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TRANSCRIPT
Wireless Without Limits Steve Coran
Lerman Senter PLLC [email protected]
February 2017
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The Citizens Broadband Radio Service The WISP Opportunity
This presentation is not intended to create an attorney-client relationship. The information contained in this presentation is general and is not offered as legal advice. You are strongly encouraged to consult with an
attorney if you have specific questions. Any reliance on the information in this
presentation is taken at your own risk.
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Disclaimer
100 megahertz of “new” spectrum adjacent to “known” band
Ability for existing 3650-3700 MHz licensees to register new locations
Glide path to new spectrum is driving LTE development, and LTE development is driving network expansions
Spectrum sharing paradigm sets the stage for similar approaches in other bands
Potential for subsidized deployment through upcoming Connect America Fund reverse auction
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WHY SHOULD I CARE?
Mobile wireless interests that want spectrum for “small cells” Utilities that want additional spectrum for mission critical
communications, but do not want disruption to 3650-3700 MHz band
WISPs that want additional spectrum for fixed broadband, but do not want disruption to 3650-3700 MHz band
Satellite interests that want to ensure interference protection to earth stations
Government interests that want to ensure that military uses are protected from harmful interference
New entrants and public interest advocates that champion unlicensed spectrum
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Stakeholders
On April 17, 2015, the FCC adopted new rules, which became effective July 23, 2015 (mostly…) • Creates 100 megahertz in the 3550-3650 MHz band for shared
commercial use with military and earth station incumbents • Enables continued use of existing operations in 3650-3700
MHz band with limited opportunity for system expansion • Equipment to be operable across entire 150 megahertz, with an
important exception • Delegates many technical decisions to multi-stakeholder group • Invited further comment on other issues
Additional rules adopted May 2, 2016 were effective August 25, 2016
BAND IS NOT AVAILABLE FOR COMMERCIAL USE YET!
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FCC Decisions
Linchpin of rules is a three-tiered database-controlled Spectrum Access System (SAS) • Incumbent Access
o Navy radar systems along coastlines and ground-based military radar to be protected by Environmental Sensing Capability (ESC)
o Licensed fixed satellite earth stations to be protected geographically • Priority Access – licensed use, but protects incumbents
o Licenses to be awarded by competitive bidding • General Authorized Access (GAA) – “license by rule” for
designated and opportunistic use o Not unlicensed o But like unlicensed, no explicit grant of license required; just
operate per SAS instructions o SAS required to “facilitate coordination” among GAA users
as well as protect Incumbent and Priority Access users
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Spectrum Management
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Band Plan
3550-3650 MHz 3650-3700 MHz
Incumbent Access – Military and FSS Earth Stations Coastal Areas, Military Bases, Fixed Earth Station Sites PAL Limit = up to 70 MHz
No PALs
GAA = 30 MHz or more GAA = 50 MHz
Priority Access Licenses (PALs) • Assigned by census tracts through competitive bidding • 10-MHz channels assigned dynamically • 40-MHz cap for any one PAL holder in a census tract • Three-year license term with no renewal right
o Can acquire two three-year licenses in first application window • No build-out requirements • “Use it or share it” obligations • Will be available in Rural Areas if only one
applicant files an auction application
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Licensing
General Authorized Access • Available in every census tract and assigned where there are
no PALs o At least 80 megahertz (≥30 MHz in 3550-3650 MHz, 50
MHz in 3650-3700 MHz) • Assigned opportunistically where and when PALs are not
“in use” o Where – anywhere within default contour protection of
-96 dBm/10 MHz around each PAL CBSD as determined by SAS
o When – PAL CBSD discontinues service for more than seven days
• Must defer to Incumbent and PAL use under the control of SAS
• SAS may or may not identify and resolve interference among GAA users
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Licensing
Secondary Markets • “Light-touch” leasing for eligible parties
o Certification of compliance with basic licensee qualifications
o Notification to SAS of leasing arrangement o SAS must be able to confirm eligibility and
compliance with 40 MHz cap o SAS to provide daily reports to the FCC o FCC will report on weekly Public Notice
• Partitioning and disaggregation not permitted
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Licensing
Citizens Broadband Service Devices (CBSDs) • Must be capable of reporting information to the SAS • Must be capable of two-way transmissions on any
frequency from 3550-3700 MHz as instructed by SAS, but not required to operate in two-way mode
• Part 90 equipment in 3650-3700 MHz is permanently exempt from requirement to operate across entire 150 MHz, but will otherwise need to comply with CBSD rules and SAS registration after transition period
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Spectrum Use
Categories of CBSDs • Category A (small cells)
o Lower power o Need only report EIRP to SAS
• Category B o Higher EIRP o Outdoor only with professional installation
required o More detailed information reported to SAS o Permissible only when Environmental Sensing
Capability (ESC) system has been deployed near the military radar facilities
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Spectrum Use
End User Devices • Operate under power control of CBSD • Not required to communicate directly to SAS, but must
be able to receive and decode instructions from CBSD such as frequencies and power limits
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Spectrum Use
CBSD Category
Maximum EIRP
(dBm/10 MHz)
CBSD Installations
Operations in 3550-3650 MHz
Operations in 3650-3700 MHz
End User Device
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Category A 30 - Indoor - Outdoor max 6m HAAT
Everywhere Outside DoD Protection Zone
Everywhere Outside FSS and DoD Protection Zone
Category B 47 - Outdoor only - Professional Installation
Outside DoD Protection Zone & requires ESC
approval
Everywhere Outside FSS and DoD Protection Zone
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Uses and Restrictions
Interference protection within PAL protection area • Aggregate received level of -80 dBm/10 MHz signal
threshold with antenna at 1.5 meters AGL • May agree to different parameters and report to SAS
Phased approach to protect Federal incumbents • Phase I – limited to low power operations with maximum
EIRP of 30 dBm subject to SAS outside of designated coastal zones and ground-based radar facilities o Coastal zones 77% smaller than stated in initial NTIA
report • Phase II – allows higher power operations subject to SAS
and ESC, which is likely to be infrastructure-based
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Interference Protection
Earth station interference protection SAS to provide protection
• Earth station licensees must annually register with the FCC to report information and technical changes
• CBSDs can operate within areas predicted to cause interference by agreement
• SAS to be capable of receiving and responding to interference complaints from FSS licensees
• Protection areas will be customized based on registration information provided to SAS o SAS to consider all CBSDs within 150 km of earth
station when calculating protection distances o 40 km distance for adjacent emission and blocking
interference calculations
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Interference Protection
Existing uses can continue Five-year transition period to CBRS rules No PALs – band is incumbent and GAA use only Maximum Part 96 power level in rural areas will
be higher than existing Part 90 limit Existing equipment is exempt from band-wide
operability rule Existing equipment can become CBSD network
through proxy controller device No new, non-exclusive nationwide licenses
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3650-3700 MHz Rules – Overview
Freeze on filing for new nationwide licenses • FCC does not want to issue new licenses during transition
period • Leasing specifically prohibited for 3650-3700 MHz Service
licenses • What to do?
o Acquire existing license in secondary market? o Management agreement? o Waiver of freeze?
Post-transition • Users will be GAA, but no PALs in band
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3650-3700 MHz Rules – Overview
Five-year transition period until April 17, 2020
Registration for fixed/base stations must have been on file with FCC by April 17, 2015 in order to be eligible for interference protection from new GAA users
• Licensees can file registrations after that date, but registrations will not get grandfathered protection
• If license expires before then, can get short-term renewal to April 17, 2020
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3650-3700 MHz Transition Rules
Grandfathered licensees will receive interference protection from GAA users within a Protection Zone so long as network operations were “in use” by April 16, 2016 • “In use” – must be registered with ULS, constructed,
serving unaffiliated paying customers and in compliance with FCC rules
• Must register frequencies and “service contours” with SAS
• Part 90 cooperation rules continue to apply • Registrations approved after April 17, 2015 are not
entitled to interference protection • Treated as incumbent users during transition period
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3650-3700 MHz Grandfathering
On October 23, 2015, FCC adopted Public Notice inviting comment on how to define and implement “protected contours” for Grandfathered Wireless Protection Zones WISPA, Google and WinnForum negotiated over
several weeks to develop proposal designed to balance protection of incumbents with future uses Decision released August 19, 2016
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Protected Contours Methodology
Two-Prong Sector-Based Approach • For sectors encompassing registered CPE, protection centered on
each base station with the registered azimuth and beam width covering all registered subscriber locations in the sector (normally not more than 18 km)
• For sectors encompassing unregistered CPE, a 5.3 km radius sector from each registered base station based on the registered azimuth and beam width registered for that location
Protection for frequencies registered in ULS Protection at all locations within the Grandfathered
Wireless Protection Zone Protection level of -80 dBm/10 MHz within Zone
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Protected Contours Methodology
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Protected Contours Methodology
Implementation • Licensees will certify which of their base stations were
registered on or before April 17, 2015 and constructed, providing service to unaffiliated customers and in full compliance with FCC rules as of April 17, 2016 o Certification to identify whether base station has unregistered
CPE and the distance to the furthest CPE for the sector o Certification only for base stations, not CPE (except distance)
• FCC in process of modernizing ULS to collect relevant data o FCC will communicate with licensees the filing process and
deadline • One-time event
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Protected Contours Methodology
FCC delegated technical issues to multi-stakeholder group(s) • SAS issues • Inter-SAS communications, security, interference protection,
CBSD-to-SAS communications • ESC development • Professional Installation – training and certification
Wireless Innovation Forum is leading effort, has formed four Work Groups: • Operations and Functional Requirements • Security Requirements • Protocol Specifications • Testing and Certification
WISPA and some manufacturers are active participants in WinnForum
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Multi-Stakeholder Group
Eight parties filed to be certified as SAS and/or ESC administrators during “first wave” that ended May 16, 2016 • Amdocs (SAS only) • Comsearch • CTIA • Federated Wireless • Google • iPosi (ESC only) • Keybridge • Sony (SAS only)
On December 21, 2016, seven conditionally approved to be SAS administrators
• Must submit systems for compliance testing before final approval, which may include public testing period and field trials
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SAS and ESC Applications
Continuing SAS and ESC development in WinnForum SAS approval and certification by FCC Auction rules and procedures Experimental deployments Public Notice on “Protected Contours”
implementation Earth Station registration process
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Still to come . . .