires an lators – in contrast to the many coun-
understanding of the debate and ultimate tries embracing license-exempt use
resolution over the size of the band to be of the full 6 GHz band -- that any part
studied that preceded it – namely, an of the 6 GHz band is necessary for 5G
expectation that the upper portion of licensed mid-band spectrum. In light
the band could be studied for license- of this and the inactivity on the 6 GHz
exempt use in due course. In concluding band among the IMT community dis-
its study of the lower 6 GHz band and cussed above, the benefits associa-
approving LPI and VLP portable devices, ted with reserving the upper 700 MHz
the European Commission – and the of the 6 GHz band for possible future
European regulators that participated IMT use remain speculative.
– did not decide that the upper portion
There is currently an ITU-R study
question on coexistence between IMT
and incumbent FS and FSS networks
at 6425-7025 MHz (Region 1), as well as
another on 7025-7125 MHz (globally).
Many types of equipment The study question is probably most
are expected to support noteworthy as another marker of
the regulatory direction of the band,
the entire 1200 MHz of the because Regions 2 and 3 specifically
6 GHz band, as the Unit- explicitly declined to join in on the
Region 1 coexistence study at the WRC-
ed States, Brazil, Canada, 19. Region 1 will be evaluating whether
Saudi Arabia, and the Re- IMT could coexist with fixed satellite
uplink, fixed microwave, and other
public of Korea are en- services such as a mobile satellite
downlink located in the 6425-7125
abling the band for such MHz band. In the 2017-2021 European
operations, with many examination of license-exempt
coexistence, the European process
other countries expected concluded that LPI and VLP license-
to do so in 2021. exempt devices could coexist with
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