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Spectrum Management 2008 Industry Association Roundtable Paul J. Sinderbrand

The Spectrum Management Industry Association aims to promote a competitive marketplace for wireless broadband services through legislative and regulatory advocacy. Key focus areas include 700 MHz, D Block and Public/Private Safety Partnership, WCS, AWS-3, BRS/EBS, LMDS, and more.

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Spectrum Management 2008 Industry Association Roundtable Paul J. Sinderbrand

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  1. Spectrum Management 2008 Industry Association Roundtable Paul J. Sinderbrand Wilkinson Barker Knauer, LLP 202.783.4141 psinderbrand@wbklaw.com

  2. 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

  3. Primary Recent Spectrum Focus • 700 MHz • Future of D Block and Private/Public Safety Partnership • Comments - June 20; Reply comments - July 7. • 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

  4. WCS/SDARS

  5. 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.

  6. 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

  7. 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.

  8. 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.

  9. 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.

  10. 2.5 GHz Restructuring FORMER PLAN

  11. 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

  12. 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.

  13. 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.

  14. 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 • Can auction be avoided? • BTAs or something else? • How much spectrum? • Priority for local and/or accredited institutions? • Upfront payments? Bidding credits?

  15. 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 “self-relocate” 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.

  16. 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

  17. 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

  18. THANK YOU! Paul J. Sinderbrand Wilkinson Barker Knauer, LLP 202.783.4141 psinderbrand@wbklaw.com

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