The NOAA/NASA public campaign to reverse the FCC’s auction of 5G spectrum in the 24 GHz band is two years late and $2 billion short. The FCC’s 24 GHz rules were adopted two years ago through the standard interagency coordination process, and the spectrum has since been auctioned to wireless providers for more than $2 billion. NOAA/NASA had an opportunity to win the interagency debate on the issue, including at the Department of State, and they lost. It’s inappropriate for disgruntled federal agencies to wage a public relations war to reverse settled U.S. policy.
NOAA/NASA claim the FCC’s out-of-band emissions (OOBE) limits for the 24 GHz band will result in harmful interference to the collection of weather data via satellite by NOAA, a division of the Department of Commerce. The potential for 5G operations in the 24 GHz band to affect global weather satellites makes this an issue of international importance that is on the agenda for international treaty negotiations at the ITU’s World Radio Conference (WRC) in the fall. To facilitate orderly and uniform measures and procedures, the State Department has final authority to approve and express U.S. policy positions during international treaty negotiations. And with respect to 24 GHz, State has already submitted the FCC’s out-of-band emission limits as the U.S. position during preliminary negotiations (e.g., with the Inter-American Telecommunications Commission, which includes all 35 independent states of the Americas).
The NOAA/NASA PR campaign infringes the State Department’s role in expressing a uniform treaty position and undermines State’s legitimacy during preparatory negotiations for the WRC. This is unacceptable, particularly when the campaign is based on flawed analysis.
The interagency study underlying the NOAA/NASA objections has not been publicly released, presumably due to the dispute among the agencies about the appropriate inputs for the interference model. Dr. Neil Jacobs, Assistant Secretary of Commerce for Environmental Observation and Prediction, recently testified before Congress that “subject matter experts in the FCC, NASA, [and] NOAA are going back and forth, still debating the input parameters” to the model. It thus appears that his testimony regarding the interference potential of the FCC’s OOBE limits was based on the input parameters proposed by NOAA/NASA.
To the extent there is available information, the NOAA/NASA inputs are unrealistic and, in some instances, illogical. For example:
- NOAA/NASA assume 5G base stations and end-user devices will transmit at the same time, which is impossible in a functional 5G network.
- NOAA/NASA assume the power level of 5G signals will be the same from their authorized frequency edge to the frequencies used by NOAA’s weather satellites even though there is 250 MHz of separation between the two sets of frequencies. This is not possible. The 5G signals will attenuate (i.e., their power level will decrease) as the distance from their band edge increases.
- NOAA/NASA assume interference from co-channel services even though the FCC has authorized only one 5G network per channel.
These inputs and other worst-case assumptions appear designed to overstate the level of potential 5G emissions that could be received by NOAA’s weather satellites. No wonder the State Department sided with the FCC.
The obvious bias of NOAA/NASA is unusual but not inexplicable for federal agencies when spectrum is at stake. The FCC’s assignment of 24 GHz spectrum for 5G has implications that go beyond the potential for harmful interference to NOAA’s satellite systems. Any time there is widespread deployment of new commercial systems in a band, it impacts the potential for future federal use of that band as well as the adjacent frequencies (e.g., the 250 MHz that currently separate the 24 GHz frequencies allocated for 5G and NOAA’s satellites). And in this case, the sudden resignation of David Redl, the assistant secretary who headed the National Telecommunications and Information Administration (NTIA), has left a power vacuum in the Commerce Department with respect to federal spectrum issues. (The secretary in charge of NTIA is responsible for spectrum matters that involve other federal agencies and offices, like NOAA/NASA).
The race to 5G is too important for the U.S. to countenance the NOAA/NASA power play, especially when the 24 GHz band has already been auctioned and the WRC is rapidly approaching.
NOAA did not respond to my request for comment on the NOAA/NASA inputs to the study parameters.
