The Holy Grail: FemtoCells At Home integrated into the Home Gateway

ModeratorBarlow Keener

Keener Law Group

Email: bk@keenerlawgroup.comTel: 617-671-1202

The Holy Grail: FemtoCells At Home integrated into the Home Gateway :

Panellist Company Position

Barlow Keener Keener Law Group Regulatory Attorney

Richard Brennan HuaweiETSI TISPAN Vice-Chair, and TISPAN WG-2 Chair

Dr. Majid FoodeeiTranswitch Corporation (Centillium)

Dir. Strategic/Technical Marketing

Femtocell: Regulatory Framework

FCC – Staffers taking notice but no rulemaking or decisions

1st Mention of “femtocell” by FCC: Feb 2008 “2007 Annual Report of Competitive Market Conditions for

Commercial Mobile Services” Discussion of Sprint’s Airave product Prior mention of picocells for trials in airplanes

FCC Definition VoIP: Does it apply to Femtocell Use?“Interconnected VoIP services” are services that (1) enable real-time, two-way voice communications; (2) require a broadband connection from the user’s location; (3) require IP-compatible customer premises equipment; and (4) permit users to receive calls from and terminate calls to the public

switched telephone network.

Femtocell looks like VoIP but CRMS providers are fully regulated

Femtocell Interference: Traveling Towers

Femtocell interference

If the Femtocell is moved into another licensed area, it will cause interference if not “turned off”

Femtocells create holes in the macro tower coverage Licensed areas are exclusive to the licensed carrier

Nomadic femtocells are the responsibility of the customer’s carrier

Customers, not carriers, control the location of the femtocell

Rogue or nomadic femtocells cells Femtocell technology provides the opportunity for rogue devices Picocells, for example, are used on cruise ships

A ”traveling licensed area” – along with the traveling picocell No regulatory limitations on femtocell devices

Location of towers controlled where customers use the service Femtocells without location controls can be used anywhere

Interference with rogue femtocells in licensed spectrum

Femtocell: Bubbling Regulatory Reaction

FCC – Staffers taking notice but no rulemaking or decisions “Unauthorized” Booster FCC is working on

CTIA 2007 Booster Complaint: Sudden new action FCC Comments due Feb 22

Rogue Femtocell interfering with cellco “licensed” spectrum FCC enforcement in the home? Warrants required. Not likely… There will be a plethora of femtocell devices – not like a rogue radio

station

“Interference” 47 Sec 333: “No person shall willfully or maliciously interfere with or cause interference to any radio communications … licensed…”

“Interference” No real definition. A condition where a receiver cannot interpret a signal directed at

it.  FCC Rules Part 15: (1989) low power devices operate without exclusive

license. Must take any interference that to device way without complaint Must shut down when interfering with protected license.  Low power in a wide variety of frequency ranges. 2.4GHz (“WiFi”) 900MHz 1910 to 1930Mhz sandwiching GSM

spectrum

Femtocells - 911 Issues

More than 140,000 911 calls made each day from wireless phones FCC: Any phone near a carrier tower must have 911 access

Applies to femtocells but femtocells are under roofs , move, and not regulated

Applies to all phones that can use the spectrum – not just customers If femtocell powered up out of the “approved” location or licensed territory

area, should 911 calls be required to be made? Yes.

FCC 911 Antenna location regulation Phase I FCC's Order (94-102) require that carriers to deliver location of

cell site Phase II mandates that carriers must pinpoint a customer's actual

location 2007 FCC 911 NPRM – proposed the idea of a hybrid location requirement

FCC 911 Mandate for carriers to provide 911 even with weak signals – This will mean 911 from all femtocells but location is the problem

Automatic A/B Roaming-Intelligent Retry (with some modifications), Adequate/Strongest Signal, and Selective Retry.

Femtocell Interference: Traveling Towers

Femtocell interference

If the Femtocell is moved into another licensed area, it will cause interference if not “turned off”

Femtocells create holes in the macro tower coverage Licensed areas are exclusive to the licensed carrier

Nomadic femtocells are the responsibility of the customer’s carrier

Customers, not carriers, control the location of the femtocell

Rogue or nomadic femtocells cells Femtocell technology provides the opportunity for rogue devices Picocells, for example, are used on cruise ships

A ”traveling licensed area” – along with the traveling picocell No regulatory limitations on femtocell devices

Location of towers controlled where customers use the service Femtocells without location controls can be used anywhere

Interference with rogue femtocells in licensed spectrum

Interference

MagicJack

FemtoJack

Femtocells: Roaming charge issues

There are 90 small facilities-based cellco’s in the US Femtocells can be created without GPS or user restrictions Customers can move their femtocell to other carrier

sprectrum U.S. customer could be charged by a foreign carrier where

US customer locks on to foreign Femtocell – Mexico example

Roaming Issues are created Carrier A customer moves femtocell to Carrier B’s territory Femtocell is used by customers of Carrier B new territory Call through femtocell shows up as delivered by Carrier A Carrier A bills for roaming charges for call originated

Carrier B’s territory Difficult to monitor and detect

Parasitic Use Problems

Carriers will be transmitting calls through unknown internet VoIP carriers like Vonage have regularly been called “parasitic” The voice call is carried on unrelated 3rd party’s service New opportunities for listening and interfering with calls

“Snooping” User will not know they are on a femtocell Imagine suddenly: your cell phone calls are being routed to

China hackers

Network Neutrality Blocking: Internet providers have blocked VoIP, P2P

Sniffing Deep Packet Inspection: Allows ISPs to see/listen to all traffic

IPSec tunnel provides limited security

The “Big 4” Provider: Business Case

#1 Purpose: Femtocell used to solve iPhone data network problem

#2 Purpose: Help those with poor in-house coverage

#3 The Home Gateway – silence – but this is where the revenue is

The New Cellphone Providers

Homegateway Femtocell is the Business Case Comcast Clearwire & Sprint TimeWarner Cox WiMax