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July 2011
Vol 11 Issue 1
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Part 101 Fixed Microwave Proceeding Update
In our last newsletter we outlined the FCC proceeding in WT Docket No. 10–153 proposing to amend Part 101 of the Commission's rules dealing with the use of microwave. Approximately 38 comments and 28 reply comments were filed in the proceeding and a brief summary is provided below.
Click here to go to the FCC comments search page. Enter proceeding 10–153 to view all comments.
Permitting "Auxiliary" Fixed Stations
The proposal to permit auxiliary stations was met with broad industry opposition. Included in the list of those opposing the concept were major carriers such as AT&T, Verizon and T-Mobile, rural telephone companies, and major trade groups and industry organizations including the Telecommunications Industry Association, the Rural Telecommunications Group, the National Spectrum Management Association, the Fixed Wireless Communications Coalition, and the Satellite Industry Association. In contrast, supporters were few in number and primarily represented start up companies and the wireless internet service provider community desiring to use the Part 101 licensed spectrum for "carrier grade" subscriber access.
The primary arguments against auxiliary stations:
- Increase interference potential from the influx of secondary transmitters.
- Creates a perverse incentive to be less efficient and create more interference potential from primary links in order to maximize the auxiliary station service area.
- Auxiliary station users would attempt to create geographic service areas, reducing spectrum availability for others.
- Promotes the introduction of TDD into traditionally FDD bands increasing the complexity of the interference environment.
- Better suited for unlicensed bands or licensed area wide spectrum such as 24, 28 and 38 GHz.
- Claims made by proponents about "smart antenna" technology are flawed and unproven.
- Increases the costs of coordination for new entrants and the costs to incumbent licensees who must analyze multiple sites.
and CARS Frequencies
The idea of opening up the Cable TV Relay Service (CARS) and Broadcast Auxiliary Service (BAS) 7 and 13 GHz bands to fixed service (FS) use received a mixed response.
The broadcast community was generally opposed to the idea while commercial carriers and OEM's were generally in favor. A number of commenters pointed out that while sharing is generally a desirable goal, the one-way nature of present BAS and CARS usage and the requirement for itinerant use of the spectrum to support electronic newsgathering poses unique coordination and interference issues. In addition, the discrepancy between the 25 MHz channels used in the BAS and the 10 and 30 MHz channels typically found in the Fixed Service would result in additional coordination problems and would have to be addressed.
Permitting Adaptive Modulation
A majority of the filing parties favored the implementation of Adaptive modulation, also called adaptive coding and modulation (ACM) in some form. ACM allows a radio system to change modulation and thus system gain in response to propagation conditions and fading. While there was general agreement about the benefits associated with ACM, there was some debate about the requirement for additional restrictions or limitations to ensure that the radios did not operate below the minimum payload capacity rule for extended periods of time. Several parties suggested that meeting a certain path design criteria in the coordination process such as 99.999% may help in minimizing the potential for abuse or inefficiency.
Modification of Efficiency Standards in Rural Areas
Differing viewpoints were expressed on this issue. While some comments favored no relaxation of the efficiency standards, others extolled the benefits that relaxation would provide including driving the rollout of broadband. This is one of those tricky costs versus efficiency tradeoffs where the devil is in the details and the correct answer depends upon your particular point of view. For example, just trying to define what area is considered rural when talking about microwave is a difficult proposition. Some sites in sparsely populated areas are extremely congested.
Review of Part 101 Antenna Standards to Allow Smaller Antennas
As mentioned in our last newsletter, this is another tradeoff of size and cost versus spectrum efficiency. Several commenters supported a relaxation of the existing standards to allow for smaller antennas but provided no specifics. Others said that any modification of the standards was premature and would require a thorough evaluation before proceeding. Still others suggested that the FCC consider relaxing the standards to allow for specific antenna sizes such as a 4 foot diameter at 6 GHz, 1 foot at 18GHz, and sub-1foot at 23 GHz.
Other Comments
- FCC should act on two pending petitions for rulemaking filed by the FWCC: (1) RM-11605, in which the FWCC requests the FCC to amend its rules to allow non-Federal fixed microwave systems to share the Federal 7,125 and 8,500 MHz band; and (2) RM-11610, in which the FWCC seeks to improve Federal/Non-Federal coordination in the 23 GHz band.
- Instead of coordinating on a full arc, full band basis, limit the number of frequencies that a 6 GHz fixed satellite earth station can have based upon a demonstration of "actual need".
- Reallocate the underused 27.5–28.35 GHz LMDS band for fixed point-to-point usage.
- Add 10 MHz channels in the 10.55–10.68 GHz band.
- Increase power levels in the MVDDS 12.2–12.7 GHz DBS band to provide backhaul point-to-point service.
- Encourage the voluntary licensing of all fixed ENG-RO sites, regardless of band.
- Encourage use of the 2.3 GHz WCS band for wireless backhaul operation.
- Promulgate rules that govern the relationship between antenna power and distance for bands above 15 GHz.
Since the November 22, 2010 deadline for reply comments, a number of Ex Parte presentations and comments have been submitted to the FCC. Several of these deal with the NPRM proposal to authorize auxiliary stations. Comsearch met with the FCC on March 11, 2011 and presented information on subjects at issue in the proceeding. In particular our presentation discussed our opposition to the auxiliary stations proposal.
On April 14, 2011, Comsearch also filed recommendations for rules and pattern requirements to allow smaller antennas in the 6, 18, and 23 GHz bands.
In a Public Notice dated June 7, 2011, the FCC requested additional comment on fixed service sharing of the 7 and 13 GHz bands with BAS and CARS. The FCC asked for information on whether geographic limitations on FS operations or maintaining portions of the bands for exclusive BAS and CARS usage could provide a framework for sharing. The FCC also requested comment on the necessary coordination procedures and appropriate channelization plans. Comments were submitted by 8 interested parties at the June 27 deadline.
Stay tuned. We will continue to update you as new developments transpire.
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800 MHz—FCC seeks comment on petition from Sprint Nextel to allow wideband operations in 800 MHz enhanced specialized mobile radio service bands. (DA No 11-1152, Dkt No 11-110) DA-11-1152A1.pdf
2150–2162 & 2500–2690 MHz Bands—Proposed regulatory changes described in the Fourth Further Notice of Proposed Rulemaking. Seek comment on a proposal intended to make it possible to use wider channel bandwidths for the provision of broadband services in certain spectrum bands. (Dkt No. RM-11614 03-66, FCC No 11-81) FCC-11-81A1.pdf
6875–7125 MHz & 12700–13200 MHz Bands—Wireless backhaul further inquiry (DA No 11-1011, Dkt No 10-153) DA-11-1011A1.pdf DA-11-1011A2.pdf
76–77 GHz Band—Proposed to modify Sections 15.35 and 15.253 of the rules to enable enhanced vehicular radar technologies in the 76-77 GHz band to improve collision avoidance and driver safety. (Dkt No 11-90 10-28 RM-11555, FCC No 11-79) FCC-11-79A1.pdf
Broadband Access Issues—More than 20 million Americans denied access to jobs & economic opportunity within broadband economy. More than 100 million Americans do not subscribe to broadband. (Dkt No 10-159, FCC No. 11-78) DOC-306788A1.pdf FCC-11-78A1.pdf FCC-11-78A2.pdf FCC-11-78A3.pdf FCC-11-78A4.pdf FCC-11-78A5.pdf
Caller ID "Spoofing"—Consumers Gain New Protections Against Fraudulent Caller ID "Spoofing". (Dkt No 11-39, FCC No 11-100) FCC-11-100A1.pdf
Electronic Tariff Filing System—The FCC enables carriers to replace paper filings with online filings. Electronic filing eases burden on carriers, increases transparency for public. (Dkt No 10-141, FCC No 11-92) FCC-11-92A1.pdf FCC-11-92A2.pdf FCC-11-92A3.pdf FCC-11-92A4.pdf FCC-11-92A5.pdf
Emergency Alert System—First ever nationwide test scheduled for November 9, 2011 at 2 PM EST. (DA No 11-1030, Dkt No 04-296) DA-11-1030A1.pdf
LightSquared—Comment deadlines established regarding the GPS-LightSquared technical working group report. (DA No 11-1133, Dkt No 11-109) DA-11-1133A1.pdf
Low Power Television Digital Transition—Amendment of parts 73 & 74 (Dkt No 03-185, FCC No 11-110) FCC-11-110A1.pdf FCC-11-110A2.pdf FCC-11-110A3.pdf
Phone Bill "Cramming"—FCC proposes rules to help consumers identify and prevent "Mystery Fees" (Dkt No 09-158, 11-116,98-170, FCC No 11-106) DOC-308351A1.pdf DOC-308351A2.pdf DOC-308351A3.pdf DOC-308351A4.pdf DOC-308351A5.pdf FCC-11-106A1.pdf FCC-11-106A2.pdf FCC-11-106A3.pdf FCC-11-106A4.pdf FCC-11-106A5.pdf
FCC Grants Hughes Network Systems, LLC Request for "SPACEWAY 6"
Ka-band Service
The FCC granted Hughes Network Systems, LLC's (Hughes') request for a declaratory ruling to access the U.S. market using a planned Ka-band geostationary satellite orbit (GSO) fixed-satellite service (FSS) space station, SPACEWAY 6, that will operate under the authority of the United Kingdom at the 90.9° W.L. orbital location. Hughes states that SPACEWAY 6 will be used to provide a variety of two-way communications services to business and residential customers in the United States, including high-speed data services, high-definition video programming, on-demand entertainment, digital music, interactive television, and high-speed Internet access. SPACEWAY 6 will be permitted to provide service to U.S. customers in the 28.35–29.1 GHz and 29.25–30.0 GHz frequency bands (Earth-to-space) and the 18.3–19.3 GHz and 19.7–20.2 GHz frequency bands (space-to-Earth) once Hughes completes coordination with Federal satellite systems operating in the downlink band, and submits a copy of the U.K. space operations authorization in the public record in this proceeding. U.S. operations in the 28.6–29.1 GHz frequency band (Earth-to-space) will be on a secondary basis to stations operating in this band on a primary basis. Further, because there is no designation for GSO FSS in the 18.8–19.3 GHz band, U.S. operations in this band will be on a non-harmful interference basis to other authorized operations. http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0617/DA-11-1067A1.doc
FCC Establishes Policies and Service Rules for BSS 17.3–17.7 GHz, 17.7–17.8 GHz and FSS 24.75–25.25 GHz Frequency Bands
The FCC adopts rules to mitigate space path interference between the 17/24 GHz Broadcasting-Satellite Service (BSS) space-to-Earth transmissions and the feeder link receiving antennas of Direct Broadcast Satellite Service (DBS) space stations that operate in the same frequency band. The FCC Order adopts an off-axis power flux density (pfd) coordination trigger for 17/24 GHz BSS space stations, requiring a minimum orbital separation requirement of 0.2 degrees between17/24 GHz BSS space stations and DBS space stations, and place bounds on orbital inclination and eccentricity of 17/24 GHz BSS space stations. The FCC also revised the informational requirements to require 17/24 GHz BSS space station applicants to file predicted and measured transmitting antenna off-axis gain information. The adopted procedures are meant to enable pending applicants and existing authorization holders to file relevant information related to these rules, thus facilitating the introduction of the 17/24 GHz BSS and anticipate that it will provide new and innovative services, including video, audio, data, and video-on-demand, to consumers in the United States and promote increased competition among satellite and terrestrial services. http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0614/FCC-11-93A1.pdf
FCC Spectrum Task Force Focus on 2 GHz band Allocations for MSS and AWS
The FCC Spectrum Task Force invites technical input on approaches to encourage the growth of terrestrial mobile broadband services in the 2 GHz spectrum range that is allocated for fixed and mobile use. The FCC seeks information on developing a cohesive approach that maximizes the terrestrial mobile broadband potential of this spectrum. Specifically, the focus is on bands co-allocated for Mobile Satellite Service (MSS) at 2000–2020 MHz and 2180–2200 MHz ("2 GHz MSS band" or "S Band"), as well as bands, or portions of bands, designated for Advanced Wireless Service (AWS), including: AWS-2 upper "H" block spectrum at 1995–2000 MHz; AWS-2 paired "J" block spectrum at 2020–2025 MHz and 2175-2180 MHz; and AWS-3 spectrum at 2155–2175 MHz. http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0520/DA-11-929A1.doc
FCC Modifies Globalstar License for Second Generation MSS space stations
The FCC modified the licenses held by GUSA Licensee LLC for operation of fixed and mobile earth stations in the United States to permit those stations to transmit radio signals to, and receive transmissions from, second-generation Mobile-Satellite Service ("MSS") space stations licensed by the Republic of France. The second-generation satellites will provide two-way voice and data communications with higher data rates than first-generation satellites and improved global and domestic coverage. The FCC also modified the license held by Globalstar Licensee LLC for operation of first-generation MSS space stations to permit changes in their orbital deployment. These modifications will allow Globalstar to offer a variety of state-of-the-art mobile satellite services to existing and new customers in the United States over the next decade and beyond. http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-520A1.doc
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Comsearch introduces iQ·link®XG Solo
A low cost, high quality software solution for your microwave network planning.
Contact us for more information on this Windows based tool. WWW.IQLINKXG.COM
Visit Comsearch at APCO International 77th Annual Conference & Expo from August 7–10, 2011, in Philadelphia, PA
Visit us at booth #1603 and enter a drawing to win a KINDLE 3G with $25 Amazon.com gift card, plus a lighted leather cover.
Spectrum Leasing
Comsearch now provides listings for leasing of 24 GHz and 39 GHz portfolios of nationwide wide area millimeter-wave (microwave) spectrum licensed to FiberTower Corporation, a wireless backhaul services provider.
Comsearch filed over 20,000 FCC applications in 2010!
Find out more about our FCC application filing services.
Two-Time Winner—Outstanding 4G Solutions for Wireless Backhaul
Two CommScope businesses—Andrew Solutions and Comsearch—have been named winners of the second annual Wireless Backhaul Distinction Award presented by 4GWE.
Comsearch selected by FCC as TV Bands Device Data Administrator
View the Federal Communications Commission DA 11-131.pdf.
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