Q. How well is the WRC-19 agenda understood by Operators in the North American market, and what is the significance of WRC-19 to your business aspirations around the globe?

A. Major operators in the U.S. have a good understanding of many of the WRC-19 agenda items (“AI”), in particular AI 1.13 - the identification of spectrum for IMT-2020 to which most of their focus has been. Smaller operators are likely relying on industry associations such as CTIA and GSMA for information and updates.

There has been less focus on the other WRC-19 agenda items. However, to the extent that an AI is addressing the same spectrum as is included in AI 1.13, such as AI 1.13 HAPS or AI 1.6 NGSO, operators have been involved to ensure that terrestrial services are not negatively impacted in the band or a bad precedent is set for this or future WRCs.

WRC-19 is important domestically in the U.S. as it will directly impact the ability and utility of mmWave bands in the deployment of terrestrial 5G. Globally it will impact the business from economies of scale and international roaming perspective. In addition, to the extent that there is harmonization of spectrum bands internationally, this provides opportunities to serve multi-national businesses with less complex devices.

WRC-19 is important domestically in the U.S. as it will directly impact the ability and utility of mmWave bands in the deployment of terrestrial 5G. Globally it will impact the business from economies of scale and international roaming perspective.

Q. Spectrum challenges for the Industry are immense. How prepared is the private sector as a whole to address these challenges?

A. 5G will provide (1) much greater speeds, (2) much lower latency, and (3) massive IoT connections. Operators on their own using existing terrestrial allocations and licenses will be challenged to deploy 5G along with supporting legacy technology as customers migrate to 5G. As such, the industry will be hard pressed to address the challenges of increased consumer demand and new services. Additional low-band, mid-band, and high-band (mmWave) spectrum needs to be identified and then allocated to operators by countries in order to be prepared to meet the challenges. Those countries who fail to do so will fall behind, losing opportunities.

Q. What is on your wish list for WRC-19 and WRC-23?

A. For WRC-19, it is the following:

Agenda Item 1.13 (top on the wish list):

• Identification of the 26 GHz band (24.25-27.5 GHz) for IMT-2020 with minimal necessary constraints (condition A2a). Any constraint on OOBE in this band must be based on realistic and non-flawed studies protecting passive EESS services in 23.6-24.0 GHz. Many of the studies that went into Task Group 5/1 were flawed and analyzed a sensor that didn’t exist. We support the current U.S. position on the protection of passive services at -20 dBW/200MHz. Sharing studies of other services such as FSS and ISS showed large positive margins and no conditions are necessary here.
• Identification of the 40 GHz band (37-43.5 GHz) for IMT-2020 with no conditions ( Method C2, Alternative 2; method D2, alternative 2; method E2, alternative 2). Because different Administrations are looking at various blocks of spectrum within this range for IMT-2020 (for example the U.S. has identified 37-40 GHz for IMT-2020 which the EU has identified 40-42.5 GHz), it is important that the entire tuning range be identified which will offers Administrations flexibility and maximizes economies of scale while providing for international roaming. This allows each government to choose which range is best in their respective country given their local circumstances and still allow others, such as satellite access to portions of the band. In addition, studies show existing unwanted emission limits in 3GPP are sufficient to protect other services, including passive EESS which is already shared with active services, and no technical conditions to protect other services are required.

We view the industry post WRC-19 as vibrant and competitive and moving quickly to 5G.

AI 9.1.1 – Sharing between IMT and MSS in 1885-2025 and 2110-2200
Support No Change to the regulatory conditions currently in force. ITU-R studies being conducted in response to this issue have identified several technical and operational measures to address compatibility of the terrestrial and satellite components of IMT in adjacent countries. Necessity of these measures depends on cross-border situations, and these measures may not be universally applicable to all possible cross-border cases. Administrations should have the flexibility to adopt a variety of such measures, based on actual system characteristics and confidential information, during the bilateral coordination processes, and this flexibility should be maintained. A change to the Radio Regulations would limit the present flexibility for deployments by individual countries.

AI 1.14 HAPS
Some of the bands under consideration as part of AI 1.14 are not going to be used by IMT/5G systems (e.g. 21.4-22 GHz and 31-31.3 GHz), while other bands under consideration for AI 1.14 are also being considered for IMT or 5G use. Any use of HAPS, if designated for use in the IMT candidate bands under WRC-19 AI 1.13, or bands used by mobile 5G networks, should not impact IMT identification or in any way limit the potential of mobile 5G networks or fixed systems. There must not be any constraints on IMT or mobile 5G networks in the Radio Regulations related to sharing with HAPS and HAPS should not cause interference to or claim protection from IMT. This is of particular importance given the priority of the 26 and 40 GHz bands for IMT as well as mobile 5G in 28 GHz. In that sense, it is necessary to establish technical and regulatory provisions for HAPS to be able to not interfere with IMT. Given that the draft CPM text does not include the appropriate PFD limit, it is important to ensure that any WRC action to enable HAPS use in any bands used by IMT or mobile 5G systems adopts appropriate pdf limits.

For WRC-23, it is the following:
For WRC-23, our wish list includes the identification for study of additional spectrum bands below 24 GHz for IMT and to prevent the encroachment of other services in the bands identified in WRC-19 by other services such as ESIMs and HAPs. For instance, there are proposals to study NGSO to GSO links in various bands including 3700-4200 MHz and in

5925-6425 MHz. Both of these bands are currently subject of a U.S. proceeding - neither for NGSO to GSO links and worldwide are being considered for terrestrial service.

• Many suggested agenda items are proposing to cover ALL the 5G bands; a number of these proposals target key bands in AI 1.13 particularly the 37 GHz, 39 GHz and 47 GHz bands.
• Also, it should be noted that some of these agenda items are proposing many 5G bands without any consideration of relative market demand. For example, ESIMs already have access to 4.55 GHz of spectrum with an additional 4 GHz under study as part of WRC-19 agenda item 1.5; an additional 12.5 GHz of spectrum would be under consideration in the future agenda item proposals for ESIM use without having ever establishing any spectrum needs for ESIMs

Q. How do you view the Industry post WRC-19?

A. We view the industry post WRC-19 as vibrant and competitive and moving quickly to 5G.