Are Millimeter Wave Radios Safe?

Deep inside the filing of the recent docket at the FCC that resulted in eased access to poles for 5G providers were comments that warned about the unknown health impacts of millimeter wave radiation. A group of 225 scientists from 41 countries filed comments in Dockets No. 15-79 asking that the FCC be cautious in implementing millimeter wave radiation without further scientific research into the impacts of prolonged exposure of the radiation to humans. These scientists have all published peer-reviewed papers on the topic.

As scientists are wont to do, their wording sounds cautious, but in scientific language is a stern warning: “There is scientific evidence to cause concern among independent scientists, that this new infrastructure, on top of existing electrical and wireless infrastructures, will cause more harm to mankind and nature . . . The FCC needs to critically consider the potential impact of the 5th generation wireless infrastructure on the health and safety of the U.S. population before proceeding to deploy this infrastructure.”

I looked around the web to find some of the research that’s been done in this area in the past. A quick web search showed:

·         The biggest impact of millimeter wave radiation is on the skin and 90% of the transmitted power is absorbed by the dermis and epidermis layers of the skin – meaning concerns about skin cancer.

·          A 1994 study showed that low levels of millimeter radiation created lens opacity in rats, which is linked to cataracts.

·         A 1992 Russian study found that frequencies between 53-78 GHz caused overall stress in rats that manifested by an increase in arrhythmia and other changes to heart rates.

·         A 2002 Russian study found that exposure to low level 42 GHz radiation had a profound impact on the overall immune systems in rats.

·         A 2016 Armenian study observed that millimeter wave radiation created changes in the cells of bacteria. They postulated that the radiation could do the same to humans. This study concluded that changes to bacteria could change result in increasing drug resistant.

·         Another Armenian study showed that the impact to plants might be even greater than to animals.

·         Dr. Joel Moskowitz of UC Berkeley says that the impacts of all of these other studies might be understated since 5G uses pulsed frequencies. The studies were all done using constant frequency and Dr. Moskowitz has shown that pulsed frequencies magnify the impact of radiation on organisms.

One of the handful of current uses of millimeter wave radiation is in airport scanners, which use frequencies between 24 – 30 GHz. Numerous studies have shown that the likely exposure from these scanners is safe, but made the conclusion based upon the relative short burst of exposure. The issue that has scientists concerned about 5G is continuous transmission from poles in front of homes, and perhaps eventually building some of this frequency into cellphones.

Obviously, no study has yet shown a direct health impact from pole-mounted 5G transmitters since they are just now starting to see their first deployments. The scientific evidence of the dangers of the prolonged low-level radiation has a lot of people concerned. I’ve been contacted by several groups that are starting to alert their local officials of this danger (the inbox of a blogger can be really interesting). Nationwide several local politicians have jumped on the issue.

The question these local groups are asking is if there is any way to use the health concerns to try to block 5G deployment in their neighborhoods. It looks to me like the recent FCC order for allowing small cell sites on poles doesn’t contain much ambiguity – pole owners have a federal mandate to connect the 5G devices. However, that order is being challenged in court by numerous states and cities and I imagine that the health concerns are going to be one of the issues raised in those appeals – with the primary legal tactic challenging if the FCC has the jurisdiction to override cities on pole issues.

Interestingly, Verizon has announced a timeline that seems to be going full bore on installation of 5G transmitters. The industry is usually cautious about relying on any FCC order until it’s been vetted by the courts, but perhaps Verizon is only concentrating on 5G deployment in cities that have invited them to deploy, like Sacramento. It won’t be surprising to see cities ask for an injunction against deployment until the courts decide on the issues.

Will South Dakota Get 5G?

The Senate Commerce Committee held a recent hearing in Sioux Falls, South Dakota talking about the benefits that 5G will bring to the state. The hearing was chaired by Senator John Thune, who’s one of the primary telecom-related members of Congress.

A local paper quoted Thune as claiming that 5G is going to transform the economy of the country and of the state. He cited the same 5G talking points used by the FCC in their recent order that mandated cheap and fast connections to poles for 5G transmitters. Thune also said we’re in a race with China, Japan and South Korea and that we can’t afford to lose the 5G race.  FCC Commissioner Brad Carr was at the hearing and said that 5G could bring hundreds of millions of dollars of economic benefit to the state. He also estimated that realizing the benefits of 5G would require hundreds of thousands of small cells mounted on poles and light poles in the state.

The numbers cited in this hearing stun me. What would it mean to have hundreds of thousands of 5G transmitters on poles in South Dakota and could such a network create hundreds of millions of benefits for the state? I decided to try to put those numbers into context.

I still don’t know what a 5G transmitter on a pole will cost. I’ve heard that a full-blown small cell site currently costs more than $15,000 – but I have to assume that in order to make this even reasonably profitable that most of the devices in a 5G network will have to cost far less (and likely have far less functionality than a full-blown small cell site). Assuming thst that manufacturers will somehow get the installed price down to $2,500 each, then deploying on 200,000 poles (derived from “hundreds of thousands of poles”) equates to a cost in the state for just for the pole electronics of $500 million. This doesn’t include the cost of the fiber and other backhaul costs needed to support the 5G gigabit network.

I look at that $500 million number, knowing that it’s only a portion of the cost of deploying 5G and I wonder who is going to make that kind of investment in South Dakota. It’s not going to be the two primary incumbents, CenturyLink or Midco, the primary cable TV incumbent. It’s unlikely that Verizon owns any significant amounts of fiber in the state and they are not likely to do much there. I look around the industry and I can’t see any major player who would make a $500 million investment in a state with so few people.

Consider the demographics. South Dakota is one of the least populated states and the Census estimates the population to be around 870,000 with almost 400,000 housing units. The biggest city is Sioux Falls with a population of 176,000, Rapid City has 70,000 and cities are much smaller after that. When you get outside the cities it’s one of the least densely populated states.

Even if somebody made that kind of investment in South Dakota, how do they make their money back? Very few large public companies today are willing to earn infrastructure returns on investments, which is one of the primary drivers of our infrastructure crisis. Almost nobody other than governments are willing to invest in projects that have 10 and 20-year paybacks. This is the primary reason why no big ISPs are building residential fiber-to-the-home. It’s hard to envision the paybacks for 5G being much faster than fiber.

If I do the math on a $500 million investment, it would require a new revenue stream of $35 per month for every one of the 400,000 households in North Dakota to repay that investment in 3 years. Even at 6 years that’s still $17.50 per month for every household in the state. When you consider that only a much smaller percentage of people would somehow pay for some sort of theoretical 5G product, the cost per potential customer becomes gigantic – if 25% of the people in the state somehow bought a 5G product that would require a new expenditure of $70 per home per month to pay this investment off in the six years that Wall Street might find acceptable.

Of course, the investment is not just $500 million because there are a lot of other costs to bringing a widespread 5G network. To build the kind of network envisioned at the Congressional hearing has to cost far north of a billion dollars, any possibly several billions if a lot of fiber has to be built. That makes me wonder what the 5G hype is all about. It’s hard to envision anybody making this kind of investment in South Dakota. I’m not busting on South Dakota because this same cost to benefit applies to any place outside of large NFL cities with a high density of households.

I don’t have a crystal ball and I can’t say that somebody won’t invest in 5G in states like South Dakota. But I understand business plans and paybacks and I can’t foresee any of the current big ISPs in the industry making the needed investments where housing density is low. Smaller ISPs can’t raise the huge amount of needed money. It’s certainly possible that some of the neighborhoods a few cities in the state might see some 5G, but that’s probably not going to be on anybody’s radar for a while. I’m skeptical because I just can’t see a way to make the math work.

Deploying 5G – It’s no Panacea

This was published last week as an article on WRAL Techwire, a Raleigh TV station. 

If you read many articles about 5G, you’d think that we’re on the cusp having wireless broadband brought to most homes in America, providing homes with another option for broadband. This idea was recently bolstered by news that Verizon plans to offer 5G wireless broadband to as many as 11 million homes over the next few years.

However, Verizon has one huge advantage over the rest of the market in that they already own an extensive fiber network that reaches to cellular towers, large businesses, schools, large apartment complexes and high-rise buildings. Verizon plans on leveraging this existing network to bring wireless broadband to neighborhoods lucky enough to be near to their fiber. It’s unlikely that anybody else will copy the Verizon business plan – the other big telcos with large fiber networks, AT&T and CenturyLink, have made it clear that they are not pursuing 5G broadband to homes.

Verizon has a second benefit that few others share. As a huge cellular carrier, Verizon will benefit by relieving the pressure on their cellular networks in neighborhoods where they offer 5G. The bandwidth being demanded on cellular networks is the fastest growing sector of the industry with total bandwidth requirements doubling every 18 months. Verizon will save a lot of money by not having to bolster their cellular backbones in 5G neighborhoods.

So, what would it take for anybody else to provide the same 5G wireless technology as Verizon? The 5G technology relies on the placement of small transmitters on utility poles or street lights and the FCC just passed rules making it easier for a provider to get the needed connections. Each transmitter will be able to wirelessly transmit broadband to homes or businesses in the immediate area. Verizon press releases say the effective distance for delivering a signal is up to 2,000 feet, but most of the industry thinks the realistic distance is closer to 1,000 feet. That means that any given pole-transmitter will be able to ‘see’ anywhere from a handful up to a few dozen homes, depending upon what’s called line-of-sight. The 5G spectrum requires a relatively clear path between the transmitter and a dish placed on the home – and that means that 5G is best deployed on straight streets without curves, hills, dense tree cover or anything that decreases the number of homes within range of a transmitter.

The first-generation Verizon technology claims broadband speeds of around 300 Mbps, with the goal to eventually reach gigabit speeds. That level of bandwidth can only be delivered to the pole-mounted unit in two ways – with fiber or with a high-bandwidth wireless link. If wireless backhaul is used to bring broadband to the poles there can be no obstructions between the pole units and the wireless basestation – unlike many kinds of wireless transmission, high-bandwidth wireless backhaul can’t tolerate any obstructions in the transmission path. That requirement for pure line-of-sight will make wireless backhaul impractical in many neighborhoods.

Where wireless backhaul won’t work a 5G network will require fiber to each pole transmitter. The cost of building fiber to neighborhoods is the biggest barrier to widespread 5G deployment. It’s expensive to string fiber in residential neighborhoods. The cost of putting fiber on poles can be expensive if there are already a lot of other wires on the poles (from the electric, cable and telephone companies). In neighborhoods where other utilities are underground the cost of constructing fiber can be exorbitantly high.

To summarize, a 5G network need transmitters on poles that are close to homes and also needs fiber at or nearby to each pole transmitter to backhaul these signals. The technology is only going to make financial sense in a few circumstances. In the case of Verizon, the technology is reasonably affordable since the company will rely on already-existing fiber. An ISP without existing fiber is only going to deploy 5G where the cost of building fiber or wireless backhaul is reasonably affordable. This means neighborhoods without a lot of impediments like hills, curvy roads, heavy foliage or other impediments that would restrict the performance of the wireless network. This means not building in neighborhoods where the poles are short or don’t have enough room to add a new fiber. It means avoiding neighborhoods where the utilities are already buried. An ideal 5G neighborhood is also going to need significant housing density, with houses relatively close together without a lot of empty lots.

This technology is also not suited to downtown areas with high-rises; there are better wireless technologies for delivering a large data connection to a single building, such as the high bandwidth millimeter wave radios used by Webpass. 5G technology also is not going to make a lot of sense where the housing density is too low, such as suburbs with large lots. 5G broadband is definitely not a solution for rural areas where homes and farms are too far apart.

5G technology is not going to be a panacea that will bring broadband to most of America. Most neighborhoods are going to fail one of the needed parameters – by having poles without room for fiber, by having curvy roads where a transmitter can only reach a few homes, etc. It’s going to be as much of a challenge for an ISP to justify building 5G as it is to build fiber to each customer. Verizon claims their costs are a fraction of building fiber to homes, but that’s only because they are building from existing fiber. There are few other ISPs with large, underutilized fiber networks that will be able to copy the Verizon roadmap. With the current technology the cost of deploying 5G looks to be nearly identical to the cost of deploying fiber-to-the-home.

Flexible Numerology

This is the last in a series that looks at the underlying technologies that will create improvements for 5G – I looked previously at MIMO antennas and network slicing. Today I look at flexible numerology. Flexible numerology, in a nutshell involves new techniques that allow for changing the width of data channels in a frequency band.

The easiest way to understand the issues involved is to think back at how we used wireless devices in the past. Anybody that ever fiddled with an older 802.11n WiFi router using 2.4 GHz remembers directing different devices in the home to channels 1,6 or 11. While the 2.4 GHz band has 11 separate available channels, most wireless router manufacturers limited the use to those three channels in order to avoid cross-channel interference. They knew that if a home only used these three channels they’d likely not see such interference and would get the maximum performance on each channel. However, the decision to use only those three channels limited the amount of bandwidth that can be utilized. In peak usage situations only 3 of the 11 channels of 2.4 GHz are carrying bandwidth – avoiding interference meant not using much of the available frequency.

It’s easy to think of the channels within a wireless frequency as separate channels, because that’s how they are defined at the FCC. Cable companies are able to create distinct channels of frequency within the controlled confines of a coaxial cable in way to limit interference between channels. But when transmitted in the wild through the air all sorts of interference arises. Anybody old enough to remember watching TV in the 50s can remember times when you could see ghosts of a nearby channel when you were watching one of the low channel numbers.

Our cellular networks have been designed in a similar fashion to the WiFi channels. Within each of the frequencies used for cellular service are channels predefined by the FCC, with buffers between each channel. However, even with the buffers there is cross-channel interference between neighboring channels, and so the cellular carriers have selectively chosen to spread the actual use of frequency in ways similar to how we used channels 1,6 and 11 for WiFi.

Flexible numerology is new goal for 5G that was published with the 3GPP Release 15 standard. Flexible numerology is part of a system for allocating frequency in a new way that is intended to get the most and best use of the spectrum.

5G will use the same underlying method for modulating signals as 4G LTE – orthogonal frequency division multiplexing (OFDM). The OFDM scheme is the current way to try to get the best use of frequency and with OFDM a data stream is split across several separate narrowband channels to reduce interference, much in the same way that we used the three channels of WiFi.

Flexible numerology is going to give the cell site the option to create much smaller narrowband channels within the channels described in the OFDM standard. That’s the magic sauce that will enable 5G to communicate with huge number of devices without creating massive interference.

Consider a situation of two users at a 5G site. One is an IoT sensor that wants to trickle small amounts of data to the network and the other is a gamer that needs bursts of huge amounts of bandwidth. In the LTE network both devices would be given a narrowband channel – the IoT device for perhaps a tiny amount of time and the gamer for longer bursts. That’s an inefficient use of frequency since the IoT device is transmitting only a tiny amount of data. For even the short time that the cell site communicates with that device, in an LTE network the device commands as much bandwidth as any other user.

Flexible numerology will allow assigning a tiny slice of frequency to the IoT device. For example, the cell site might elect to assign 1/64th of a channel to the IoT device, meaning the remaining 63/64ths of the frequency can be assigned to some other purpose to be used at the same time that the IoT device is demanding bandwidth. In a 5G network the IoT device might grab a tiny slice of frequency for a short period of time and barely create a ripple in the overall use of frequency at the cell site.

The cellular network might treat the gamer the same as today but has numerous new options with flexible numerology to improve the gaming performance. It might separate sent and received data and size each path according to needs. It might create a connection for a longer time period than normal to efficiently transmit the needed packages. Essentially, flexible numerology lets the cell site treat every customer differently depending upon their specific needs.

This implementation of flexible numerology for 5G is complicated and will require new algorithms that ultimately get built into the chips for 5G devices. It’s always interesting to watch how new standards are implemented in the industry. I’ve seen numerous papers on the web over the last few months from labs and universities looking at the challenges of flexible numerology. These investigations will eventually get translated into lab trials of devices, and, if those trials are successful make it into the production for both cell sites and cellular devices. This is why a new standard like 5G can’t be implemented immediately. Standards define the problem, and then scientists, engineers and manufacturers take a shot at making the new ideas work (or sometimes find out that they don’t work). It’s likely to be years until the flexible numerology is made to work good enough to be in everyday use in cell sites – but when it does the utilization of frequency will be significantly improved, which is a key goal for 5G.

I’m Not a Fan of the 5G Hype

I read a lot of articles talking about what a huge deal 5G will be for the economy. The source of the excitement is the huge numbers being thrown around. For example, Qualcomm and IHS Technology issued a report in 2017 that estimated that 5G could enable $12 trillion in economic output around the world by 2035. That same report made the incredibly hyped claim that 5G could be as important to the world as the introduction of electricity. It’s no wonder that financial people are excited about the potential for 5G and why so many companies want to somehow grab a piece of this new market.

But I look around my own part of the world and I have a hard time seeing this kind of impact. I live in a town of 90,000 people. If we are like the average US market then roughly 85% of homes here already have landline broadband. Practically everybody here also has a cellphone, with the majority using smartphones.

People may read my blog and think I am not a fan of 5G – but that’s not true, I’m just not a fan of the hype. I would love for Verizon to offer me another choice of home broadband – I would consider changing to Verizon at the right price, as would many other households. My biggest question is how much value Verizon would create by introducing 5G in my town. Let’s say Verizon was to capture 30% of the broadband market here – that certainly creates an advantage to Verizon and gives them a significant new revenue stream. However, for every customer Verizon gains, Charter or AT&T would lose a customer, and overall that’s a zero-sum game. Further, if you assume that 5G competition would drive down prices a bit (it might not since oligopolies tend to not compete on price), then the overall spending on broadband in the town might actually decrease a bit.

The same thing would happen with cellular 5G. The big four cellular companies will have to spend a lot to upgrade all of the cell sites here to 5G. We’re a hilly and heavily wooded City and it will take a lot of small cell sites just to fill in the existing cellular holes. But unless they can find a way to charge more for 5G cellular broadband, then cellphone broadband is also a zero-sum game. Everybody in town already has a cellphone and a data plan, and the long-term trend is for cellular data prices to drop. I don’t see the new revenue stream from 5G cellular that will pay for the needed upgrades. Perhaps faster cellular data speeds will attract more people to drop landlines, but that’s also a zero-sum for the market as a whole.

There is one new aspect of 5G that the cellular carriers are counting on to create a new revenue stream. Once the 5G technology has been developed, the 5G standard calls for the ability of a cell site to communicate with as many as 100,000 devices – a huge increase over today’s capabilities. The cell carriers are clearly banking on IoT as the new revenue opportunity.

However, that kind of transition isn’t going to happen overnight. There are a whole lot of steps required before there is a huge cellular IoT revenue stream. First, the technology has to be developed that will handle that huge number of IoT devices. The 5G core standards were just developed last year and it will take years for vendors and labs to achieve the various goals for 5G. As those improvements are realized it will take a lot longer to introduce them into the cellular networks. We are just now finally seeing the deployment of 4G LTE – AT&T is just now deploying what they call 5G Evolution into any major markets, which is actually fully-compliant 4G LTE. The same slow roll-out will occur with 5G – we’ll advance through 4.1G, 4.2G, etc. until we see fully-compliant 5G network in a decade.

We’ll also have to wait for the rollout of IoT sensors that rely on a 5G network. It will be a bit of a chicken and egg situation because nobody will want to deploy devices that need 5G until 5G is active in a sufficient number of neighborhoods. But eventually this will come to pass – to a degree we can’t predict.

The question is if IoT usage is the trillion-dollar application. I certainly look forward to a time when I might have an embedded chip for 24/7 health monitoring using a 5G network – that’s a service that many people will be willing to pay for. But there is no guarantee that the revenue streams will materialize for IoT monitoring to the extent envisioned by AT&T and Verizon. I’ve done the math and the only way that the carriers can see a trillion-dollar benefits from IoT is if future homes have an IoT monitoring bill of the same magnitude as our current cellular or broadband bills – and that may never come to pass. I would love to see a concrete business plan that predicts where these huge new benefits come from, but I’ve seen nothing specific other than the big claims.

There is one aspect of the hype that I do buy. While I can’t see any way to equate the value of 5G to be as important as electricity, it is likely to share the same kind of introduction cycle that we saw with the electric grid. It took 25 years for electricity to spread to the majority of US cities and another 25 years until it was in most of rural America. New technologies today deploy faster than the deployment of electric grids – but this still can’t happen overnight and is at likely to be many years until rural America sees 5G cellular and a lot longer for 5G fixed broadband.

If you believe the hype in the press, we’ll start seeing big benefits from 5G in 2019 and 2020. I can promise you a blog at the end of next year that looks to see if any of this hype materialized – but I already suspect the answer will be no.

False Advertising for 5G

As has been expected, the wireless carriers are now actively marketing 5G cellular even though there are no actual 5G deployments. The marketing folks are always far in front of the engineers and are proclaiming 5G today much in the same way that they proclaimed 4G long before it was available.

The perfect case in point is AT&T. The company announced the launch of what they are calling 5G Evolution in 239 markets. They are also claiming they will be launching what they are calling standards-based 5G in at least 19 cities in early 2019.

The 5G Evolution product doesn’t contain any part of the new 5G standards. Instead, 5G Evolution is AT&T’s deployment of 4G LTE-Advanced technology, which can be characterized as their first fully-compliant 4G product. This is a significant upgrade that they should be proud of, but I guess their marketing folks would rather call this an evolutionary step towards 5G rather than admit that they are finally bringing mature 4G to the market – a claim they’ve already been making for many years.

What I find most annoying about AT&T’s announcement is the claim that 5G Evolution will “enable peak theoretical wireless speeds for capable devices of at least 400 megabits per second”, although their footnote goes on to say that “actual speeds are lower and will vary”. The 4G standard has been theoretically capable of speeds of at least 300 Mbps in a lab setting since the standard was first announced – but that theoretical speed has no relevance to today’s 4G network that generally delivers an average 4G speed of less than 15 Mbps.

This is like having a fiber-to-the-home provider advertise that their product is capable of speeds of 159 terabits per second, although actual speeds might be something less (that’s the current fastest speed achieved on fiber by scientists at the NICT Network System Research Institute in Japan). The intent of the statement on the AT&T website is clearly aimed at making people think they will soon be getting blazingly fast cellular data – which is not true. This is the kind of false advertising that is overstating the case for 5G (and in this case for 4G) that is confusing the public, politicians and regulators. You can’t really blame policy-makers for thinking that wireless will soon be the only technology we will need when the biggest wireless provider shamelessly claims speeds far in excess of what they will be ever be deploying.

AT&T’s second claim of launching standards-based mobile 5G in 19 markets is a little closer to the truth, but is still not 5G cellular. That service is going to deploy millimeter spectrum hotspots (a technology that is being referred to as Mi-Fi) in selected locations in 19 cities including Las Vegas, Los Angeles, Nashville, Orlando, etc.

These will be true hotspots, similar to what we see in Starbucks, meaning that users will have to be in the immediate vicinity of a hotspot to get the faster service. Millimeter wave hotspots have an even shorter propagation distance than normal WiFi hotspots and the signal will travel for a few hundred feet, at best. The hotspot data won’t roam and will only work for a user while they stay in range of a given hot spot.

AT&T hasn’t said where this will be deployed, but I have to imagine it will be in places like big business hotels, convention centers and indoor sports arenas. The deployment serves several purposes for AT&T. In those busy locations it will provide an alternate source of broadband for AT&T customers who have a phone capable of receiving the Mi-Fi signal. This will relieve the pressure on normal cellular data locally, while also providing a wow factor for AT&T customers that get the faster broadband.

However, again, AT&T’s advertising is deceptive. Their press releases make it sound like the general public in these cities will soon have much faster cellular data, and they will not. Those with the right phone that find themselves in one of the selected venues will see the faster speeds, but this technology will not be deployed to the wider market in these cities. Millimeter wave hotspots are an indoor technology and not of much practical use outside. The travel distances are so short that a millimeter wave hot spot loses a significant percentage of its strength in the short distance from a pole to the ground.

I can’t really blame the marketing folks at AT&T for touting imaginary 5G. It’s what’s hot in the marketplace today and what the public has been primed to expect. But just like the false hype when 4G was first introduced, cellular customers are not on the verge of seeing blazingly fast cellphone service in the places they live and work. This advertising seems to be intended to boost the AT&T brand, but it also might be defensive since other cellular carriers are making similar claims.

Unfortunately, this kind of false advertising plants the notion for politicians and policy-makers that cellular broadband will soon be all we will need. That’s an interesting corporate tactic to take by AT&T which is also building more fiber-to-the-premise right now than anybody else. These false claims seems to be most strongly competing with their own fiber broadband. But as I’ve always said, AT&T wears many hats and I imagine that their own fiber folks are as annoyed by this false advertising as the rest of us in the industry.

The 5G Summit

There was recently a 5G Summit held at the White House to discuss how the administration could encourage the public sector to deploy 5G as quickly as possible. The purpose of the summit was summarized well by Larry Kudlow, the director of the National Economic Council who said the administration’s approach to the issue is ‘American first, 5G first”.

Kudlow went on to say that the administration wants to give the wireless industry whatever they need to deploy 5G quickly. The FCC recently took a big step in that direction by speeding up and cutting the costs for attaching 5G small cell sites to poles and other infrastructure in the right-of-way.

There are a few other ways that were mentioned about how the administration could foster 5G deployment. David Redl, the head of the NTIA called for the government to make the needed spectrum available for 5G. The FCC is in the process of having an auction for spectrum in the 25 GHz and 28 GHz bands. The FCC is also working towards finalizing rules for the 3.5 GHz and 3.7 GHz spectrum (the 3.5 GHz CBRS band will be the subject of tomorrow’s blog).

I hope that the fervor to promote 5G doesn’t result in giving all of the new spectrum to the big wireless carriers. One of the best things the FCC ever did was to set aside some blocks of spectrum for public use. This fueled the WiFi technology sector and most homes now have WiFi networks. The spectrum also powers the fixed wireless technology that is bringing better broadband to rural America. While 5G is important, the administration and the FCC need to set aside more public spectrum to allow for innovation and broadband deployment outside of the big ISP sector.

I found this summit to be intriguing because it’s the first time I recall the government so heavily touting a telecom technology before it was introduced into the marketplace. There was mention in the Summit that the US is in a race with China to deploy 5G, but I’ve never seen anybody explain how that might give China an advantage over the US. China is far behind the US in terms of landline broadband and it makes sense for them (and much of the rest of the world) to stress wireless technologies.

There certainly was no similar hoopla when Verizon first announced the widespread deployment of fiber – an important milestone in the industry. In fact, at the time the press and Wall Street said that Verizon was making a mistake. It’s interesting to see that Verizon is again the market leader and is the only company, perhaps aside from T-Mobile, that has announced any plans to deploy 5G broadband. It’s worth looking back in history to remember that no other big ISPs followed Verizon’s lead and for over a decade the only other fiber to residences was built by small telcos, municipalities and small overbuilders.

Even if the government makes it as easy as possible to deploy 5G, will other big ISPs follow Verizon into the business? For now, AT&T has clearly decided to pass on the technology and is instead investing in fiber to homes and businesses. The big cable companies have shown no interest in the technology. The cellular companies will upgrade mobile networks to 5G but that’s expected to happen incrementally over a decade and won’t be a transformational technology upgrade. 4G LTE is still expected to be the wireless workhorse for many years to come.

There was one negative issue mentioned at the Summit by Rep. Greg Walden of Oregon. While praising efforts to deploy 5G he also said that we needed to take steps to protect the supply chain for 5G. Currently the FCC has precluded the use of any federal funds to buy technology manufactured by Huawei. But a more pressing issue is the current tariffs on China that are inflating the cost of 5G electronics – something that will be a barrier to deployment if they remain in place for very long.

It’s likely that the Summit was nothing more than politicians climbing onto a popular bandwagon. There has been enough hype about 5G that much of the public views it as a cutting-edge technology that will somehow transform broadband. We’re going to have to watch the Verizon deployment for a while, though, to see if that is true.

The administration has it within their power to create more benefits for companies willing to invest in 5G. However, helping huge companies like Verizon, which doesn’t need the help, is not likely going to bring 5G to more homes. And federal money won’t transform 5G into a technology that can benefit rural America, since 5G requires a robust fiber network. I just hope this doesn’t signal more giveaways to the giant ISPs – but if the FCC’s small cell order is any indicator, that might be all it means.

Network Slicing

Almost every PowerPoint I’ve seen about 5G cellular networks talks about network slicing. This is a new networking term unique to 5G. This is the second article looking at new features of 5G, with the first being a blog on Massive MIMO.

Cellular networks are now expected to make multiple simultaneous connections with different characteristics. The examples used in most presentations explain how a cellular network should be able serve traditional cellular voice, more robust cellular data, IoT monitoring and connecting to self-driving cars. Each of these applications requires connections with different bandwidth, latency, security etc. The cellular network will be expected to immediately recognize the required need and respond appropriately.

It’s a challenge because of the diverse nature of each kind of network demand. For example, an IoT network will be comprised of huge numbers of devices mostly in fixed locations and requiring small bandwidth. Contrast this with cellular data, where as we increase data speeds we’ll expect the network to deliver large amounts of bursty bandwidth to mobile devices by combining multiple channels of frequency and even signals from multiple cell sites. Demands for self-driving cars or gaming will expect large and steady bandwidth with extremely low latency. These examples are some of the primary uses for a future cell site, but there are dozens of other kinds of connections that will be needed.

The ability to design a quick response to diverse network needs is made more difficult by the fact that every market for every cellular carrier uses a different combination of spectrum blocks and different channels within the blocks. This makes it impossible to design a ‘standard’ network strategy that will work everywhere. To be effective a cellular network must combine the spectrum components available in a given network to create a homogeneous network.

Landline networks are able to handle diverse types of demands using a combination of quality of service (QoS) and techniques like virtual private networks (VPNs). QoS uses a feature called differentiated services to classify and manage different types of IP traffic like streaming video, VoIP, web surfing, etc. Many networks also then use VPN functions like IP tunneling to isolate data paths aimed at specific customers.

These same techniques are hard to apply on a cellular network. Cellular systems need a sophisticated networking solution because the network is limited at any given time by the number of channels of frequency that are not being used. We don’t worry about this on landline networks because we can flood the network with enough bandwidth to accommodate every request. To most effectively use the available bandwidth a cellular network must quickly recognize the exact nature of the bandwidth being demanded and then cobble together the most efficient use of available spectrum. Current QoS solutions can’t adequately distinguish between different types of traffic to the degree needed to make this determination.

Network slicing provides a new way to partition the spectrum on a network. In layman’s terms it performs several functions that differ from QoS. Network slicing can quickly determine the nature of a bandwidth demand. It can then create a wide range of network responses.

One of the features of network slicing is that the network can be pre-configured for different uses. For example, a portion of the network can be isolated and assigned to a single function like IoT. Even more important, new revenues can be generated by partitioning and isolating a part of the network for a single customer – a business within range of a small cell site can be sold a share of the capacity of the cell site to guarantee better service. Slicing could also segregate traffic better – for instance, a cellular carrier could isolate traffic from one of it’s MVNO partners from other traffic on the cell site.

Network slicing can also subdivide spectrum. It allows the cell site to use a portion of a channel for a given connection rather than the whole channel. Slicing off small amounts of spectrum for small bandwidth needs if far more efficient than how cell sites operate today.

Finally, network slicing introduces a lot of new data features not available with QoS. The network can customize the way it handles any particular data stream in terms of data priority, encryption, data storage, etc. The network can more easily give priority to things like law enforcement connections, or IoT signals from critical devices.

FCC Small Cell Order – Timelines and Fees

Yesterday’s blog looked at the preemption issues in the FCC’s new ruling concerning small cell deployment on utility poles, light poles, buildings and other infrastructure. The order is WT Docket No. 17-79; WC Docket No. 17-84 and was approved on September 27. Today I’ll look at the rest of the order concerning timeline and fees.

The new rules establish a ‘shot clock’ for the local review of small cell deployments. The FCC established similar shot clocks in 2009 for the deployment of the traditional cell tower deployments. They said then that localities had to review an application for collocating cellular infrastructure within 90 days and gave localities 150 days to review an application for placing a new cellular tower. Cities were free to reject requests if an application failed to meet local regulations and the shot clock defined the time during which a locality had to provide a response to a cellular carrier.

The FCC just set a shorter shot clock for small cell deployment, and localities now have 60 days to process an application for collocation of small cell equipment on a facility that already has similar infrastructure and 90 days to review an application for a new placement. Interestingly, in the case of small cells, those time lines are likely reversed. Cities probably have more concerns about placing multiple small cells on the same pole, yet that situation has the shortest time frame for review.

Numerous cities intervened in the docket and argued that small cell devices are not necessarily ‘small’. While many devices are the size of a pizza box (the example used by the FCC), there have been requests to place cabinets nearly the size of refrigerators on poles. The FCC resolved these issues by defining devices covered by the new rules as ‘Small Wireless Facility’ that must meet the following parameters: the pole or structure can’t be greater than 50 feet tall; the small cell device can’t add more than 10% to the height of an existing structure; the equipment can’t be larger than 28 cubic feet (excluding antennas) and an antenna can’t be more than 3 cubic feet. This limits the devices to boxes that are just a hair larger than a 3 X 3 X 3 foot cube.

The FCC also suggested limits on the fees that a city can charge for access to rights-of-way. They suggest application fees be no more than $500 per application that can include up to five small cell devices, with an additional $100 per small cell after five. The FCC also suggested a fee limit of $270 per year per small cell to cover any recurring fees including rights-of-way. The new rules say that carriers can’t challenge rates at or below these suggested limits.

The FCC new rules would allow a city to charge fees greater than these suggested limits. However, this adds a burden on the city to demonstrate that the costs are reasonable and are a reasonable approximation of actual costs. The FCC says that it would expect only ‘limited circumstances’ under which a city could charge higher rules. Many cities filed in the docket that their costs to review an application is far greater than $100 per site since they usually do a field visit for each proposed site and often hire wireless engineers to make the review.

Many municipalities in the docket cited costs higher than these FCC limits and these low fee levels are why some are calling this a multi-billion dollar giveaway to the cellular carriers. They not only get small cells deployed more quickly, but they are paying a lot less for the applications and rights-of-way fees.

It’s clear that this docket gives 5G and other small cell providers everything on their wish list. It’s been rare in the past to see FCC orders that are so blatantly in favor of one side of an issue. As a regulator the FCC is supposed to weigh the views and needs of everyone involved in a given issue and try to compromise on common ground. However, this order is entirely one-sided in favor of wireless carriers.

Nobody doubts that 5G is an interesting new technology that will bring benefits to many. However, the recently announced Verizon 5G deployments are talking about bringing broadband speeds in the range of 200-300 Mbps. Everything I read predicts that the 5G improvements to cellular speeds will be incremental over a decade and bring speeds as fast as 100 Mbps for those in areas with multiple small cells. It’s clearly unprecedented for the FCC to come out so heavily in favor of a technology before it’s even been proven in field deployment. It’s still unusual for the FCC to protect a specific technology and it would still be nice to see them make it easier to deploy fiber.

The FCC has taken sides to protect new industries before, just not so early in the game. There were rules that fostered the deployment of cable TV, of cellphone and of landline broadband – but these rules generally were issued when it became clear that the new industry needed market protections to grow and thrive. I guess it’s due to the heavy lobbying that declares that 5G will solve all of our broadband problems – but we’re too early into the new technology to know yet if that’s true.

FCC Small Cell Order – Preemption

On September 27 the FCC adopted new rules that apply to the deployment of small cells on utility poles, light poles, buildings and other infrastructure. The order largely preempts state and local authority and today’s blog will focus on the preemption issue.

The orders are in WT Docket No. 17-79; WC Docket No. 17-84 and comes in two parts. First is a Declaratory Ruling where the FCC examines and then claims authority to override local and state regulations on small cell deployment issues. The second portion of the order is a Third Report and Order that sets a new ‘shot clock’ for processing small cell applications and which sets caps on local fees for connecting small cell sites.

FCC orders often conflict with state and local regulations and the FCC always has to decide the extent to which they are willing to override state and local regulations. This is a particularly touchy topic for anything to do with pole attachments and rights-of-ways because the Telecommunications Act of 1996 explicitly gave states the right to establish their own rules governing pole attachments. Since that order 22 states have elected to establish their own rules for connecting to poles while the remaining states follow the FCC pole attachment rules. However, it’s never been clear to what extent the 1996 Act gave any rights to cities.

With that said, states are generally not allowed to establish rules that conflict with the intent of FCC rules. For example, the 1996 Act gave the rights for carriers to gain access to poles, ducts and conduits, but state regulation can’t get rid of that right. State pole attachment rules generally clarify the specific application of the FCC rules and in some cases are more stringent than the FCC rules. For examples, there are states that have shorter time lines for attaching fiber to poles than the FCC rules.

This particular order has more than the usual share of legalese, but my interpretation of this order is that it applies everywhere and that the FCC has largely preempted all state and local regulations related to small cells. For example, the order presumes that any local regulation that would cause a delay in new FCC’s expected timelines would constitute an ‘effective prohibition of service”. The FCC says explicitly that delays cause by any “state or local regulation of wireless infrastructure deployment constitutes an effective prohibition of service prohibited by Sections 253 or 332(c)(7) of the Communications Act.

In regulatory terms that’s strong language – for example, the order says that states can have rules covering issues like aesthetics or the undergrounding of utilities, but any such rules cannot delay the FCC timelines. That’s important because it provides a way for carriers to get a court injunction against any city that delays the small cell deployment process for any reason. I’ve read the order several times and my interpretation is that it’s nearly impossible for a municipality to say no to a small cell request. It looks like cities must meet the FCC timelines without exception or delay.

There was a concern by many cities that the FCC was going to end the municipal exemption for pole attachments that has excused municipally-owned poles from FCC pole attachment rules. The order doesn’t address that issue, so it doesn’t appear that these new rules would apply to utility poles owned by a municipal utility. It’s less clear to me if this order applies to light poles or other structures that don’t connect to wires. (See the first comment below – the FCC took the position in a footnote that the order applies to all municipally-owned assets in the public ROW, but is not so clear on assets outside the ROW).

There is also a practical issue that I don’t see addressed in the order. Not all parts of a small cell deployments are in the air and there can be cabinets and other devices at street level used to power the small cells. Since cities are not allowed to cause the delay of small cell deployment, that logically would preclude local that slow the ground-based part of such deployments. That is an expansion of FCC jurisdiction – they’ve never exerted jurisdiction over the placement of cabinets since those rules consider numerous local issues like safety, handicapped access and aesthetics.

This order is clearly tilted in favor of small cell carriers. The wording of the order reads like the industry wish list and even has some language suggested by the wireless carriers. The carriers want to be able to deploy small cells anywhere quickly, at a low cost, and this order grants them that right. I’ve seen articles that claim this is a billion-dollar giveaway to the carriers.

Since this order preempts local and state pole attachment authority I would expect a flood of lawsuits challenging the order. In this industry the best regulations have always been the ones that balance the needs of all parties. There are clearly local concerns about the proliferation of small cell devices and this ruling is deaf to local concerns. Interestingly the cellular carriers and a number of big cities have already negotiated solutions to deploying small cells – and in every case this ruling is more severe than arrangements the carriers have willingly agreed to. That is the best evidence that this order has gone too far in the favor of the carriers.