The Mimosa 10 GHz FCC Petition

By Brian Hinman

Mimosa is proud to announce its FCC petition advocating for the shared allocation of the 10.0 – 10.5 GHz band for lightly licensed wireless broadband operations. We believe this petition furthers the policy goals of the FCC’s published National Broadband Plan by significantly expanding the amount of spectrum available for broadband use nationwide.

Several key elements underscore the need to share existing bands more effectively, and the 10 GHz band in particular:

  • Cellular Spectrum is Precious. We need to preserve licensed non-line-of-sight (NLOS) spectrum for high-velocity mobility applications, because there isn’t enough of this spectrum to meet all of our broadband needs.
  • 5 GHz is Heavily Congested. The unlicensed Part 15 U-NII bands have become increasingly popular for both for mobile offloading and fixed Internet access, creating heavy congestion that will only intensify going forward.
  • Part 101 is Booked-Up. The traditional method of backhauling traffic uses licensed fixed access under Part 101 regulations, but in most key service areas, operators can not pull new licenses due to the density of legacy radios without spectrum sharing capabilities.
  • Higher Frequencies Won’t Go the Distance. Part 101 spectrum is more readily available above 20 GHz, but these frequencies suffer from severe rain fade, making links impractical for the distances operators often need to service.
  • 10 GHz is Lightly Used. As amateur radio operators will attest, the 10 GHz band is currently very quiet, making it an ideal band for shared operations.

Together, these factors make it more critical than ever to creatively share the 10 GHz spectrum while minimally impacting existing users of the band.

In the United States, the 10.0 – 10.5 GHz spectrum is currently allocated for federal and non-federal radiolocation and amateur radio operations. Our proposal to include fixed and mobile broadband in this spectrum aligns the US allocation with existing allocations in other regions of the world, while protecting the band’s current users. Importantly, we also believe that the logical migration of traffic backhaul to the 10 GHz spectrum promotes a more effective use of the unlicensed 5 GHz U-NII bands for point-to-multipoint operations.

In formulating our petition, we carefully considered the costs and benefits of licensed versus unlicensed spectrum. On the one hand, licensed spectrum provides certainty with link coordination, but can limit the number of radios deployed within a region and potentially limits access to large corporations with the financial resources to exclusively hold spectrum rights. On the other hand, unlicensed spectrum provides a broadly available resource that can spur new markets such as we’ve seen with Wi-Fi; however, interference due to congestion can impair the perceived reliability of unlicensed services. We believe the appropriate compromise mirrors the light-licensing process developed for the 3.65 GHz band. Under FCC Part 90 Subpart Z, 3.65 GHz licenses guarantee interference mitigation through an informal coordination process, while a low nationwide licensing fee ensures availability for even the smallest service provider. We propose that the 10.0 – 10.5 GHz band be licensed under these same rules, adding specific protections for existing operation in the band. On this basis, we hope to see the band widely used for broadband access, while limiting interference to promote the most reliable services possible.

We hope that you will see the merit in our petition, and encourage you to contact the FCC to express your views before the expiration of the 30-day comment period on April 10, 2014.

Learn more about wireless policy and spectrum initiatives: