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Author Archives: Jennifer McCarthy

 About Jennifer McCarthy

Jennifer McCarthy is responsible for the company’s regulatory and government affairs agenda. Jennifer is a telecommunications regulatory attorney with over 25 years of experience in the wireless sector having held a variety of government affairs, business development, and operations positions for several of the industry’s leading technology innovators. Most recently, Jennifer was with MVP Capital, working with wireless spectrum license holders, TV and radio station owners, and other online content service providers on a variety of M&A projects. Prior to that, Jennifer was Senior Vice President of Regulatory Affairs and Operations for NextWave Wireless Inc. and part of the executive management team of MediaFLO USA Inc., a subsidiary of QUALCOMM Incorporated, where she identified, purchased, and cleared the TV Channel 55 spectrum used to deploy the nation’s first network dedicated to the reception of mobile television programming and other multimedia services. She was also the head of QUALCOMM’s international government affairs team responsible for regulatory and international trade strategy at the International Telecommunications Union and related organizations. Early in her career, she worked with Freedom Technologies, Inc., a boutique Washington, D.C.-based telecommunications consulting firm and its associated law firm. Ms. McCarthy has a B.A. in political science from Yale University and a J.D. from Georgetown University Law Center. She is a member of both the California and Washington, DC Bars.

AFC Lab Test Success: Ahead Towards Commercial Wi-Fi 6E Standard Power

Federated Wireless, Inc. is one step closer to enabling commercial Standard Power Wi-Fi 6E operations in the 6 GHz band.

Today, we submitted our Automated Frequency Coordination (AFC) system lab test report – which we passed with flying colors – to the FCC for its review and approval.  AFC lab testing is one of the final stages in the journey started nearly five years ago to the day when the FCC launched the rulemaking proceeding to open the 6 GHz band to unlicensed devices on a shared basis with incumbent systems.

The final stage – the public trial period – is also nearing completion.  Federated Wireless has provided responses to hundreds of inquiries regarding channel and power level availability as part of the ongoing AFC public trial.  Once Federated Wireless submits our public trial report in early November, the FCC will be poised to complete the journey by certifying Federated Wireless to become an AFC system operator, enabling us to support commercial Wi-Fi 6E Standard Power and outdoor operations while protecting incumbent systems from interference.

Over the past five years, Federated Wireless has worked with our industry partners, including Aruba, a Hewlett Packard Enterprise, Airspan, Mediatek, Cisco, and other Wi-Fi Alliance and WInnForum members, in addition to a diverse group of incumbents and regulatory agencies worldwide to foster an environment of trust and open communication.  This cooperation created a solid foundation for the deployment of AFC systems and Standard Power unlicensed devices in the United States as well as around the world.  By ensuring that operational requirements are met, database management tools are efficient, and security measures are robust, Federated Wireless has helped to pave the way for a smooth and reliable implementation of unlicensed Standard Power operation.

The FCC’s decision to open the 6 GHz band to unlicensed Standard Power operation marked a significant milestone in the wireless industry.  Through the unwavering commitment of an interdisciplinary team led by Federated Wireless, industry and regulators came together to establish the operational framework for AFC systems and devices.  Federated Wireless is thrilled to have been a part of this unprecedented collaboration and looks forward to supporting commercial 6 GHz Standard Power in the very near future.

Learn more about our AFC, here.

Paving the Way for Unlicensed Standard Power Operation in the 6 GHz Band through Automated Frequency Coordination

In April 2020, the Federal Communications Commission (FCC) made a groundbreaking decision that would reshape of wireless landscape by opening a substantial portion of the 6 GHz band (5.925 – 7.125 GHz) for operation of Standard Power unlicensed devices under the management of Automated Frequency Coordination (AFC).

In response to this historic decision, the Wireless Innovation Forum and WiFi Alliance took the lead to jointly establish the operational framework for AFC systems and devices. After months of close collaboration, earlier this spring these organizations submitted the requirements and test plan for AFC devices to the FCC.

On June 20, 2023, the requirements and test plan for AFC systems were submitted. Federated Wireless was among the key contributors to both of these incremental milestones and the overall achievement of a standards framework, playing a pivotal role by leveraging our technical expertise and regulatory leadership.

Next Steps

With the comprehensive package now in the hands of the FCC, the next crucial step is for the FCC to complete its review and issue a public notice, which will give the green light for AFC system operators and Standard Power device manufacturers to commence lab testing activities. The industry eagerly awaits this important step, as it represents the final regulatory hurdle before the commercial implementation of unlicensed Standard Power operations in the 6 GHz band.

Unprecedented Collaboration

Defining the operational requirements, database management tools, security measures, interface design, device specifications, and testing plans for AFC systems and Standard Power devices required unparalleled cooperation among various stakeholders in the ecosystem.

As part of this collaborative effort, Federated Wireless helped bring together incumbents, system operators, cable companies, AFC system providers, and device manufacturers.  Working closely with industry partners, Federated Wireless facilitated a comprehensive dialogue that allowed all interested parties to voice their concerns and contribute to the development of robust operational guidelines. By fostering an environment of trust and open communication, Federated Wireless played a vital role in ensuring the industry achieved a harmonious consensus, creating a solid foundation for the deployment of AFC systems and Standard Power unlicensed devices.

Federated Wireless develops cutting-edge solutions for AFC systems and devices. By ensuring that operational requirements are met, database management tools are efficient, and security measures are robust, Federated Wireless has helped to pave the way for a smooth and reliable implementation of unlicensed Standard Power operation.

As early as 2021, significant partners began signing up to work with the Federated Wireless AFC solution. Aruba, a Hewlett Packard Enterprise, selected Federated to provide the AFC service required to operate its future outdoor, higher power, and ruggedized radio products in the 6 GHz band. In just 2023 alone, Airspan announced it will use Federated Wireless’ AFC system for Wi-Fi 6E solutions, and Mediatek linked with Federated Wireless to complete AFC testing on Wi-Fi 7 and 6E chipsets.

As well, in February, Cisco announced it will integrate the Federated Wireless AFC into its 6 GHz capable access points to enable enterprise transformation with high-capacity, high-performance shared spectrum network access.

The FCC’s decision to open up the 6 GHz band for unlicensed Standard Power operation marked a significant milestone in the wireless industry. Through the unwavering commitment of an interdisciplinary team that included Federated Wireless, industry and regulators came together to establish the operational framework for AFC systems and devices. The collaboration and cooperation among various stakeholders is unprecedented, resulting in a clear path to robust operational guidelines and adoption of AFC for 6 GHz standard power moving forward.

Learn more about how Federated Wireless is enabling the Wi-Fi 6E and 6 GHz ecosystem here.

Reshape the Wireless Ecosystem with Citizens Broadband Radio Service

This article originally appeared in RCR Wireless, here.

How do you measure the success of a new technology? Do you review adoption numbers? User satisfaction? What about the ecosystem that builds around the technology including equipment manufacturers and solution providers? Does unlocking new use cases factor into the value proposition? Does solving longstanding vertical market pain points? Succeeding in any of these areas counts as a major achievement. But when it comes to Citizens Broadband Radio Service (CBRS), we’re seeing something unique: a groundbreaking innovation having an impact across virtually every metric and a broad array of market segments.

When the Federal Communications Commission (FCC) launched CBRS just a few years back, they introduced a new way to use public airwaves, based on a novel spectrum-sharing framework that lets different tiers of users access the same frequency band. It was a bold new approach to commercial wireless. And it’s already exceeding expectations.

In just three years since going live, CBRS has seen faster and more widespread deployment, by a more diverse range of users, than any other spectrum band in history. It’s spurred a dynamic ecosystem of hardware, software, and services vendors addressing a wide range of use cases. CBRS has become a model for sharing spectrum among federal and non-federal users. And it’s already changing the landscape of the wireless marketplace.

A new approach to commercial wireless

When the FCC formulated CBRS, they dubbed it the “Innovation Band.” From its inception, CBRS was intended to shake up the U.S. wireless industry and unlock new use cases and connectivity options for a diverse range of users. And its unique spectrum-sharing framework was among its most important innovations.

Historically, when the FCC has released spectrum for commercial use, they’ve auctioned exclusive licenses, and large Mobile Network Operators (MNOs) would spend billions to secure exclusive rights. This model has been the default for decades, but the FCC and the broader wireless industry hoped to address three longstanding challenges with it:

  • Clearing incumbents: Under exclusive-use auctions, incumbents like the Department of Defense (DoD) would have to completely clear the spectrum and shift to new frequencies. The process has historically taken a decade or more and cost hundreds of billions of dollars.
  • Maximizing utilization: Even after major investments in spectrum licenses have been made, in many locations, it’s common for hundreds of megahertz of exclusively licensed spectrum to go unused, resulting in wasted assets that could be put to better use by other users and different business models.
  • Spurring innovation: Competition is vital for the success of a thriving ecosystem. By increasing spectrum access options under the CBRS sharing framework, new vendors, in particular U.S.-based suppliers, have entered the market providing end-users with greater choice while strengthening the competitiveness of domestic companies in the global marketplace.

With CBRS, the FCC hoped to address all of these issues. Instead of auctioning exclusive rights, they introduced a shared spectrum framework that could support incumbents, Priority Access License (PAL) auction winners, and non-auctioned General Authorized Access (GAA) operators simultaneously. They hoped this framework would allow the DoD to continue its operations unimpeded, even as new commercial users started to take advantage of the spectrum. And they wanted to ensure that MNOs and other large operators could get priority access where they wanted it, while allowing others to access unused spectrum when available.

Unleashing innovation

CBRS represented an ambitious vision, and the Innovation Band has lived up to its name. In less than three years since going live, more than 290,000 CBRS base stations have been deployed nationwide. (Compare that to the more than four decades it’s taken wireless carriers to deploy 420,000 cell sites.)

Even more impressive, a dynamic ecosystem has rapidly grown up around CBRS. The technology now features:

  • 228 PAL auction winners (almost 10x the number of winning bidders for the last exclusive-use spectrum auction)
  • 900 different GAA operators
  • 40+ equipment vendors
  • 187 commercial CBRS base station models
  • Nearly 500 authorized end-client devices
  • More than 4,000 certified professional installers
  • Nine authorized Spectrum Access System (SAS) Administrators

The organizations using CBRS are just as diverse. PAL users include national and regional MNOs, cable operators, Wireless Internet Service Providers (WISPs), utilities, and a whole host of new, non-traditional spectrum users, including school districts, hospitals, factories, farms, cities, critical infrastructure, industrial IoT (IIoT) companies, and others all benefitting from access to CBRS spectrum.

Setting the bar for new approaches

There was some initial concern that spectrum-sharing might be too complicated or that different user tiers might interfere with each other. Here again, CBRS has demonstrated superior functionality. Cloud-based SAS services automate registration, spectrum assignment, and everything else needed to productively share spectrum. Customers can now request spectrum and start using it the same day. And incumbents have reported no instances of interference, even as hundreds of new commercial users have begun accessing the band.

Even more exciting is the innovation, competition, and new entrants CBRS has introduced into the U.S. wireless and commercial ecosystem, while injecting positive impacts on the broader U.S. marketplace and economy. The technology is already being used to enable private wireless networks by a diverse mix of users. Organizations in manufacturing, healthcare, retail, supply chain, agriculture, education, and many other sectors are using the CBRS spectrum to support applications that would have been technologically unfeasible, or too impractical or expensive in the past.

Looking ahead

So, how should we gauge the success of CBRS? The U.S. wireless marketplace has never been more competitive. American companies launching new products and business models can now gain direct access to spectrum to accelerate innovation, without being forced to choose from the same limited technologies, based on the same non-U.S. equipment vendors. They have more wireless and connectivity options, more control, increased security, and better pricing. And the rest of the world is taking notice, as regulators in Europe and Asia are now evaluating spectrum sharing to commercialize their own spectrum resources.

If CBRS can accomplish so much so quickly, one thing is clear: However we define success for the future of the U.S. wireless market, inclusive spectrum-sharing models are proving to be an instrumental part of the story.

Jennifer McCarthy is the VP of Legal Advocacy at Federated Wireless.

CBRS Innovation Band Success: A Bright Future Ahead

United States Of America At Night - Planet Earth Seen From Space

What’s the best way to fuel innovation in the American wireless industry and expand connectivity options for U.S. businesses and citizens? Leaders representing both the public and private sectors have discussed this question for years. In 2015, the Federal Communications Commission (FCC) announced their answer: Citizens Broadband Radio Service (CBRS).

By expanding access to spectrum previously reserved for the Department of Defense (DoD), the FCC and the broader U.S. tech industry hoped to use this “Innovation Band” to kickstart a new generation of cutting-edge private wireless solutions. They wanted to do it quickly without disrupting critical national defense systems. By employing a novel shared licensing framework, they aimed to encourage new domestic businesses and stakeholders to get involved—ideally, chipping away at a global wireless ecosystem dominated by non-U.S. suppliers.

Less than three years since CBRS went live, the results are in. And they’re a resounding success. CBRS has seen faster, more widespread deployment, by a more diverse range of users than any other spectrum band in history. Now, CBRS is serving as a model for how inclusive spectrum-sharing can benefit everyone—consumers, businesses, the military and public sector, and the greater U.S. economy.

Inside the Numbers

Just how quickly has CBRS taken hold in the marketplace? In less than three years, more than 290,000 base stations have been deployed nationwide. (For comparison, the commercial wireless industry has built less than 420,000 cell sites over its entire 40-year history.) Meanwhile, a vibrant ecosystem of hardware, software, and service providers has grown around CBRS, spurring a wave of new entrants into the wireless marketplace. That ecosystem already includes:

40+ equipment vendors

187 commercial CBRS Base Station Device (CBSD) models

Nearly 500 authorized client devices

More than 4,000 certified professional installers

Nine authorized Spectrum Access System (SAS) Administrators

A record number of users have already adopted the CBRS spectrum, including:

  • Priority Access License (PAL) users: Under CBRS’ shared licensing framework, 228 bidders won priority licenses—almost 10x the number of winning bidders in the 2022 exclusive-use auction for the 3.45 GHz band. PAL winners represented a diverse mix of new and traditional spectrum users, including national and regional Mobile Network Operators (MNOs), cable operators, Wireless Internet Service Providers (WISPs), and electric utilities.
  • General Authorized Access (GAA) operators: Among the most exciting aspects of its inclusive spectrum-sharing model, CBRS ensures that GAA operators can access spectrum that’s not being used by incumbents or priority license holders. (This is a huge change from the traditional exclusive-use model, where in some locations, hundreds of megahertz of licensed spectrum go unused.) Already, nearly 900 different operators—cities, factories, school districts, hospitals, research centers, critical infrastructure companies, and more—are taking advantage of the GAA spectrum.

This diverse mix of users and operators—and the fact that they can all productively share the same spectrum band—is itself a monumental achievement.

Fueling Innovation

From its inception, CBRS was intended to shake up the telecommunications space and bring new innovation and competition to the U.S. wireless market. By any measure, the Innovation Band has more than lived up to its name. Customers are already using CBRS in a wide range of fixed and mobile use cases—both by MNOs to bolster wide-area coverage and by public- and private-sector users for highly customizable private networks. Early private deployments span manufacturing, healthcare, supply chain, agriculture, education, smart cities, and many other sectors.

Among other goals for CBRS, the U.S. government and military leaders hoped to reduce the industry’s dependence on the same three non-U.S. wireless suppliers and promote a more dynamic American ecosystem. Here again, the Innovation Band is exceeding expectations. Both new and traditional vendors can now gain direct access to the spectrum to launch new products and business models without being forced to do things the same way, with the same limited choices in solutions and partners. U.S. businesses now have more wireless vendor and technology options than ever before to implement new solutions—more quickly, with better pricing, and with greater control and customization.

Nowhere has this change been felt more than among WISPs seeking to bring broadband connectivity to rural regions, remote areas, and other underserved communities. The FCC first enabled the WISP market in the 2000s, but outdated technology and limited, proprietary equipment options caused the market to stagnate. Today, CBRS has breathed new life into the WISP model. Licensees can now access up to 3x the amount of spectrum in some locations and choose from a wide range of state-of-the-art 4G/5G equipment from dozens of vendors at competitive prices.

CBRS Performance and Simplicity

CBRS uses an innovative tiered sharing framework, where DoD incumbents and PAL licensees take priority, but unlicensed GAA operators can also access spectrum where available. Sharing is fully automated, with cloud-based SAS services handling everything in the background to prevent interference.

Despite initial concerns that spectrum-sharing might be too complicated, or that incumbents might be at risk of interference, the CBRS model has proven a resounding success. Even in its first few years post-launch, incumbent DoD operations have reported zero instances of interference—even as the number of commercial users in the band has exploded.

CBRS’ dynamic spectrum management has also proven fast, simple, and seamless for customers. Using automated SAS registration and spectrum assignment has proven as easy as using any other cloud service, as demonstrated by the nearly 300,000 transmitters already deployed. CBRS customers can request spectrum and start using it the same day. SAS administrators have also simplified back-end connectivity for equipment vendors, pre-validating interoperability and eliminating the need to customize spectrum-related features for different operators.

Extending the CBRS Model to New Frequency Bands

If CBRS was an experiment in whether different operators can productively share spectrum, the results are in. Not only is shared licensing viable, but it’s also an excellent option for commercializing any spectrum band, especially compared to the traditional model of clearing the band and auctioning exclusive licenses. CBRS-style sharing delivers more economic value to businesses and consumers much more quickly.

Historically, clearing incumbent systems from a band to support exclusive licensing can take 10 years and hundreds of billions of dollars. With CBRS-style sharing and dynamic spectrum management, critical government and military operations can continue uninterrupted, even as thousands of new networks and services begin sharing the same spectrum. Meanwhile, U.S. businesses and consumers can start using and benefiting from the spectrum right away, instead of waiting 10+ years to clear the band.

U.S. taxpayers also avoid the massive costs of moving incumbent government operations. In the 3.1-3.45 GHz band, for example, DoD estimates that clearing the band and relocating would cost approximately $200 billion.

Looking Ahead

For all these reasons, the DoD and most of the U.S. tech industry are thrilled at what CBRS has already accomplished and excited to extend the shared spectrum model to other bands. The benefits of CBRS-style sharing frameworks are now clear: Shared licensing offers the best path to maximize our use of limited spectrum resources. U.S. businesses gain far more choice in new wireless solutions, services, and partners, far more quickly. Consumers gain more broadband access in more places, with better pricing. Incumbents can maintain critical military operations without disruption and without the huge costs of clearing and relocating.

And for the future of U.S. wireless innovation? With a CBRS-like model, U.S. businesses no longer have to rely solely on traditional spectrum access models, working with the same exclusive partners and using technology from the same non-U.S. equipment makers. In just a few years, CBRS has spurred more competition and new market entrants than the U.S. public wireless marketplace has seen in decades. As we look to the future, it’s now clear that a balanced, inclusive spectrum policy offers the best path to promoting innovation and competition and propelling U.S. companies to the forefront of global wireless innovation.

As Vernita D. Harris, Director, Department of Defense Chief Information Officer Electromagnetic Spectrum Enterprise Policy & Programs (EMSEPP) recently wrote: “While spectrum sharing is not novel, CBRS represents a revolutionary leap in spectrum sharing, and provides valuable lessons learned for broader spectrum sharing implementation.… DoD believes the nation that masters spectrum sharing among all users will gain a huge technological, economical, and strategic advantage over competitors in the commercial and national security arenas.”

Response to the NTIA RFC on Developing a National Spectrum Strategy

The Federated Wireless team continues to lead the shared spectrum wave, and, in doing so, sets up the United States to lead the 5G wave. This was an initiative President Trump outlined late last year, and we gladly accepted the challenge.

Preparing For The Future of 5G

We recently filed a document in response to the National Telecommunications and Information Administration’s (NTIA) Request for Comments (RFC) on developing a sustainable National Spectrum Strategy that ensures sustainable access to the Nation’s scarce spectrum resources for all users who need it, including Federal and non-Federal stakeholders.

Those in the industry know that 5G is coming. The next-gen in mobile connectivity has been making headlines for years with commentary from those who think it’s almost here to those who think it’s a few years off. No matter your mindset, players – large and small – are preparing for it.

The demand for spectrum capacity to build out our nation’s 5G network is so high, President Trump put out a Presidential Memorandum last October calling for a comprehensive national strategy for managing spectrum resources. The President called on several departments and agencies to develop a solution for harnessing the potential of 5G. The Memorandum calls for a report on the status of existing efforts and planned near- to mid-term spectrum repurposing initiatives.

Our Response to NTIA RFC

The document Federated Wireless submitted was in response to the President’s call to action and NTIA’s request for comments. As the National Spectrum Strategy is developed, we strongly urge NTIA to fully utilize automated, dynamic spectrum management and sensing technologies, such as those embedded in the Spectrum Access System (SAS) and Environmental Sensing Capability (ESC), that have been designed to administer the multi-tier sharing regime and protect critical Federal incumbent operations in the CBRS band (3550-3700 MHz).

Why? Four reasons:

1. Dynamic sharing technologies are the future of spectrum management, will facilitate U.S. leadership in 5G, and are crucial to the successful implementation of a sustainable National Spectrum Strategy.

The legacy “clear-and-auction” approach to spectrum management is not sustainable given the cost, time to implement and interruption to the Federal mission, none of which aligns with the President’s request to be the first to roll out 5G. Spectrum sharing technologies must be leveraged to achieve this. The framework developed for CBRS is a testament to how sharing technologies can be used to support varied applications in a single band, balancing the needs of Federal users, incumbents, new licensed users, and unlicensed users. This SAS-enabled sharing model can and should be replicated in other frequency bands as part of an effort to develop and execute a sustainable National Spectrum Strategy.

2. Dynamic spectrum sharing technologies will play a pivotal role in improving the predictability of spectrum access for all users, expediting coordination of shared use, and implementing a spectrum management paradigm that meets the needs of both federal and commercial users.

The CBRS SAS utilizes location and technical operating parameters from user equipment, together with collected sensor information, to manage users and make spectrum available to whoever needs it. It’s also smart. So the more you use it, the more data it collects, the better it gets at managing spectrum. This data will significantly expedite the process of both assessing spectrum use and coordinating shared access. Additionally, the SAS  conducts spectrum usage assessments in seconds, among other things. We go into great detail on the automation benefits of SAS in our response.

3. The National Spectrum Strategy should leverage dynamic sharing technologies to promote the U.S. mission and industry abroad.

We believe the National Spectrum Strategy should not only adopt a flexible spectrum management policy for U.S. operations but also emphasize the importance of promoting the use of such flexible policies in other regions of the world, including through international regulatory and standard-setting bodies. Promoting the use of flexible spectrum management policies would advance the export of business models, products, and services developed by U.S. industry and aid in ensuring that Federal users are able to continue to access spectrum bands critical to their missions, even as foreign administrations reallocate bands for other uses.

4. The National Spectrum Strategy should leverage and extend existing research, development, and standards work to maximize the effectiveness of the spectrum management paradigm.

We ask that NTIA ensure the National Spectrum Strategy promotes the use of open standards and automated enforcement mechanisms to facilitate the efficient use of spectrum. The WInnForum is a great example of how this can be done. We also believe in cross-stakeholder RDT&E to ensure the CBRS spectrum is used as densely and efficiently as possible.

The race to 5G is on, and we’re ready to do what we can to make sure the U.S. hits its stride. We look forward to working alongside NTIA and Federal users to ensure we are providing sustainable, flexible spectrum access for all those who need it – Federal and non-Federal users alike.