Transcript LMDS: A WASHINGTON PERSPECTIVE

Spectrum Management 2008
Industry Association Roundtable
Paul J. Sinderbrand
Wilkinson Barker Knauer, LLP
202.783.4141
[email protected]
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• Membership – Wireless Broadband
System Operators, Application
Providers and Manufacturers
• Objective – promote legislative and
regulatory environment that facilities a
competitive marketplace for wireless
broadband services
• Philosophies
• Technological neutrality
• Parity among like services, tempered
by appreciation of differences
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• Primary Recent Spectrum Focus
• 700 MHz
• Future of D Block and Private/Public Safety
Partnership
• Comments - June 20; Reply comments - July 7.
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•
•
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WCS (2.3 GHz)
AWS-3 (2155-2175 MHz)
BRS/EBS (2.5 GHz)
LMDS and 39 GHz
• 4/11/2008 WTB Order extends deadline for LMDS substantial
service to 6/1/2012 for those who requested
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WCS/SDARS
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WCS-DARS Coexistence
• 2305-2320/2345-2360 MHz Is Poised To Become
A Home To WiMAX Mobile Services, but . . .
• DARS Terrestrial Repeater Technical Limits Must
Be Adopted To Protect WCS From Interference.
• WCS OOBE Limits Are More Restrictive Than
Necessary To Protect DARS And Must Be
Loosened.
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WCS/SDARS NPRM
• 12/18/07 NPRM solicits comment on proposals
by WCS Coalition and by XM and Sirius for rules
to govern WCS and SDARS repeaters.
• OOBE restrictions on mobile WCS
• Power levels for SDARS repeaters
• Power levels for WCS base stations and mobiles
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WCS OOBE Limits
• OOBE limits between 2320 MHz and 2345 MHz
were adopted in 1997 before WCS or DARS
technologies were settled:
• Fixed stations: 80 + 10 log (p) dB
• Mobile stations: 110 + 10 log (p) dB
• Restrictions effectively preclude use of C and D
Blocks for mobile and impose undue economic
costs on A and B Blocks.
• Testing demonstrates that, under real world
conditions, current limits are not necessary to
protect DARS.
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WCS Power Limits
• DARS proposed to reduce maximum current handheld
power levels from 250 milliwatt EIRP limit imposed by RF
exposure rule to 10 milliwatts/1 milliwatt
• Adoption of proposal would preclude viable mobile
wireless broadband service
• Testing has shown that DARS receivers can operate with
muting even when faced with WCS handhelds operating
at currently-authorized levels.
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DARS Terrestrial Repeaters
• Ten years after DARS first authorized to use “gap fillers,”
FNPRM is still pending on technical rules.
• Evidence is clear that high-powered DARS repeaters can
result in blanketing interference to WCS.
• In 2001, FCC granted XM and Sirius STAs allowing
terrestrial operations (40,000 Watts EIRP in some cases),
subject to obligation to cure interference to WCS.
• DARS now insists on grandfathering all existing repeaters,
without protection obligation.
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2.5 GHz Restructuring
FORMER PLAN
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2.5 GHz Bandplan Transition
• Timeline
• January 20, 2009 – Deadline for submitting Initiation Plans
• January 21, 2009 – 90 day window opens for licensees to notify
FCC and affected licensees of intent to self-transition
• April 20, 2009 – Deadline for licensees to notify FCC and affected
licensees of intent to self-transition.
• October 21, 2010 -- All transitions should be complete (except in
cases of disputes that toll the completion deadline)
• Transition to new bandplan is proceeding quickly
• 402 of 493 Initiation Plans filed
• 253 Post-Transition Notifications filed
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Flexibility/Protection
• Cochannel Interference
• Limiting signal strength at service area boundary to 47
dBµV/m does not protect base station from interference by
non-synchronized cochannel base station.
• Height benchmarking provides additional protection against
base-to-base interference.
• If height of antenna above average terrain along the radial
between stations exceeds D²/17, station is outside of height
benchmark (where D is distance to GSA boundary)
• Base station exceeding benchmark must restrict received
signal level to -107 dBm or less at base station that is
within benchmark
• Adjacent Channel Interference
• 43+10log(p) mask generally applies to base stations
• If OOBE interference is caused, must meet 67+10log(p)
measured 3 MHz from block edge.
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3/20/08 Third R&O and FNPRM in
WT Docket No. 03-66
• On recon, FCC establishes deadlines for response to
documented interference:
• Require compliance with the more restrictive mask/height
benchmarking within 24 hours where a new or modified
base station interferes with an existing base station;
• Allows operator of existing base station 60 days to comply
with more restrictive mask when OOBE interference is
caused to a new base station;
• Allows operator of existing base station 90 days to comply
with height benchmarking when cochannel interference
results at a new base station;
• FCC confirms that in other cases of documented
interference, both licensees have an obligation to
cooperate in good faith to reasonably mitigate the
interference.
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3/20/08 Third R&O and FNPRM in
WT Docket No. 03-66
• 75+ forfeited BRS BTA licenses to be
reauctioned using typical rules.
• Late 2008 or early 2009
• FNPRM seeks comment on licensing EBS white
space
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•
•
•
•
Can auction be avoided?
BTAs or something else?
How much spectrum?
Priority for local and/or accredited institutions?
Upfront payments? Bidding credits?
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BRS Relocation From 2150-2162 MHz
• Ninth Report and Order in ET Docket No. 00-258 Fails
To Protect Incumbents – WCA petition for
reconsideration pending
• Since AWS has 15 years to relocate BRS, FCC
must permit BRS to secure replacement for
throughput increased during interim.
• BRS incumbents should be permitted to “selfrelocate” just as point-to-point microwave can.
• Internal costs must be recoverable.
• Incumbent should get pre-payment to avoid
having to fund its own involuntary relocation.
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BRS Relocation From 2150-2162 MHz
• Adjacent channel interference must be
cured by AWS, but only after the fact –
jeopardizing existing operations! FCC
should require prior coordination by AWS
with BRS under Section 101.103(d) notice
and response system, just as AWS must
do with point-to-point microwave
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4/10/08 Globalstar ATC R&O
• Allows ATC in 2483.5-2495 MHz band
• Rejects ATC at 2495-2500 MHz; thus keeps ATC out
of new BRS channel 1 at 2496-2502 MHz
• Retains requirement that Globalstar cure any
interference that ATC causes and imposes BRS 24
hour/60 day deadlines
• Acknowledges that Globalstar may be effectively
limited to below 2493 MHz
• Punts concerns on use of TDD, Open Range
relationship and gating tests
• Globalstar filed application last Friday to modify ATC
authority
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THANK YOU!
Paul J. Sinderbrand
Wilkinson Barker Knauer, LLP
202.783.4141
[email protected]
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