the citizens broadband radio service the wisp opportunity ... · february 2017 . page 1 the...

Wireless Without Limits Steve Coran

Lerman Senter PLLC [email protected]

February 2017

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.

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

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

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!

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

Spectrum Management

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

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

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

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

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

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

Spectrum Use

CBSD Category

Maximum EIRP

(dBm/10 MHz)

CBSD Installations

Operations in 3550-3650 MHz

Operations in 3650-3700 MHz

End User Device

23

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

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

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

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

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

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

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

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

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


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


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

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

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

Still to come . . .

Thank you!

Steve Coran

Lerman Senter PLLC 202.416.6744

[email protected]

the citizens broadband radio service the wisp opportunity ... · february 2017 . page 1 the...

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