Stuck on the Runway: The Damage to Core U.S. Strategic Interests from an Unwarranted Delay to 5G
January 4, 2022
In November 2021—just a month before AT&T and Verizon’s planned December 5 launch of 5G networks in major markets in the United States—the Federal Aviation Administration (FAA) issued a Special Airworthiness Information Bulletin seeking input on the supposed effects of 5G deployments in C-band radio frequency spectrum on aircraft altimeters operating on frequencies separated by at least 220 megahertz (and by 400 megahertz or more from the first tranche of C-band spectrum coming online).
This comes after last year’s record-breaking Federal Communications Commission (FCC) auction, where AT&T, Verizon, and other wireless carriers paid over $80 billion for licensed use of the C-band spectrum. Under law, they now have the right to use this spectrum for 5G, but the FAA is trying to stop this move to 5G.
The FCC adopted its 5G C-band rules in February 2020, after examining the aviation industry’s altimeter claims and after interagency consultation with the National Telecommunications and Information Administration (NTIA), which manages federal use of spectrum, as well as with federal spectrum users including the FAA. Now, a year and a half later, on the cusp of 5G deployment in the United States, the FAA has issued a public bulletin calling for data to assess anew any possibility of risk—despite a clean engineering bill of health from the FCC and the fact that in dozens of countries across the globe, 5G operators have deployed networks in C-band frequencies without any reports of interference.
AT&T and Verizon announced a voluntary 30-day delay in the commercial launch in the spectrum in light of the FAA bulletin. Following intense engagement with the FAA and FCC, they also announced a voluntary set of mitigation measures near airports and heliports for six months to prove, again, that there are in fact no indications of any aviation safety risks from use of C-band for 5G.
On New Year’s Eve, just days before AT&T and Verizon’s 5G deployments were to begin, Secretary of Transportation Pete Buttigieg and FAA administrator Stephen Dickson requested that they again delay their C-band deployment. The companies agreed to a further two-week delay and “in the spirit of cooperation and good faith” volunteered to adopt additional risk mitigation measures similar to those used in France. The companies noted that there is full FAA approval for U.S. flights into and out of France’s airports and that the “laws of physics are the same in the United States and France.”
This episode has deep roots. In the early 1900s, spectrum was the free range of the sky, and Congress created the FCC in 1934 to bring order to the airwaves with spectrum licensing and interference protection that provided certainty for investments in wireless technologies. For decades after, the primary users were the government and military, broadcasters, aviation, and cab dispatch radios. With the primitive technology of that time, there was little focus on efficient use of spectrum, and large "guard bands"—empty, unused spectrum between bands in use—were an inefficient tool to help avoid interference. Since there was usually limited competing use in many spectrum bands, the opportunity cost of guard bands was low. But the invention of the mobile phone changed this dramatically.
Three things make the older approach to spectrum management untenable. First, modern technology in software and antenna provides interference protection to nearby services without the need for large, empty guard bands. Second, there is intense commercial demand for mobile services and devices, and the promise of 5G is that this will go beyond individual smart phones to connected wireless devices in cars, factories, and hospitals. Wireless applications are the future of economic growth. The third change is that the United States now has a powerful, determined competitor who wants to lead in technology and 5G, and in this case, China is proving nimbler than the United States.
This is not a new challenge. The incumbents who were allocated spectrum in the last century when it was plentiful never want to move or upend the status quo. Put simply, this FAA warning was baseless, and the consequent deployment delay was unnecessary. Seventeen years of technical studies have informed the FCC’s rules on use of this spectrum. More than 40 countries, including major defense allies and commercial partners at whose airports and air bases hundreds of U.S. commercial and military aircraft take off and land every day, have deployed wireless communications services in the C-band with no indications of any harmful interference affecting altimeters. Even the FAA bulletin observes, “there have not yet been proven reports of harmful interference due to wireless broadband operations internationally.” The FAA’s action is based on one report by competitors for the spectrum. Spectrum engineers and a broad range of spectrum experts have denounced it as flawed (for a technical deep-dive see this point-by-point analysis).
This delay damages U.S. security and economic interests. It provides an unhelpful boost to Russia’s disinformation campaign that promotes fears about the safety of 5G. The delay in 5G deployment in the C-band is also a gift to China’s efforts in leveraging 5G deployments to expand its companies’ global market share in information and communications technologies, including through its “national champions” such as Huawei. The secure, reliable buildout of 5G service in the United States is a core national security interest. Early deployment of C-band spectrum for 5G is critical to the United States’ global leadership in next-generation wireless 5G products and services.
One of the strengths of the United States in the tech competition with China, until now, was its ability to flexibly reallocate spectrum to higher-value uses and not let entrenched interests block change. It cannot afford to let China and other competitors gain an advantage due to unnecessary delay, especially over alleged risks that have not been seen in the C-band deployments already operating in nearly 40 other countries.
Last year, the CSIS Working Group on Trust and Security in 5G Networks wrote about the importance of accelerating 5G deployment and provided recommendations for how the United States can achieve this important goal. This commentary adds one more recommendation: Congress and the Biden administration should make clear that the United States has two and only two spectrum regulators—the FCC for commercial use and the NTIA for government use. In her renomination hearing on November 17, FCC chair Jessica Rosenworcel called for “a whole-of-government approach” to spectrum management. That is the right approach. But “whole of government” does not mean every agency gets to create its own spectrum policy. This is not what Congress intended and it is not in the national interest. The administration should let the designated agencies, and not the FAA, decide how to regulate spectrum.
Clete Johnson is a non-resident senior fellow with the Strategic Technologies Program at the Center for Strategic and International Studies (CSIS) in Washington, D.C. James A. Lewis is senior vice president and director of the Strategic Technologies Program at CSIS.
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