Current Issues Affecting Fixed Wireless:

An Update on FWCC Activities

National Spectrum Management Association

Cheng-yi Liu

703-812-0478 | liu@fhhlaw.com

Fletcher, Heald & Hildreth, PLC

May 19, 2015

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Fixed Wireless Communications Coalition (FWCC)

Formed in 1998 Provides a voice for the Fixed Service community Hundreds of filings at the FCC (over 230 per ECFS)

initiated numerous rulemaking proceedings Success due to dedicated and diverse membership Members include:

equipment manufacturers, engineering firms, licensees of microwave systems and their associations, communications service providers and their associations, railroads, public utilities, petroleum and pipeline entities, public safety agencies, cable TV providers, backhaul providers, communications carriers, and telecommunications attorneys and engineers

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FWCC Objectives (excerpt)

To participate in regulatory proceedings that impact the Fixed Service through spectrum allocation, technical or service rules, or otherwise

To initiate regulatory actions as needed to maintain and improve the environment for the Fixed Service

To defend the Fixed Service against interference from other services both licensed and unlicensed

(visit www.fwcc.us for full list)

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FWCC Objectives

In other words, we strive to ensure that:

fixed services have access to necessary spectrum

that the regulatory environment under which we operate is workable and keeps pace with technological developments

that fixed services can coexist harmoniously—and interference free—among other spectrum users.

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Access to Spectrum

Spectrum policy motivation: MORE BANDWIDTH FOR MOBILE BROADBAND Meow!

Effect on fixed service: Corresponding need for more wireless backhaul Mobile services compete for spectrum access

Example: 2014 Notice of Inquiry – 5G mobile services in 24+ GHz bands Many bands currently used by fixed service

FWCC seeking other spectrum opportunities

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Access to Spectrum

42 – 43.5 GHz 2012 FWCC Petition for Rulemaking Already allocated for Fixed Service Suitable for urban backhaul

7125 – 8500 MHz Currently only for Federal users Under 10 GHz, mitigates rain fade Can alleviate congestion in Lower/Upper 6 GHz Needs NTIA consent, automated coordination system

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The Regulatory Environment

Laws and regulations often lag technology

FWCC active in advocating for change Congress, Communications Act re-write FCC proceedings

Ensure rule changes do not create negative implications

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The Regulatory Environment

Relaxation of antenna standards Smaller can be better

FCC modified 6, 18, & 23 GHz standards in 2012 FWCC provided input

FCC also sought comment on standards for other bands FWCC requested rulemaking for 70/80 GHz antennas Smaller antennas facilitate dense urban deployment

Lower costs Visually inoffensive Can be installed in more places

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The Regulatory Environment

5.8 GHz unlicensed Useful for quick deployment of long links (unlimited antenna gain

with no power penalty) Easy transition to licensed 6 GHz operation

2013 FCC proposal to consolidate two rule sections Resulted in possible elimination of unlimited antenna gain FWCC and other successfully opposed

Currently, ongoing efforts to address OOBE issue Stricter OOBE negates benefits of unlimited antenna gain Government concerned with protecting TDWR installations

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Coexistence With Other Spectrum Users

Prevent interference concerns

Promote efficient use of spectrum

Frequency coordination process generally works well Coordination among fixed service users Coordination with Government users Coordination with other services (e.g., satellite)

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Coexistence With Other Spectrum Users

Occasional disputes between fixed service users

2014 dispute centered around Expedited coordination requests Growth channel holding periods FWCC sought clarification for uncertainty

2015 FCC Public Notice Reiterated coordination requires cooperation from both sides Sought further comment on whether:

– Fixed time limits are needed for growth channels– Other rule changes needed to address growth channels

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Coexistence With Other Spectrum Users

2010 FWCC Petition for Rulemaking re 23 GHz band 23 GHz shared with Federal users

Requires NTIA coordination FWCC requested automated coordination system

Alleviates lengthy NTIA coordination process If implemented, would better facilitate conditional authorization

FWCC also requested eligibility for conditional authorization across the entire band Currently, only limited frequency pairs eligible Heavy usage on eligible frequencies Rest of band underutilized

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Coexistence With Other Spectrum Users

Fixed Satellite Service Earth Stations Coordinated/licensed for “full band, full arc” Effectively blocks many fixed service links Problems if earth station not built or not in right place

FWCC requested earth station audit in 2010 Also requested in 2008, 2004, and 2002 So far, without resolution

FWCC working with NSMA WG3 Conducting studies to further illustrate the issue

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Coexistence With Other Spectrum Users

Fixed Service Sharing with TV BAS & CARS at 7 & 13 GHz FCC authorized in 2011 NSMA working on coordination guidelines Issue of missing receive-end data in ULS

Likely due to manual porting of Form 313 data Past efforts to encourage ULS corrections unsuccessful FWCC working with NSMA to seek FCC assistance

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Thank you!

(most FWCC filings available at www.fwcc.us)

Cheng Liu

703-812-0478 | liu@fhhlaw.com