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Fifth-generation (5G) cellular technology is still months or years away from major deployment, but that’s not stopping Apple from looking ahead to the next generation — or two — of wireless technology. A just-published letter to the FCC reveals that Apple is already considering potential applications of 95GHz to 3,000GHz wireless technology, urging the agency to leave substantial portions of the ultra-high-frequency radio spectrum unlicensed or shared — all in the name of market innovation.

Until recently, consumer products did not use so-called 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. So starting this year, 5G cellular products 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.

The Apple-FCC letter is focused on even higher-frequency spectrums. 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 offers 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.”

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 interesting — a hint that its planning horizon is closer to a decade or two than a year or two ahead of current trends. Having said that, Apple is one of very few technology companies to have made no public commitments regarding impending 5G technology, in part because of issues with partners in the here and now.

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