An Update on FWCC Activities National Spectrum Management Association Cheng yi Liu 7038120478 liufhhlawcom Fletcher Heald amp Hildreth PLC May 19 2015 Fixed Wireless Communications Coalition FWCC ID: 647860
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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, 2015Slide2
Fixed Wireless Communications Coalition (FWCC)Formed in 1998Provides a voice for the Fixed Service community
Hundreds of filings at the FCC (over 230 per ECFS)initiated numerous rulemaking proceedingsSuccess 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
spectrumthat the regulatory environment under which we operate
is workable
and
keeps pace with technological developmentsthat fixed services can coexist harmoniously—and interference free—among other spectrum users.
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Access to SpectrumSpectrum policy motivation:MORE BANDWIDTH FOR MOBILE BROADBANDMeow!
Effect on fixed service:Corresponding need for more wireless backhaulMobile services compete for spectrum access
Example:
2014 Notice of Inquiry – 5G mobile services in 24+ GHz bands
Many bands currently used by fixed serviceFWCC seeking other spectrum opportunities
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Access to Spectrum42 – 43.5 GHz2012 FWCC Petition for RulemakingAlready allocated for Fixed Service
Suitable for urban backhaul7125 – 8500 MHzCurrently 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 EnvironmentLaws and regulations often lag technologyFWCC active in advocating for change
Congress, Communications Act re-writeFCC proceedingsEnsure rule changes do not create negative implications
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The Regulatory EnvironmentRelaxation of antenna standardsSmaller can be betterFCC modified 6, 18, & 23 GHz standards in 2012
FWCC provided inputFCC also sought comment on standards for other bands
FWCC requested rulemaking for 70/80 GHz antennas
Smaller antennas facilitate dense urban deployment
Lower costsVisually inoffensiveCan be installed in more places
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The Regulatory Environment5.8 GHz unlicensedUseful for quick deployment of long links (unlimited antenna gain with no power penalty)
Easy transition to licensed 6 GHz operation2013 FCC proposal to consolidate two rule sectionsResulted 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 gainGovernment concerned with protecting TDWR installations
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Coexistence With Other Spectrum UsersPrevent interference concernsPromote efficient use of spectrum
Frequency coordination process generally works wellCoordination among fixed service users
Coordination with Government users
Coordination with other services (e.g., satellite)
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Coexistence With Other Spectrum UsersOccasional disputes between fixed service users2014 dispute centered around
Expedited coordination requestsGrowth channel holding periodsFWCC 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 Users2010 FWCC Petition for Rulemaking re 23 GHz band23 GHz shared with Federal users
Requires NTIA coordinationFWCC requested automated coordination systemAlleviates 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 eligibleHeavy usage on eligible frequencies
Rest of band underutilized
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Coexistence With Other Spectrum UsersFixed Satellite Service Earth StationsCoordinated/licensed for “full band, full arc”
Effectively blocks many fixed service linksProblems if earth station not built or not in right placeFWCC requested earth station audit in 2010
Also requested in 2008, 2004, and 2002
So far, without resolution
FWCC working with NSMA WG3Conducting studies to further illustrate the issue
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Coexistence With Other Spectrum UsersFixed Service Sharing with TV BAS & CARS at 7 & 13 GHzFCC authorized in 2011
NSMA working on coordination guidelinesIssue of missing receive-end data in ULSLikely 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