Andres Teeäär
Saatja: Simona Lipstaite <
[email protected]>
Saatmisaeg: teisipäev, 9. märts 2021 20:33
Adressaat: Andres Teeäär; Maret Ots; Erko Kulu
Koopia: Colin Thomson; Marcin Cichy
Teema: Thank you and follow-up: 6 GHz, Facebook
Manused: EU 6GHz Feb 2021.pdf; Maintaining European Leadership in 6 GHz.pdf
Kategooriad: Kategooria Sinine
Dear Mr Kulu, Ms Ots, Mr Teeäär,
Thank you for the informative meeting yesterday, we appreciated your insights.
Please find attached the slide deck presented during the meeting, as well as additional information on how Europe
can maintain its leadership in connectivity by opening up the upper 6 GHz band for license-exempt use for WiFi.
As discussed, on behalf of Facebook we would ask Estonia to urge the Radio Spectrum Policy Group (RSPG) to issue
an Opinion endorsing license-exempt operation in the upper 6 GHz band.
We would also encourage EU member states to work within the context of CEPT WRC-23 preparatory process to
develop technical and regulatory framework supporting EU harmonised unlicensed access to upper 6GHz, and
champion No Change to 6425-7125MHz band under WRC-23 AI 1.2 (Res149).
We would like to propose a follow-up meeting with your team later in the spring to touch base on the discussions on
the issue in Estonia and answer any follow-up questions you may have, including with your colleagues responsible
for WRC-23 preparations. Please also let us know whether it would be useful to set up a similar meeting with the
Ministry of Economic Affairs and Communications.
Please don’t hesitate to reach out in the meantime if we can help with any additional information.
Thank you again, and we look forward to continuing the conversation.
Best wishes,
Simona Lipstaite
Senior Manager, UK & Europe
Access Partnership
Square de Meeûs 37
1000 Brussels
Belgium
Tel: +32 (0) 2 535 77 11
Mob (UK): +44 (0) 7500 461 541
www.accesspartnership.com
1
Securing 6GHz
Spectrum for Europe
Objectives
2
Objectives and Timeline
Develop national support for license-
2021
exempt access to upper 6 GHz.
- Work within framework of CPG/PT1 Q3 - RSPG Opinion identifying upper 6GHz band
- Develop technical / regulatory studies for license- exempt use in Europe
underpinning unlicensed proposal 2022 - RSPG Opinion on licence exempt access to
upper 6GHz complements and informs RSPG
Opinion on EC positions relating to WRC-23
Q4 - CEPT European Common Proposal (ECP) Agenda Items
advocating No Change to Radio Regs in 6425-7025 2022
MHz and 7025-7125 MHz bands in response to Res
145 (WRC-19) EC Mandate to CEPT for harmonised framework for
license- exempt access to upper 6 GHz band
- Europe becomes international champion for license-
2023
exempt access to upper 6 GHz band
3
Two Policy Outcomes
1. RSPG Opinion that identifies 6GHz for license-exempt use in Europe
2. EC Mandate for harmonised framework for license-exempt RLAN for wireless
broadband services
3. EU Framework for licence-exempt access to upper 6GHz band recognised internationally
as regulatory best-practice
ECC Decision (20)01
5925 MHz 6425 MHz 7125 MHz
ECC
4
6 GHz Band 4
EU Policy Context
5
Unlicensed Access to 6GHz is Consistent with EU Policy Vectors
✓20% of member state national recovery plans earmarked for digital and connectivity
✓EU Digital Age Ambitions need connectivity
o E.g... AI, cybersecurity, quantum computing, government ICT, etc.
✓Consistent with EU’s 5G ambitions
✓Wi-Fi will contribute to public sector digital transformation + growing European capabilities
✓Radio Spectrum Policy Group (RSPG) Opinion on Radio Spectrum Policy Programme calls
on European Commission and Member States to:
✓ Improve broadband connectivity by ensuring availability of spectrum for WAS/RLAN
applications and by using shared spectrum including with innovative solutions
✓ Promote the role of wireless connectivity for the functioning of the economy and society
during crises, in particular during a pandemic period and subsequent recovery
6
EU Policy Context
• EU Next Generation and Digital Decade initiatives:
o EUR 750 billion post-COVID recovery in 2021-2023
– 20% for investment in digital markets
o One of the goals: expansion of fiber deployments
– Wi-Fi needs more spectrum to deliver the benefits
of fiber expansion
• EC recommendation for toolbox to reduce costs
and timescales to boost investment in high-
capacity networks and access to 5G
7
Economic driver for unlicensed access to upper 6GHz
• Across the EU 27 and UK, WiFi is carrying an additional 5 Exabytes of traffic per month as
a result of changed demand patterns brought about by the COVID-19 pandemic.
• The trend will not reverse as we emerge from restrictions imposed by the COVID pandemic
• The uptick in traffic is equivalent to streaming a billion HD films every month
• Economic Value of WiFi across EU in 2021 is estimated at EUR377.1 Bn and, EUR525.1 Bn by 2025
• The increased use of WiFi in the EU27 and the UK as a result of changed usage patterns brought
about by COVID-19 has grown the economic value that WiFi generates by EUR 26 billion.
• WiFi , an existing important source of connectivity and driver of economic activity has become a
pre-condition for an optimally functioning society
8
Technical context
9
Technical Conditions: ECC Decision (20)01
Parameter Low Power Indoor (LPI) Very Low Power (VLP)
Maximum mean e.i.r.p. for in-band emissions 23 dBm 14 dBm
Maximum mean e.i.r.p. density for in-band emissions 10 dBm/MHz 1 dBm/MHz
Maximum mean e.i.r.p. density for out-of-band -22 dBm/MHz -45 dBm/MHz
emissions below 5935 MHz
LPI Devices VLP Devices
• Indoor and outdoor use is allowed
LPI Access Point: • Use on drones is prohibited
• Indoor use only, including • A VLP device is a portable device
aircraft and trains with metal
coated windows
• Outdoor and use in vehicles not
permitted
• Has an integrated antenna and is
not battery powered
LPI Client Devices:
• Any device connected to an LPI
access point or another LPI client
device
• May or may not be battery
powered
10
Ask in context of WRC-23 AI1.2 (Res 149)
5G spectrum needs
• 400 MHz of harmonized mid-band spectrum at 3400-3800 MHz already identified for 5G in Europe
o Draft RSPG Opinion Recommends investigating 5G in 3800-4200 MHz
o Identifying upper 6GHz for 5G has no benefit
o One whole contiguous band will benefit 5G (3.4-3.8/4.2 GHz) and WiFi (5.925-7.125 GHz)
Incumbent fixed and satellite services in upper 6GHz band
• Incumbent licensed fixed and fixed-satellite operations in 6425-7125 GHz band need to be protected.
o Co-frequency 5G operation in band significantly impaired by need for reduced power to protect incumbent services
5G operations
• 6GHz 5G identification would not deliver ubiquitous coverage and QoS to European citizens
o Network deployment costs will limit 5G operation to FWA to home in rural and low population density areas
Benefits of unlicensed 6GHz
• RLAN = essential complementary technology that is fundamental to distribution of broadband connectivity throughout home
(office, arena, convention center etc.) regardless of whether connectivity is provided by fiber, 5G or other technology
11
• RLAN in 6 GHz band = 120 MHz and 320 MHz channels leveraging benefit of fiber connectivity
International context
Region 1 Region 2 Region 3
Approved
CEPT (5925-6425 MHz) US (5925-7125 MHz) South Korea (5925-7125 MHz)
UK (5925-6425 MHz) Chile (5925-7125 MHz)
United Arab Emirates (5925-6425 MHz) Guatemala (5925-7125 MHz)
Being considered / studied
Jordan (54925-7125 MHz) Argentina (5925-6425 MHz) Japan (5925-7125 MHz)
Kingdon of Saudi Arabia Brazil (5925-7125 MHz) Taiwan (5925-7125 MHz)
Canada (5925-7125 MHz)
Costa Rica (5925-7125 MHz)
Colombia (5925-7125 MHz)
Honduras ((5925-7125 MHz)
Mexico (5925-7125 MHz)
Peru (5925-7125 MHz)
12
Our ask
• Work with FB and other proponents at national level and within the
context of CEPT WRC-23 preparatory process to develop technical and
regulatory framework supporting EU harmonised unlicensed access to
upper 6GHz
• Champion RSPG Opinion identifying EU harmonised unlicensed access
to upper 6GHz
• Champion No Change to 6425-7125MHz band under WRC-23 AI 1.2
(Res149)
13
North America Europe Middle East Africa Asia
Washington DC London Brussels Abu Dhabi Dakar Singapore
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Washington DC 20036 London, SW1E 6QT B-1000 Brussels PO Box 127432 Senegal 089109
USA UK Belgium Abu Dhabi, UAE
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Fax: +1 202 223 2009 Fax: +44 (0) 20 8748 8572 F: +32 (0)2 535 77 00 Fax:+971 2 815 7888 Fax:+221 33 827 52 55
14
Maintaining European Leadership in 6 GHz
EU Member States Must Champion Licensed Exempt Operations in the Upper 6 GHz Band
February 2021
Fixed and wireless networks contribute significantly to providing affordable and accessible services and
bridging the digital divide. Wi-Fi is an indispensable way of transporting data and services for devices
that are now part of our daily activities, such as tablets and smart phones. To respond to the increasing
demand for connectivity and achieve the objectives of the Gigabit Society 2025 and Digital Decade,
Europe needs more spectrum for Wi-FI.
The European Commission has recently taken an important step by opening the lower 6 GHz band
(5.925-6.245 MHz).1 While this action is important and commendable, further steps are necessary. To
ensure the Europe delivers the connectivity citizens and businesses need and fulfill its EU 5G Action
Plan, it must ensure that the upper 6 GHz band (6.425-7.125 MHz) is also opened for unlicensed use.
The Need for Unlicensed Spectrum is Critical
Unlicensed spectrum is the fuel powering the wireless revolution that has transformed how Europeans
live their lives. From Wi-Fi to Bluetooth, and beyond, unlicensed spectrum has led to an explosion in
innovation. Meanwhile, as the COVID-19 pandemic has kept people socially distanced, the connectivity
supported by unlicensed spectrum has become the critical glue connecting every EU citizen.
By moving the economy forward, allowing children to learn, or simply keeping people in touch with
their families and friends, Wi-Fi has become essential. Unlicensed access to spectrum is also a vital
resource for innovation. One high-profile example of such is augmented and virtual reality (AR/VR).
ARVR technology is used today for diverse purposes including training surgeons, pilots and mining
engineers through immersive simulations of their working environment; diagnosing progressive medical
conditions including dementia; and educating teenagers on issues relating to gang crime and drugs.
Across the EU27 countries, as well as the United Kingdom, Wi-Fi networks are now carrying an
additional five exabytes of traffic per month as a result of changed demand patterns caused by the
pandemic.2 This uptick is equivalent to streaming a billion HD films every month, fueling an increase of
€26 billion in the dependency of the overall economy on Wi-Fi.3 These trends will not reverse after the
pandemic: if anything, Wi-Fi has morphed from being an important source for connectivity into a basic
pre-condition for a fully functioning society. Europe should ensure a balanced and technologically
neutral broadband roll-out supporting all available fixed/mobile wholesale solutions.
Licensed Exempt in the Upper 6 GHz Band Would Advance EU Policy Objectives
Opening the upper 6 GHz segment would be an important step towards advancing overall EU policy
goals. In the short term, the EU has budgeted €750 billion for its post-COVID recovery plans (from 2021-
2023), of which 20% will be used to deliver better connectivity. The goals include the expansion of fiber
deployments, to bring ultra-fast broadband to EU homes. However, EU citizens typically access their
broadband connectivity through Wi-Fi, and existing deployments in the 2.4 and 5 GHz bands are not
fast enough to deliver the benefits of fiber connectivity to EU citizen. Wi-Fi will need to evolve
towards 160 and 320 MHz channels only available in the 5945-7125 MHz band.
1 ECC Decision (20)01, 20 Nov. 2020 (opening 5.925-6.245 MHz band to unlicensed operations).
2 Based on European Commission estimates of traffic per month per capita combined with AP analysis that 80% of all new traffic is
carried on Wi-Fi. See also Access Partnership, Wi-Fi: A pre-requisite for economic activity in times of COVID-19 and beyond, April
2020.
3 Access Partnership estimate, based on Telekom Advisory Services study of global economic value of Wi-Fi between 2018 and 2023.
The EU’s ambitious digital agenda depends on connectivity and, in turn, on Wi-Fi: an essential and cost-
effective solution for mobile and in-home connectivity regardless of the broadband delivery platform.
Advances in fields like artificial intelligence and quantum computing, as well as improving the use of
government information and communications technologies, are extraordinarily difficult without
adequate connectivity via Wi-Fi. Meanwhile, Wi-Fi can continue to serve as an important complement
to EU investment in 5G, allowing for traffic offloading and lowering the cost of 5G deployment.
Furthermore, the current scope of spectrum allocated to 5G (700 MHz, C band, 26 GHz) is recognised
as technically and economically sufficient, so there is no need for recourse to 6GHz.
Unlicensed is the Best Technical Use of the Upper 6 GHz Band
The technical rules for low-power operations that were recently adopted for the lower 6 GHz segment
can readily be extended to the upper 6 GHz segment. The incumbent users are the same in the lower
and upper 6GHz bands. Most importantly, the new unlicensed operations in the band (Wi-Fi etc.) will
be identical in both segments, with devices typically using the same radio since the bands are adjacent.
The technical analysis that justified action in the lower segment also supports deployment in the upper
segment. The ability to use one radio over the entire 6 GHz band would not only help reduce device
costs and improve battery life, but critically enable deployment of 320 MHz Wi-Fi channels (Wi-Fi 7).
In contrast, using the upper 6 GHz band for licensed IMT would be inefficient. Due to the need to protect
incumbents, high-power IMT operations would necessarily be impaired, with any 6 GHz 5G service
proving incapable of delivering ubiquitous service. Moreover, while there is an IMT proposal for this
segment, it is only for ITU Region 1 and therefore not globally harmonised4, meaning that IMT
equipment in this band – especially terminals – would not be readily available.
While larger channels in 3400-4200 MHz would enable an increase of 5G network performance, adding
a separate band that does not support wider channel, is subject to stringent power limits and suffers
from crippling propagation and in-building penetration characteristics would not enable operators to
significantly improve the 5G service. Given that 5G already has access to 400 MHz of valuable mid-band
spectrum, adding a geographically-impaired and single-region IMT allocation in the upper 6 GHz band
– especially at the cost of unlicensed operations – would fail to put spectrum to best use.
The Time for Action is Now
An agenda item for the next World Radio Conference in 2023 proposes to add an IMT allocation for the
upper 6 GHz band in Region 1, driven by countries that do not wish to open the 3400-3800 MHz to 5G.5
In contrast, European countries have already identified a comprehensive set of priority bands for 5G
and cannot afford to wait three years for a resolution of this issue. Other countries, such as the United
States, South Korea, Canada, Chile, Jordan, Saudi Arabia and Brazil, are moving ahead on low-power
operations in the entire 6 GHz band,6 ready to benefit from Wi-Fi operating on 320 MHz wide channels,
and the EU must not be left behind.
To facilitate this, EU Member States should ask the Radio Spectrum Policy Group (RSPG) to issue an
Opinion endorsing licensed exempt operation in the upper 6 GHz band.
These actions will send a strong signal to the market and the rest of the world that the future of the
upper 6 GHz band will be a prosperous one based upon unlicensed operations.
4 WRC-19 Final Acts, Resolution 245 at p. 363.
5 WRC-23 Agenda Item 1.2 (implementing WRC-19 Resolution 245).
6 U.S. Federal Communications Commission, Unlicensed Use of the 6 GHz Band, 23 Apr 2020.