Apple asks FCC for “light touch” as it explores 95GHz to 3,000GHz wireless options

Executive Summary:

Apple has written to the Federal Communications Commission (FCC) asking the agency to leave certain frequencies unlicensed or shared as it tests 95 GHz to 3,000 GHz wireless technology. A major part of this “5G” testing is working on millimeter wave radio spectrum, which was traditionally reserved for larger devices, such as radars, satellites and airport security scanners.  One year ago, we wrote that Apple would be testing millimeter wave technology in controlled facilities in Cupertino and Milpitas, California.  This is a follow up to that blog post


NOTE that millimeter wave spectrum has yet to be added to the IMT 2020 permitted frequencies.  Here’s the current status and future direction for IMT 2020 and “5G” spectrum:

The World Radiocommunication Conference 2015 (WRC-15) paved the way for the future development of IMT on higher frequency bands by identifying several frequencies for study within the 24.25-86 GHz range for possible identification for IMT under Agenda Item 1.13 of WRC-19 (see below).

The 24.25-27.5 and 37-43.5 GHz bands are prioritized within the ongoing ITU-R work in preparation for WRC-19 agenda item 1.13.  All geographical regions and countries are recommended to support the identification of these two bands for IMT during WRC-19 and should aim to harmonise technical conditions for use of these frequencies in 5G.

The frequency band of 27.5-29.5 GHz, though not included in the WRC-19 Agenda Item 1.13, is being considered for “5G” in the USA, South Korea and Japan, according to Huawei.

The first solid list of IMT 2020 frequencies will be set at the WRC-19 – World Radio Conference meeting- 28 October to 22 November 2019 in Sharm El Sheikh, Egypt.

To date, the most definitive document approved by ITU-R for IMT 2020 has been: Minimum requirements related to technical performance for IMT-2020 radio interface(s)



Until recently, consumer products did not use millimeter wave radio spectrum, which the FCC allocated to large devices such as satellites, radars, and airport security scanners. Over time, however, technology companies found that the millimeter wave spectrum could be used to radically improve mobile devices’ data speeds.

Starting this year, “5G” fixed broadband access products (which have nothing to do with the forthcoming IMT 2020 standard for real “5G”) will begin to use radios operating in the 24GHz to 29GHz range, radically increasing data bandwidth over short distances.  Non-cellular wireless technologies such as next-generation Wi-Fi or Bluetooth could conceivably occupy other frequencies.


In a recent letter to the FCC,  Apple requested the agency to leave substantial portions of the ultra-high-frequency radio spectrum unlicensed or shared — a so called “light touch” to “5G” regulation.  That suggests the iPhone king is already considering potential applications of 95GHz to 3,000GHz wireless technology,

The Apple-FCC letter is focused on even higher-frequency spectrum. Specifically, the company says that the commission needs to avoid making the mistakes of prematurely or narrowly licensing radio frequencies above 95GHz, as researchers are already looking at 120GHz to 260GHz and 275GHz to 450GHz ranges for “high-speed, short range” purposes. The concern is that the FCC will sell licenses to small stripes of spectrum now, then have to claw them back later once technology companies determine their best uses — a situation that just played out with 5G millimeter wave licenses, with billions of dollars in consequences.

“Apple supports the Commission’s proposal for experimental licensing in the bands above 95 GHz and believes that adopting this flexible model will help to spur innovation in the band,” the company said in a May 2 letter, signed by Mark Neumann, a senior engineer at Apple.

“As the band is still largely greenfield, this is a rare opportunity to allow for freedom of exploration that does not exist in other bands and advantage should be taken,” Apple continued.

Apple told the FCC it favored a “light regulatory touch” that would leave a greater share of the spectrum unlicensed, and open for anyone to use.  Apple’s comments were in response to the FCC’s request seeking comments on how to regulate the high-bandwidth wireless spectrum, often referred to as “super high” spectrum. Apple believes that the current approach to regulation is too far in favor of established, licensed technologies, instead of emerging uses that a company like Apple might be interested in.

Apple offered the FCC two key suggestions to prepare for next-generation wireless technologies. First, it says the FCC should “increase the fraction of the spectrum that it opens to unlicensed spectrum” (including licensed-unlicensed spectrum sharing), rather than heavily preferring licensed technologies, as is the case today. Second, it suggests that the FCC increase the size of unlicensed bands beyond the “too narrow” 1GHz to 7GHz currently proposed, permitting more space for upcoming devices to aggregate spectrum for massive bandwidth. “Very wide bandwidth operations” would call for “20 gigahertz or more to function optimally,” Apple notes, and could have benefits for “environmental protection, human safety, and manufacturing.”

What is this spectrum good for?

Currently, the frequencies that Apple is commenting on are unused — or “greenfield,” as Apple puts it.  But that doesn’t mean that there aren’t many different scientists and industry researchers who are starting to come up with ideas for those frequencies.  The big advantage to millimeter wave is that it can achieve very high data rates, with much more bandwidth than current cellular networks.

“As Apple says in its filing no one really knows what’s going to happen with that very high spectrum. But since something will someday it’s time to create a mechanism to use it. Maybe not Apple’s preferred unlicensed mechanism,” wireless consultant Steve Crowley told Business Insider in an email. “Regulation takes time, the standardization process takes time, product development takes time. It doesn’t hurt to take the first step.”

The FCC took that first step earlier this year, by filing a notice inviting comment on its proposed rules, which is what Apple responded to. “Now, I realize that some are skeptical that this spectrum can be used productively,” said FCC Chairman Ajit Pai in a statement earlier this year. “But the skeptics have been proven wrong before,” Pai added.

The more spectrum that remains unlicensed, the more likely it is that Apple can experiment in those radio frequencies and build them into its future products. The spectrum used by cellular networks is licensed, for example, but Wi-Fi uses unlicensed spectrum, which enabled Apple to use it in innovative ways, such as for wireless speakers and network syncing.

The FCC also makes money by auctioning licenses to specific bands of spectrum. And if FCC declares that  a new slice of spectrum is unlicensed, that means Apple can access it for free.  The question remains what it could be used for.  One possibility is to use those frequencies for infrastructure to enable “5G” or for fixed broadband access.

“I’d expect first uses of bands 95 GHz and above to be used for 5G small cell backhaul — interconnecting the millimeter wave cells connecting handsets, and fixed users, below 95 GHz,” Crowley told Business Insider. “Currently, bands under study (by whom?) include the so-called W-band (92-114 GHz) and D-band (130-175 GHz),” Crowley added.

Apple’s interest in millimeter wave:

Apple devices currently use Intel and Qualcomm modem chip sets to connect to cellular networks. The referenced FCC filing is only the latest sign that Apple is currently experimenting with millimeter wave technologies, which are expected to be a big part of “5G” networks, even if not used for mobile broadband access (see opinions above and below).

Apple has been testing millimeter wave technology in Cupertino, California since last May on the 28 GHz and 39 GHz, bands that are lower than the ultra-high spectrum Apple commented on.  Earlier this year, Apple applied to make both of its Cupertino, CA headquarters into “innovation zones” which would enable it to run tests more easily without regulatory headaches and applications.

Apple devices access spectrum in numerous licensed and unlicensed frequency bands. For example, iPhones use spectrum ranging from 13 megahertz (contactless payments via Apple Pay) to 5 gigahertz (802.11ac Wi-Fi with MIMO) and support more than 18 different LTE bands,” according to the Apple application, which was also signed by Neumann, the senior Apple engineer.

Last month, Apple pulled a job listing off of its site for a “mmWave IC design engineer,” which suggested it planned to build chips to work on 5G networks. Currently, Apple buys its modems from Qualcomm and Intel.

Experts have said that millimeter wave “might wind up being a kind of middle mile technology, connecting small cells which in turn connect to our phones or big ticket items like buses and home modem.”  Also, “This could be could be part of a wider system that Apple are working on in order to be able to serve more different devices perhaps expanding their own router system with millimeter wave.”

Apple CEO Tim Cook has said that Apple wants to own all of its core technologies— and that likely includes the modem chips that connect Apple devices to networks like those operated by Verizon and AT&T. But even if that’s not part of Apple’s plans, the company clearly wants to understand these extremely high frequencies well.


Opinion of Venture Beat:

It’s unlikely that Apple will actually use spectrum in the 95GHz to 3,000GHz range for consumer products anytime soon, but the fact that it’s even considering the future of next-generation and next-next-generation wireless right now is quite interesting — a hint that its planning horizon is closer to a decade or two than a year or two ahead of current trends.

Qualcomm president Cristiano Amon announces that 19 manufacturers and 18 carriers will be using Snapdragon X50 modems to roll out 5G devices to customers in 2019.  Image Credit: Jeremy Horwitz/VentureBeat


Apple now has four roads to a 5G iPhone, each challenging

Alan’s comment:

To its credit, Apple is one of very few technology companies to have made no public commitments regarding impending 5G technology.  Perhaps they will wait till all the hype, spin and nonsense fades into the background.

One thought on “Apple asks FCC for “light touch” as it explores 95GHz to 3,000GHz wireless options

  1. Alan Weissberger, thank you ever so for your informative post on Apple’s high frequency wireless communications test plans!

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