Comments of Shaw Communications Inc. Consultation on Spectrum

Comments of Shaw Communications Inc.

Consultation on Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum in Various Bands, Including Bands Shared with Satellite, Mobile and Other

Services

Gazette Notice SMSE-018-12

ABRIDGED

April 22, 2013

I. Introduction

1. These comments are submitted by Shaw Communications Inc. (“Shaw”) in response to

Canada Gazette, Part I, 21 December 2012, Notice No. SMSE-018-12, Consultation on

Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum

in Various Bands, Including Bands Shared With Satellite, Mobile and Other Services (the

“Consultation” or “Consultation Document”).

2. As indicated in the Consultation Document, the purpose of the consultation is to “seek

comments on the possibility of making additional spectrum available for backhaul, as

well as views on updating standards and policies, with a view to increasing flexibility,

utilization and efficiency, taking into account technological advances.”1

3. Shaw welcomes this Consultation and the opportunity to explore under-utilized

frequency bands and how they could be used to meet growing demands for capacity

throughout Canada.

4. Shaw is a diversified communications and media company, providing consumers with

broadband cable television, High-Speed Internet, Home Phone, telecommunications

services (through Shaw Business), satellite direct-to-home services (through Shaw

Direct) and engaging programming content (through Shaw Media). Shaw serves over 3

million customers using a variety of technologies, including coaxial cable, fibre,

terrestrial broadcast antenna systems, DTH satellites, unlicensed WiFi spectrum and

licensed microwave spectrum in the fixed service.

5. At the present time, Shaw utilizes mixed fibre and wireless microwave solutions to

provide medium- and long-haul networks in order to support the distribution of

1 Consultation on Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum in

Various Bands, Including Bands Shared with Satellite, Mobile and Other Services, Canada Gazette, Part II, Notice SMSE-018-12, paragraph 2.

broadcasting, Internet and phone services in regions where fibre facilities are not

feasible.

6. Although we acknowledge the findings of the Red Mobile Consulting report2 that the

offloading of traffic and the migration from microwave to fibre for facilities for high-

capacity links has made more spectrum available in certain regions, it should be noted

that this trend has only occurred where it is physically and financially feasible to

construct fibre facilities. In many areas where Shaw operates this is not the case and we

have seen demand for bandwidth increase twofold over the last three years. We

remain concerned that spectrum will be unavailable to meet our forecasted backhaul

requirements in the near future within some regions.

7. In fact, we note in this regard that demand for Internet services and increased

bandwidth utilization are the primary drivers for Shaw’s growing need for backhaul

spectrum. For example, in the mountainous areas along coastal and interior British

Columbia, it is neither physically nor economically feasible to build fibre connections to

smaller communities. In these situations, Shaw relies on microwave systems to provide

the necessary backhaul links.

8. Broadband access is a very high priority for the government in recognition of its critical

importance to realize the potential of Canada’s digital economy. In particular,

broadband access in less populated areas is a focus for the government, as reflected in

the policy framework for the 700 MHz band.3 In order to bring broadband access to

more remote areas and realize the government’s objectives, it is imperative that

sufficient spectrum be available.

2 Study of Future Demand for Radio Spectrum in Canada 2011-2015, Red Mobile Consulting

(http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10253.html) 3 See Policy and Technical Framework – Mobile Broadband Services (MBS) – 700 MHz Band—Broadband Radio

Service (BRS) – 2500 MHz Band, SMSE-002-12, March 12, 2012.

http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10253.html

9. At the same time, Shaw notes that it continues to make extensive use of VHCM systems

in remote and underserved areas. There is an ongoing need for these systems in these

particular areas of the country. As such, Shaw does not support the placement of a

moratorium on the licensing of these systems.

10. Before responding to the specific questions posed in the Consultation Document, it

should be noted that certain information provided herein is submitted in confidence to

the Department. This information is consistently treated as confidential by Shaw and

release of this information on the public record would provide existing and potential

competitors with invaluable confidential details regarding Shaw’s network and future

plans. This information could be used by such parties to develop more effective

marketing and business strategies which could cause Shaw specific direct harm.

Therefore, in accordance with subsection 20(1) of the Access to Information Act, Shaw

requests that this information be maintained in confidence by the Department and that

all requests for disclosure be refused. An abridged version of these comments is being

provided for placement on the public record.

II. Responses to Specific Questions Posed in the Consultation Document

The Department is seeking comments on specific requirements for wireless backhaul spectrum with respect to microwave short-, medium- and long-haul systems.

4-1 Please provide current and forecasted usage information and deployment plans for short-, medium- and long-haul wireless backhaul systems within your network.

4-2 Describe your current needs and technical requirements (e.g. capacity, data rates) for backhaul systems. a. Is there an immediate need for additional spectrum for network expansion or system upgrades? If so, how much spectrum is required and in which frequency range?

4-3 Describe your forecasted needs and technical requirements in the medium to long term (three to five years). Provide specifics regarding capacity, frequency (short-, medium- and long-haul) and other related aspects that may affect network design and operation. a. Is there a requirement for additional spectrum? If so, how much spectrum is required? In what frequency range? What are the related time frames?

4-4 Is there a continuing need for bands below 3.7 GHz for long-haul systems or could this

need be met in bands at 3.7 GHz and above?

11. Information filed in Confidence with Industry Canada.





16. Shaw does not support the displacement of existing services to promote expansion but

rather expansion into other frequency bands not currently available for FS should be

considered where there is open spectrum available.




4-5 Given current and anticipated deployments, identify specific frequency bands and corresponding geographical areas in which you are experiencing or expect congestion. Please provide your deployment plans for these areas and proposals to mitigate congestion.



4-6 Are the above definitions still practical in determining what areas are congested (i.e. when technical requirements should be relaxed or tightened)? If not, please explain and provide proposals on alternative definitions and/or measures.

4-7 Although a relaxation of antenna pattern is most commonly requested through the application of the GDP guideline, other policy and technical requirements may also be eased. Should the Department specify technical requirements and policies to be relaxed when the GDP guideline is applied in uncongested areas? Please explain and provide proposals on the specific minimum technical requirements that should be relaxed.

4-8 Currently, the GDP guideline is applied to specific frequency bands. Are there other bands that would benefit from the application of the guideline? Please provide proposals.

Interested parties are invited to provide any other comments that may be relevant to congestion levels.

22. Shaw believes that the definitions contained in the Geographical Differences Policy

(“GDP”) guideline remain the most appropriate way of determining areas of congestion.

23. With respect to uncongested areas (which are currently defined by the GDP guideline as

an area where 90% or more of the channels are available in 90% or more of the possible

directions), Shaw submits that relaxation of the antenna pattern and channel size limits

should be considered in uncongested areas. We believe that this will allow operators to

increase their channel sizes allowing a higher amount of data to be transmitted across a

single channel rather than taking up multiple channels resulting in more bandwidth

utilization.

24. In the frequency bands designated for long – and medium-haul systems, the maximum

allowable channel size is typically 30 to 40 MHz. If the band is relatively unused in an

uncongested area, it might make sense to allow the use of 50 MHz channels to reduce

the overall amount of spectrum utilized to achieve the same amount of bandwidth. This

change would require manufacturers to modify equipment to handle the larger

channels. Shaw would support such a modification to the maximum channel size in

uncongested areas to ensure that a minimum level of spectral efficiency is maintained.

25. Shaw further recommends that the GDP guideline be expanded to include all point-to-

point FDD frequency bands and not just those that are used specifically for backhaul

purposes. This would relate to both the Primary and Secondary services in all bands

that utilize FS for point to point FDD systems which would allow for more efficient use of

the spectrum in moderately and highly congested regions.

The Department is seeking comments regarding deployments within the 4 GHz band, including the following: 5-1 Is there any interest in the deployment of new heavy route backhaul systems or the

expansion/growth of existing systems within the band? What is the anticipated time frame?

5-2 Are there technical characteristics or regulatory provisions limiting deployment within the band (e.g. capacity designation)?

5-3 Provide proposals on specific revisions to policy and/or technical standards to improve usage of the band.

Interested parties are invited to provide any other comments that may be relevant to the use of this spectrum.

26. Shaw is interested in utilizing the 4 GHz band for backhaul purposes. However, there is

very limited equipment available at this time to make use of this frequency band. If

equipment was available Shaw would utilize this band for long-haul networks. These

bands have typically been used for Very Low Capacity, Low Capacity and Medium

Capacity systems where maximum channel sizes are less than 20 MHz. However, it is

spectrum for High Capacity systems Shaw requires to meet current capacity constraints.

5-4 The Department is seeking comments on deploying fixed two-way backhaul systems within the band 6930-7125 MHz. Please specifically address any technical issues, the feasibility of sharing, as well as any coordination considerations with the FSS and transportable TV pickup operations.


27. The 6930-7125 MHz band is in use today by multiple parties for TV pickup operations.

These systems typically use sector or omni-directional antennas to pick up remote feeds

which would make it extremely difficult to coordinate with FS services to avoid

interference. Since TV pickup signals are not constantly in use, parties would not be

aware of interference issues until the TV pickup operators required the frequencies.

Because of this Shaw does not support changes to this band to allow sharing of the

frequency in areas where this spectrum would be in use for TV pickup. However, Shaw

would support the use of this spectrum in remote regions where the use of this

spectrum would not interfere with TV pickup services. A guideline would need to be set

to determine a safe distance from TV pickup locations in order to mitigate any possible

interference issues.

7 GHz Band (7125-7725 MHz)

5-5 Given the demand for additional spectrum, the Department is seeking comments on providing other users with access to all channels, including 30 MHz bandwidth channels within the band.

5-6 As the Department continues to encourage other diversity techniques that are more spectrally efficient, comments are being sought on the continued use of frequency diversity by utilities in this band.

28. There are currently a number of remote regions in Western Canada (mainly the

mountainous regions along the British Columbia coastline and Vancouver Island) that

are highly congested in the lower frequency bands, particularly in the lower and upper

portions of the 6 GHz band as well as the 11 GHz band. This congestion prohibits the

addition of any long haul microwave (>30 km) links. Opening up the 7 GHz band for this

purpose would allow carriers the opportunity to enhance their network capacity to

remote regions.

29. The 7 GHz band is currently allocated on a shared use basis in conjunction with mobile

and fixed satellite services as well as electric power grid telemetry and control systems.

Shaw acknowledges that with the number of shared uses in this band coordination may

pose some challenges.

30. Frequency diversity takes up more bandwidth than required for a system to work

properly because it uses a second channel that could be used by another carrier. This

reduces the amount of spectrum remaining for other carriers and contributes to

congestion in the band. Although frequency diversity does improve the reliability of a

given system, microwave links are still affected by atmospheric propagation anomalies.

31. While space diversity receive antennas are still affected by these anomalies, they can

provide the same degree of reliability across the link, but are significantly more efficient.

32. Based on these considerations, Shaw submits that the use of frequency diversity should

be discontinued by utilities in the 7 GHz band.

5-7 The Department is seeking comments on deploying fixed two-way backhaul systems within the band 8275-8500 MHz. Please address any technical issues, the feasibility of sharing and any coordination considerations with the incumbent services, including Earth exploration-satellite service (space-to-Earth), space research service (space-to-Earth) FSS (Earth-to-space), and one-way fixed services.


33. The 8275-8500 MHz band allows a maximum channel size of 18.75 MHz which is limited

to 90 Mbps per channel. Most microwave systems are expanding to provide 1 Gbps

capacity which would utilize 11 channels within this band. Given that there are only 6

channels available in the band, the bandwidth available would not be of interest to

parties, such as Shaw, looking to increase network capacity.

34. In addition to the concerns identified above, we note that this band is already highly

congested in regions where Shaw is in immediate need of additional network capacity.

5-8 The Department is seeking comments on its proposal to introduce fixed two-way backhaul services within the 12.7-13.2 GHz range, including any technical issues (e.g. preferred channel plan, bandwidths and capacity requirements), sharing and coordination considerations, as well as any other relevant factors regarding the use of this band.

5-9 Given the limited requests for VHCM systems, the Department is seeking comments on the introduction of a moratorium on future licensing of new VHCM systems in the band.

35. Shaw submits that the 13 GHz band should remain available to VHCM on a primary basis

with spectrum for backhaul being made available on a secondary basis, where it can be

feasibly coordinated. The existing landscape for VHCM systems is currently small, but as

cable carriers move to expand their reach into smaller communities they find that

installing VHCM systems is their only choice. The remoteness of these communities

places them beyond the reach of fibre optic facilities. These communities are often in

mountainous or coastal regions but they can also be found in the newer “bedroom”

communities developed outside major centres that have no existing communication

infrastructure.

36. Given the foregoing considerations, Shaw does not support the introduction of a

moratorium on licensing for VHCM systems within the 13 GHz band. There continue to

be several instances where cable carriers have no option but to provide broadcasting

services to smaller communities using VHCM systems where installation of fibre facilities

is neither technically nor economically feasible.

37. At page 22 of the Consultation Document, the Department is proposing (in Figure 5) that

that a variety of systems coexist on a coordinated basis within the 12.7-13.2 GHz band.

Shaw supports this proposal and does not believe that a moratorium on VHCM systems

needs to be instituted in order to give effect to the proposal.

38. With respect to the use of this band for fixed two-way backhaul systems, Shaw notes

that the European Telecommunications Standards Institute (“ETSI”) already has a 30

MHz channel plan that fits well into this band. Shaw recommends that the band be

limited to 20, 30, 40 and 50 MHz channel sizes to ensure the maximum bandwidth

capacity of the microwave links.

5-10 The Department is seeking comments regarding the low usage of the 18.14-18.3 GHz and 19.3-19.36 GHz portions of the band. Please address any technical characteristics or regulatory provisions limiting deployment, and provide proposals on specific policy or allocation revisions to improve usage within the band.

39. Shaw does not have any comments on the 18.14-18.3 GHz band at the present time.

5-11 The Department is seeking comments on making the band 31.8-33.4 GHz available for backhaul and is seeking views on equipment availability, considering that the band is not allocated for FS in the United States.

5-12 In addition to backhaul, comments are being sought on other potential FS applications.

5-13 The Department is seeking comments on channelling plans, policy implications, sharing measures and coordination considerations or constraints, architecture (point-to-point, point-to multipoint or a combination thereof) and anticipated time frames in which this spectrum would be required.


5-14 The Department is seeking comments on the lack of usage to date within the 38.4-38.6 GHz portion of the band. Are there technical characteristics or regulatory provisions limited deployment within this portion of the band.

5-15 The Department is also seeking comments on its proposal to allow fixed two-way systems within the 38.4-38.6 GHz range. Please include any technical issues, sharing and coordination considerations with other services, preference regarding duplexing methods, and other factors.

5-16 Comments are being sought as well on alternate uses of this portion of the band. Please include any technical issues, sharing and coordination considerations with any other services, and other relevant factors.

Interested parties are invited to provide any other comments that may be relevant to the use of this spectrum


5-17 The Department is seeking comments on whether deploying fixed systems in the band 40.5-43.5 GHz should be permitted. Factors such as potential applications, anticipated time frames, sharing constraints, mitigation measures and/or coordination considerations with other services, including radio astronomy and future HDFSS applications, are of particular interest. As well, comments are being sought on whether this band should be made available for point-to-point, point-to-multipoint systems or a combination thereof.


42. Shaw does not have any comments on the 40.5-43.5 GHz band at this time.

5-18 The Department is seeking comments on whether additional spectrum is needed for backhaul purposes. Proposals should identify the particular frequency band(s) and address technical requirements, policy and licensing implications, as well as sharing and coordination considerations. Proposals should also state whether equipment is currently

available and provide as much information as possible on the use of such spectrum in other countries.

43. As noted above, Shaw would be interested in utilizing the 3.7-4.2 GHz band for long

range microwave backhaul purposes but at this time there is very limited equipment

available for use in this band.

44. As a separate matter, Shaw notes that as the Department makes additional spectrum

available for backhaul purposes, it will need to update the methodology that it uses to

calculate licence fees for the use of this spectrum. For example, Shaw notes that 70 and

80 GHz bands are now available for two-way microwave systems. However, with

channel sizes of 250 MHz, the associated licence fees would be astronomical, making

these bands prohibitive to the use. Shaw therefore recommends that the licence fees

for all FS spectrum be updated in order to reflect current uses within the bands and the

higher bandwidths that are now achievable.

6-1 The Department is seeking comments and proposals on mechanisms to encourage greater spectral efficiencies. Recommendations pertaining to a specific frequency band should identify the band and the proposed minimum spectral efficiency. Recommendations should also address any technical issues or implications and the treatment of existing deployments.

The Department is seeking comments regarding the current capacity definitions (see Table 5) and restrictions on system traffic loads:

6.2 Do the current capacity definitions accurately reflect today’s requirements?

6-3 Is there still a specific requirement for LC- and/or MC-only bands, or should the current restrictions on the use of higher capacity systems in such bands be reconsidered? Please address specific bands, implications on usage and deployment.

Interested parties are invited to provide any other comments that may be relevant to capacity.

45. Shaw believes that the capacity definitions used by the Department should be modified

as they do not accurately reflect today’s requirements. Very few companies today

would allocate financial resources to install a system with less than 50 Mbps capacity.

Shaw proposes that the definitions be adjusted as shown in the table below:

RF Channel Capacity a,b Traffic Load (Mbit/s)c

Low-capacity (LC) ≥ 1.544 ≤ 51.840

Medium-capacity (MC) > 51.840 ≤ 155.008

High-capacity (HC) > 155.008

46. With respect to frequencies below the 6 GHz band, Shaw submits that High Capacity

systems should be reconsidered for this frequency range. Very few systems are

operating at the Low Capacity rates and, going forward, the capacities required in

remote areas will only continue to increase. Since the lower frequency bands are used

for longer distance links, Shaw does not recommend the use of cross-polarization

techniques to increase bandwidth because cross-polarization has been developed to

work over short distances. This technique is not technologically feasible over long

distances.

47. Given the foregoing, it would appear that either larger channel sizes or higher order

modulation techniques will be required to increase capacity. In Shaw’s view, because

higher order modulation techniques, [such as 512, 1024, and 2048 QAM], are more

susceptible to interference and have a lower threshold for operation which would limit

the distance that these modulations would be useful for. Shaw submits that the best

method to increase capacity is to increase the channel bandwidth allowed.

6-4 Assuming that capacity restrictions are retained, the Department is seeking comments on the RABC’s request to allow MC systems specifically within the 10 GHz band, including any implications that this may have on future usage and deployment.

48. Shaw has no comments on the RABC’s proposal at the present time.

The Department is seeking comments on defining minimum antenna characteristics:

6-5 Please provide proposals on specific frequency bands for which the Department may wish to review the minimum antenna characteristics. The proposals must include specifics for new standards, including maximum beam width, minimum gain and maximum off-axis emissions or radiation pattern envelope. Address any implications to existing licensees and the radio environment, future deployments, spectrum sharing and congestion.

6-6 Are there specific technical considerations or requirements that the Department should consider in order to mitigate any potential of increased interference or congestion if minimum antenna characteristics are relaxed or conversely, implications should these characteristics be made stricter?

Interested parties are invited to provide any comments that may be relevant to antenna characteristics and standards.

49. Shaw agrees in principle with the FCC’s standards as set out in its Second Report and

Order Notice FCC 12-87.4 We believe that Canada should harmonize its standards with

those of the FCC in order to ensure a consistent North American approach.

6-7 The Department is seeking general information on new equipment advances or technologies that can ease the growing capacity issues on backhaul systems.

50. Please see our responses to the questions above. Shaw may provide additional

comments on this topic in the reply stage of this proceeding.

6-8 The Department is seeking comments on whether the use of the following techniques should be considered as standard. Please address any resulting technical, policy or spectrum management issues, any sharing or coordination considerations, as well as any implications on congestion, frequency reuse or the radio environment as a whole.

a. Radio systems that employ adaptive modulation, noting that during adverse propagation conditions, the systems’ spectral efficiencies may fall below the specified minimums.

b. Radio links that use CCDP to effectively increase the capacity over the same channel.

c. Systems that make use of channel bonding to effectively increase the available bandwidth.

d. Other planned or available types of radio equipment technology to ease capacity issues.

6-9 Is there a need for additional flexibility or modernization of policies and/or standards to allow for evolution and advances in equipment? Please provide specific proposals addressing any technical implications, sharing and coordination considerations, as well as any impact on the interference environment and congestion levels.

4 Second Report and Order, Second Further Notice of Proposed Rulemaking, Second Notice of Inquiry, Order on

Reconsideration, and Memorandum Opinion and Order, FCC 12-87, available online at: http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0822/FCC-12-87A1.pdf

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0822/FCC-12-87A1.pdf

Should any of your comments be considered proprietary, they must be submitted separately and clearly marked as “Confidential”

51. Shaw has reviewed the proposed techniques and, although these are all quite efficient

in spectrum use, they are not all feasible in all frequency bands. Further investigation is

warranted in determining which frequency bands would be affected by these changes.

6-10 The Department is seeking comments on the level of use of analog systems, including the number of operational systems, age of equipment, life expectancy, specific frequency band and geographical area.

6-11 To reflect current deployment trends, the Department is seeking comments on whether to remove specific references to analog systems or retain them to address specific requirements. Please address potential technical or policy implications and submit any suggested amendments.


53. The specific references to analog systems should be maintained in the Department’s

policies and SRSPs as these systems are still in operation. In fact, as noted earlier, Shaw

submits analog systems should have priority treatment over digital data systems that

may be added into the specific frequency bands where there may be interference. In

particular our concern is with the 12.7-13.2 GHz band as we have numerous AML and

FML systems that are operating in this band and which provide broadcasting services to

surrounding communities. As noted above, Shaw does not support a moratorium on

licensing of VHCM systems in this band or the destandardization of analog systems

operating in the band.

6-12 The Department is seeking comments on the need for additional flexibility or other updates to policies and/or standards to promote flexible and efficient use of wireless backhaul services. Please provide specific situations and criteria under which greater flexibility of spectrum use may be afforded, addressing any technical implications, sharing and coordination considerations, as well as any impact on the interference environment and congestion levels.

54. Shaw submits that flexibility should be given to systems that wish to convert their

existing analog systems to a digital system utilizing the same amount of bandwidth as

the analog system. This will allow for the efficient re-use of the same spectrum that is

currently in use.

6-13 The Department is seeking general comments on the need to introduce one-way transmissions in certain bands where the use of a two-frequency plan is currently a regulatory obligation. Please specify the frequency band and address any technical, sharing and coordination issues.

55. Shaw submits that the introduction of one-way transmission systems in certain bands

would be an inefficient use of the spectrum as the majority of the systems currently

being implemented today are two-way systems providing data transport. The inherent

nature of IP traffic is two-way communications. In Shaw’s view, there is currently

sufficient spectrum available for one-way systems such as STL links and TV Pickup

systems.

7-1 Provide general information on your use of non-radio alternatives to resolve backhaul challenges. What is the combination (and percentage of wireless and other backhaul solutions) used within your network? Has this ratio changed within the last few years, and do you expect it to change within the next three to five years.

Interested parties are invited to provide other comments relevant to non-radio alternatives

56. As noted above, Shaw utilizes a mix of fibre and wireless microwave solutions to provide

medium- and long-haul networks in order to distribute a variety of services to rural and

remote areas, including broadcasting, Internet and phone services. Although Shaw has

made a tremendous investment of hundreds of millions of dollars in fibre facilities and,

indeed, will continue to build or lease fibre wherever it is technically or economically

feasible to do so, as noted above, this is not always possible, especially in rural,

mountainous and hard to reach communities. Therefore, it is imperative that fixed

wireless spectrum be made available for the transmission of voice, data and broadcast

traffic to these communities as proposed above.

III. Conclusion

57. We thank Industry Canada for the opportunity to provide our input in this proceeding.

Microwave networks and backhaul spectrum are integral parts of Shaw’s current and

future operations. They are also critical to the achievement of the government’s

broadband deployment and digital economy objectives, particularly the need to meet

the needs of rural and remote communities. To this end, Shaw urges the Department

to adopt the proposals and recommendations contained in this submission.

*** END OF DOCUMENT ***

Documents

Comments of Shaw Communications Inc. Consultation on Spectrum