VIA ELECTRONIC FILING CTIA Ex Parte.pdf · VIA ELECTRONIC FILING . Ms. Marlene H. Dortch, Secretary...

1400 16th Street, NW · Suite 600 · Washington, DC 20036 · www.ctia.org

March 25, 2020 VIA ELECTRONIC FILING Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Ex Parte Presentation, Unlicensed Use of the 6 GHz Band, ET Docket No. 18-295; Expanding

Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz, GN Docket No. 17-183 Dear Ms. Dortch: On March 23, 2020 and March 24, 2020, CTIA and member company representatives (“participants”) met via telephone conference with Will Adams of the Office of Commissioner Brendan Carr and with representatives of the Commission’s Office of Engineering and Technology and Wireless Telecommunications Bureau to discuss the 6 GHz proceeding. The full list of meeting participants is attached. Participants reiterated that the Commission should take a balanced approach to the 1,200 megahertz of spectrum in the 6 GHz band and urged the Commission to further evaluate the most efficient use of the upper 6 GHz band. In particular, the participants discussed the recent report by Comsearch, as summarized in the attached presentation, examining the point-to-point incumbents in the upper 6 GHz band and demonstrating the availability of spectrum for relocation of those links to the 7/8 GHz band, as well as the 11 GHz and 18 GHz bands,1 illustrating the potential for exclusive, licensed use of the upper 6 GHz band.

CTIA explained that the United States needs to double its licensed mid-band spectrum to keep up with leading nations. Even with the auction of 350 megahertz of mid-band spectrum this year, other leading countries are on track to make available significantly more licensed mid-band spectrum as the U.S., with Japan on track to open up 1,000 megahertz, China with 460 megahertz already today, and

1 See Comsearch, Analysis for 6 GHz Relocation (6525-7125 MHz) (Feb. 11, 2020) (“Comsearch Report”), attached to Letter from CTIA to FCC, ET Docket No. 18-295 (filed Feb. 24, 2020).

2

South Korea planning to make 600 megahertz available by 2022.2 The upper 6 GHz band is thus an important licensed opportunity as other leading nations commit more and more mid-band spectrum for licensed 5G operations.

At the same time, opening the lower portion of the 6 GHz band for unlicensed, with adequate

protections for incumbents, will double the amount of mid-band spectrum available for unlicensed operations today.3 Across the globe, the United States stands alone in its proposal to dedicate 1,200 megahertz of mid-band spectrum for unlicensed operations.

The report by Comsearch shows that relocation of services from the upper 6 GHz band is a

viable plan. It concludes that “large-scale relocation of 6 GHz assignments into 7/8 GHz, to operate along with the approximately 9000 federal assignments, appears feasible,”4 with a projected relocation cost to the new licensees of $2.8 billion—a small fraction of the potential value of the band. The 7/8 GHz band is a strong candidate for shared federal, non-federal fixed point-to-point operations, just as exists today in the 23 GHz band. Further, NTIA has already taken steps to explore the potential for sharing with commercial users.5 The Commission should continue to work with NTIA to study this approach, which would provide for more intensive use of both federal and commercial spectrum.

CTIA encourages the Commission to allow sufficient time to consider licensing the upper

portion of the 6 GHz band for flexible-use services and relocating incumbent Fixed Service operations from that portion of the band to other comparable facilities. Such action would also enable the Commission to study how best to ensure that satellite operations in the band would not be subject to harmful interference and how mobile operations can be relocated as well. Importantly, as CTIA has noted, such action need not delay the introduction of unlicensed operations in the lower 6 GHz band, provided the Commission adopts a robust interference protection regime. 2 See Letter from CTIA to FCC, ET Docket No. 18-295 (filed Mar. 13, 2020). 3 Id. at 2. 4 Comsearch Report at 32. 5 See Guidance on Reviewing Current Frequency Assignments and Quantification of Spectrum Usage, at 2-3, attached to Memorandum To Executive Branch Departments and Agencies From Diane Rinaldo (Aug. 1, 2019), https://www.ntia.doc.gov/files/ntia/publications/guidance_to_agencies_on_current_spectrum_usage_final_08 -01-2019.pdf (stating that affected agencies must complete their review and provide supplementary information for the 7125-8400 MHz band by April 30, 2020); Howard Buskirk, NTIA Studying Sharing in 7.125-8.4 GHz Band, COMMUNICATIONS DAILY (Oct. 2, 2019).

https://www.ntia.doc.gov/files/ntia/publications/guidance_to_agencies_on_current_spectrum_usage_final_08%20-01-2019.pdf

https://www.ntia.doc.gov/files/ntia/publications/guidance_to_agencies_on_current_spectrum_usage_final_08%20-01-2019.pdf

3

Pursuant to Section 1.1206 of the Commission’s rules, this notice is being filed in ECFS and provided to the Commission meeting attendees. Please do not hesitate to contact the undersigned with any questions.

Sincerely, /s/ Scott Bergmann Scott Bergmann Senior Vice President, Regulatory Affairs

Attachment cc: FCC Meeting Attendees

March 23, 2020 Meeting Attendees

FCC Representatives Ron Repasi Dr. Monisha Ghosh Michael Ha Ira Keltz Nick Oros Max Staloff Joel Taubenblatt CTIA Scott Bergmann Kara Graves Jennifer Oberhausen Doug Hyslop Adam Krinsky, Wilkinson Barker Knauer, LLP Mark Settle, Wilkinson Barker Knauer, LLP Comsearch Mark Gibson Joe Marzin Sprint Gardner Foster T-Mobile John Hunter Verizon Tamara Preiss

March 24, 2020 Meeting Attendees Office of Commissioner Brendan Carr Will Adams CTIA Scott Bergmann Kara Graves Jennifer Oberhausen Doug Hyslop Adam Krinsky, Wilkinson Barker Knauer, LLP Comsearch Mark Gibson Joe Marzin Ericsson Jared Carlson Sprint Gardner Foster Verizon Tamara Preiss

Analysis for 6 GHz Relocation

March 2020

Joe Marzin

Director, Technology Group

PRIVATE AND CONFIDENTIAL © 2020 Comsearch, A CommScope Company2

Background Unlicensed Use of the 6 GHz Band, Notice of Proposed Rulemaking,

GN docket No. 18-295, et al., FCC 18-147 (rel. Oct. 24, 2018) (“NPRM”)

Phase 1: Statistics of Current Usage

Phase 2: Relocation Potential

Phase 3: Fixed Service Trends

Phase 4: Estimates of Relocation Costs

Report Breakdown by Phases

Phase 1: Statistics of Current Usage

PRIVATE AND CONFIDENTIAL © 2020 Comsearch, A CommScope Company5 PRIVATE AND CONFIDENTIAL © 2020 Comsearch, A CommScope Company5

Current Usage StatsBand Segment U-NII-5 U-NII-6 U-NII-7 U-NII-8 Total

Fixed Links 26,494 0 14,797 4,591 45,882

Fixed Link Call Signs 29,709 0 16,589 4,693 50,991

Frequency Assignments 71,234 0 30,284 5,243 106,761

Temp. Fixed/Mobile Licenses 0 408 0 356 764

Temp. Fixed/Mobile Freq. Assignments

0 2,293 0 875 3,168

Class U-NII-5 U-NII-7 U-NII-8 Total

Rural 61,119 23,804 3,322 88,245

Suburban 8,884 5,659 1,524 16,067

Urban 1,140 747 365 2,252

Heavy Urban 91 74 32 197

Total 71,234 30,284 5,243 106,761

• Counts are for CONUS including Gulf of Mexico, but excluding Alaska, Hawaii, & U.S. territories

• Largest number of incumbents is in the U-NII-5 (5925-6425 MHz) band segment

• Second largest incumbent band segment is the U-NII-7 (6525-6875 MHz)

• U-NII-6 (6425-6525 MHz) and U-NII-8 (6875-7125 MHz) have lowest number of fixed links but also contain mobile and temporary fixed licenses

• Breakdown by area classification shows a high percentage of rural incumbents

Table 1: Fixed Link and Frequency Assignments by band segment

Table 2: Frequency Assignments by area classification


Top 20 CMA Counts

Table 3: Fixed Link Sites in the Top 20 CMAs

• Microwave sites tallied within the top 20 CMAs by population

• Site is counted if either end or both are within the CMA boundary


Mobile / Temporary Fixed

• Mobile and temporary fixed assignments for BAS, LTTS, & CARS

• Fixed links include Studio-to-Transmitter, Inter-city relay, TV translator relay, and some regular microwave in rural areas

• Mobile assignments include TV pickup for electronic news gathering

• Mobile licenses often licensed as point-radius, statewide, or nationwide corresponding to broadcaster or cable company service area

• There are 190 licenses and 861 frequency assignments nationwide not included in overall tally since their locations are indeterminate

Table 5: Fixed Link Frequency Assignments in the Top 20 CMAs


Path Length Ranges

• The 6 GHz band is the last remaining long path length band where links in excess of 30 km are achievable

• Some shorter paths may be eligible to move to 11 or 18 GHz bands

Figure 3: Link length for all band segments


Fade Margin & Receiver Bandwidth

• Fade Margin is a main component in determining link performance

• Relocating to alternative band typically requires comparable performance

• Radio bandwidth relates to achievable link capacity

• Similar bandwidth in relocated band necessary to achieve comparable capacity

Table 6: Digital Receiver Fade Margin Statistics by Band Segment

Table 7: Receive Bandwidth Distribution by Band Segment


Antennas

• Antenna size relates to achieving longer path lengths or better performance (i.e. larger antennas = higher gain)

• Better antenna performance helps mitigate interference and increase channel re-use

• Larger antennas equate to higher cost to purchase and lease tower space

• Space diversity antenna is a second receive antenna used to improve path performance

• Additional costs involved for relocating links with space diversity

Figure 6: Antenna Size and Performance Breakdown

Table 8: Sites with Space Diversity Antennas

Phase 2: Potential for Relocating 6 GHz Links


Band Options for Relocation

Federal 7 / 8 GHz Bands:

• 7 GHz Band: 7125-7750 MHz (625 MHz total)

• 8 GHz Band: 7750-8500 MHz (750 MHz total)

• Combined total 1375 MHz compared to 1200

MHz 6 GHz total (5925-7125 MHz)

11 GHz Band:

• 10700-11700 MHz (1000 MHz total)

18 GHz Band:

• 17740-18140 MHz & 19300-19700 MHz (800 MHz total)


Federal 7 GHz Band Plan: 7125-7750 MHz

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 MHz (E) 1 2 3 4 5 6 7 8 9 10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

30 MHz Plan Paired / First Priority Unpaired / Optional Pairing / First Priority Paired / First Priority

FIXED

fixed

SPACE RESEARCH ↑

FIXED-SATELLITE ↓

MOBILE-SATELLITE ↓

mobile-satellite ↓

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 GHz (E)11'

12'

13'

14'

15'

16'

17'

18'

19'

20'

21'

22'

23'

24'

25'

26'

27'

28'

29'

30'

31'

32'

33'

34'

35'

36'

37'

38'

39'

40'

41'

42'

43'

44'

45'

46'

47'

48'

49'

50'

51'

52'

53'

54'

55'

56'

57'

58'

59'

60'

61'

62'

63'

64'

65'

66'

67'

68'

69'

70'

71'

72'

73'

74'

75'

76'

77'

78'

79'

80'

81'

82'

30 MHz Plan Paired / First Priority Unpaired / Optional Pairing / First Priority Paired / First Priority

FIXED

FIXED-SATELLITE ↓

mobile-satellite ↓

METEOROLOGICAL-SATELLITE ↓

74

50

75

10

76

30

77

50

72

10

74

50

73

30

A2 A3 A4 A5 A6

C14 C15 C16 C17 C18

A7 A8 A9 A10

B10B8 B9

C13

B5 B6

C5 C6 C7 C8 C9 C10

B7

7 GHz Channel Plan (Low)

A1

D11 D12 D13 D14 D15D7 D8 D9 D10 D16 D17

C1 C2 C3 C4

71

50

B1 B2 B3

C11 C12

B4

A6' A7' A8' A9' A10'

D1 D2 D3 D4 D5 D6

A1' A2' A3' A4'

C28 C29 C30

B15

C19 C20 C21 C22 C23 C24 C25 C16 C27

7 GHz Channel Plan (High)

B11 B12 B13 B14

A5'

B13' B14' B15'

C1' C2' C3' C4' C5'

B5' B6' B7' B8' B9' B10'B1' B2' B3' B4'

C14' C15' C16' C17'C6' C7' C8'

B11' B12'

D18' D19' D20' D21' D22'D6' D7' D8' D9'

C30'C29'C9' C10' C11'

D26' D27' D28' D29' D30' D31'

C24' C25' C26' C27' C28'C18' C19' C20' C21" C22' C23'C12' C13'

D23' D24' D25' D38' D39' D40' D41'D32' D33' D34' D35' D36' D37'D16' D17'D10' D11' D12' D13' D14' D15'

Figure 8: NTIA 7 GHz Channel Plan


Federal 8 GHz Band Plan: 7750-8500 MHz

Figure 9: NTIA 8 GHz Channel Plan


Federal 7 / 8 GHz Bands

• Government data showed about 8300 fixed

assignments and about 10,000 total

assignments in the late 1990s and predicted

flat growth

• Described as “the Federal Government’s

traditional point-to-point microwave band”,

the 7/8 GHz bands included about 4000 fixed

assignments for the FAA, 2200 for the military

branches and coast guard, 1300 for DOE and

TVA, and 400 for DOJ

• Additional federal allocations in the 7/8 GHz

spectrum are for satellite services (fixed,

mobile, meteorological, and earth-exploration),

and space research See 47 C.F.R. §2.106

• Based on comparison of the spectrum and

channels available, large-scale relocation of 6

GHz assignments into 7/8 GHz, to operate

along with the approximately 9000 federal

assignments, appears feasible, but more study

is needed


Other Challenges

• Frequency coordination between federal and commercial users

• Accommodation of mobile / temporary fixed uses

• Wideband channels

• Antenna performance requirements

• Minimum payload requirements

• Regulatory processes required to open the bands for shared commercial use


11 and 18 GHz Bands

• Path lengths that may be used in these bands are limited by rain-based fading

• For high availability, these bands will not accommodate the longer 6 GHz links but may handle short links if the path length, rain region, and link budget allow

• About 19.5% of the existing assignments in the U-NII-5 band and about 20.6% of existing assignments in the U-NII-7 band are on links below the 11 GHz average rain fade distance of 15.1 km

• About 0.6% of the existing assignments in the U-NII-5 band and about 2.0% of existing assignments in the U-NII-7 band are on links below the 18 GHz average rain fade distance of 4.8 km

Table 11: Typical 32 QAM/100 Mb/s Link Distance at 99.999% Availability. Antenna diameter 4’ at 11 GHz, 2’ at 18 GHz

Phase 3: Trends in the 6 GHz fixed service bands


Trends 2015-2019

Figure 10: Number of paths by band 2015-2019

• Path counts are from Comsearch database on December 31, 2015 and the end of each subsequent year up to 2019

• Counts are for CONUS plus Gulf of Mexico

• 11 and 18 GHz bands included to help inform how they can help the relocation of shorter links

• Significant YOY growth in 11 GHz, strong growth in U-NII-5 band, modest growth in 18 GHz

• Static to no growth in U-NII-7 & U-NII-8 bands

Table 12: Number of paths by band 2015-2019

Table 13: Percentage change in number of paths year-over-year


Average Frequencies Per Path& Channel Bandwidth

• Tabulation of average number of frequencies per path is useful to see trends in deploying additional frequencies on a path that can increase capacity payload

• This trend could inform the need for multiple frequency assignments in a relocation band

• The average channel bandwidth trend can inform on whether wider bandwidth channel options are needed for the relocation band

• All bands show an increase in number of frequencies per path and channel bandwidth over the time period with the exception of U-NII-8

Table 16: Average number of frequencies per path 2015-2019

Table 17: Average channel bandwidth 2015-2019


Growth by Market

Figure 21: Site Counts for U-NII-5, U-NII-7, & U-NII-8 combined (2015 – 2019)

• Identifies site counts and growth by each of the top 20 CMA markets

• Los Angeles and Dallas have the highest counts and may need larger efforts or longer time frames for relocation

Phase 4: Estimated Costs for Relocation


Model for Estimate of Relocation Costs

Table 18: 6 GHz fixed microwave link counts based on path length

Relocation into various bands based on path length

• >15 km into federal 7 / 8 GHz band

• 5-15 km into 11 GHz band

• Up to 5 km into 18 GHz band

Up to 2% of links assumed will be decommissioned

• Costs may still be incurred with decommissioned links


Relocation Process

Spectrum Sharing Studies / Interference Analysis

• Identify most critical links and potential impact by new service

• Prioritize links or systems for relocation

Site Audits and RF Measurements

• In-field verification that incumbent link is operational

• Validate specific link configuration to assess costs

Estimate Comparable Relocation Costs

• Link design review to baseline incumbent links and evaluate against relocation design for comparable replacement

• Determine most economical relocation / replacement option

Negotiation and Contract Execution

• Negotiate terms and conditions for either a turnkey relocation or cash settlement option

• Execute signed agreement and manage incumbent’s progress to meet relocation commitments


Estimated Costs

• Cost of $148,291 per link is based

on prior equipment and install

costs for relocation to federal 7/8,

11, and 18 GHz bands

• While radio costs vary by

configuration, power options, etc.,

our model assumes the variances

average toward this per link cost

over the scope of very many links

Table 19: Relocation cost estimates for links in U-NII 7 & U-NII 8 (6.7 & 7 GHz bands)

Table 20: Relocation cost estimates for links in U-NII 7

Table 21: Relocation cost estimates for links in U-NII 8


Sample Relocation Quote

Table 24: Estimated cost for turnkey microwave link relocation


Conclusions

Relocation appears feasible subject to opening up of federal 7 / 8 GHz band for commercial use

Relocation cost estimate for fixed links in only U-NII-7 & U-NII-8 is $2.82 Billion

Costs and method for relocation of mobile / temporary fixed services requires further analysis

Thank you!

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