DGSO - Language · PDF fileOctober 8, 2014. Senior Director. Spectrum Development and Operations . Industry Canada . 300 Slater Street (JETN, 15th) Ottawa, Ontario K1A 0H5 . VIA E-Mail:

Pelmorex Communications Inc. Page | 1

2655 Bristol Circle

Oakville, Ontario L6H 7W1

October 8, 2014

Senior Director, Spectrum Development and Operations Industry Canada

By email only at: [email protected]

Dear Mr. Hill,

Re: Canada Gazette Notice No. DGSO-003-14 — Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (“Consultation”)

1. Pelmorex Communications Inc. (“Pelmorex”) is pleased to comment on the above referenced Consultation. Pelmorex is the licensee of the specialty services The Weather Network (“TWN”) and MétéoMédia (“MM”), which are authorized by the Canadian Radio-television and Telecommunications Commission (“CRTC”) to provide weather and environmental news and information programming. Both TWN and MM are distributed to Broadcasting Distribution Undertakings across Canada using C-band satellite.

2. As part of its CRTC licence undertaking, Pelmorex has also built and operates the National Alert Aggregation and Dissemination (NAAD) System which authenticates public safety alerts issued by public officials and disseminates these messages to TV and radio broadcasters, Broadcasting Distribution Undertakings and other parties [collectively referred to as, Last Mile Distributors, or “LMDs”] for redistribution to the public.

3. Emergency alerts issued through the NAAD System by federal, provincial and territorial governments are distributed by Pelmorex over several different mediums to LMDs, including C-Band satellite to ensure redundant, full Canada coverage. As such, Pelmorex’s use of the C-Band satellite spectrum is an important component of Canada’s national public alerting system, allowing the NAAD System to reach broadcasters and others who might not otherwise be able to access public safety alert messages, by other means, for re-distribution to the public.

4. In response to Question 7 in the Consultation, Pelmorex is concerned that enabling mobile services to operate in the 3500 MHz band in urban areas may cause out-of-band interference to the 3700-4200 band. This may affect our ability to distribute our programming services and NAAD System alerts to LMDs, and/or affect LMDs who rely on C-Band satellite to receive and retransmit our programming services and/or public safety messages from the NAAD System.

5. Pelmorex hopes that making Industry Canada fully aware of our use of this spectrum will be helpful in its determinations and we look forward to reviewing the comments of other interested parties and participating in the reply stage of this proceeding.

Yours truly,

Paul Temple Sr. Vice President, Regulatory & Strategic Affairs Pelmorex Communications Inc.

*** End of Document ****

October 8, 2014 Senior Director Spectrum Development and Operations Industry Canada 300 Slater Street (JETN, 15th) Ottawa, Ontario K1A 0H5

VIA E-Mail: [email protected]

Dear Sir / Madam:

Re: Gazette Notice DGSO-003-14 (September 6, 2014) – Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas

The enclosed comments are submitted on behalf of the Public Interest Advocacy Centre. Yours truly, (Original signed)

Geoffrey White Counsel for PIAC

Encl.

c: John Lawford, Executive Director and General Counsel, PIAC ([email protected])

PUBLIC INTEREST ADVOCACY CENTRE

LE CENTRE POUR LA DÉFENSE DE L’INTÉRÊT PUBLIC

ONE Nicholas Street, Suite 1204, Ottawa, Ontario, Canada K1N 7B7

Tel: (613) 562-4002. Fax: (613) 562-0007. e-mail: [email protected] http://www.piac.ca

mailto:[email protected]


http://www.piac.ca/

Gazette Notice DGSO-003-14 (September 6, 2014)

Consultation on Policy Changes in the 3500 MHz Band

(3475-3650 MHz) and a New Licensing Process in

Rural Areas

Comments of the Public Interest Advocacy Centre

(“PIAC”)

October 8, 2014

DGSO-003-14 – 3.5 GHz and rural licensing

Comments of PIAC October 8, 2014

i

TABLE OF CONTENTS 1. Introduction .............................................................................................................. 1

2. The 3.5 GHz spectrum in context ............................................................................ 1

3. Specific Comments on Consultation Questions ................................................... 6

Proposed New Classification of Tier 4 Service Areas — Rural vs. Urban ............................... 6

FWA in Rural Areas ................................................................................................................ 7

Proposed Licensing Process for FWA in Rural Tiers ........................................................... 7

Treatment of Incumbents in Rural Tier Areas ...................................................................... 8

FWA Band Plan in Rural Areas ........................................................................................... 9

Proposed Conditions of Licence for Existing and New FCFS FWA Licences ...................... 9

Proposed Fundamental Reallocation of the 3500 MHz Band .................................................10

Treatment of Incumbent Licensees in Urban Tier 4 Areas Following a Proposed Fundamental Reallocation of the 3500 MHz Band.......................................................................................12

4. Conclusion .............................................................................................................. 12

DGSO-003-14 – 3.5 GHz and rural licensing Comments of PIAC

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1. Introduction

1) The Public Interest Advocacy Centre (“PIAC”) makes the following comments in respect of Gazette Notice DGSO-003-14 (September 6, 2014) – Consultation on Policy Changes in the

3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (the “3.5 GHz Consultation Document”).

2) PIAC again welcomes the recent wireless spectrum proposals to address the needs of Canadians, particularly those living in rural and remote areas. These include recent consultations on the AWS-4 and AWS-3 bands, and the current consultation on the 3.5 GHz band.

3) In these initial comments PIAC responds to the Department’s nine specific consultation questions. First, however, PIAC situates the present consultation in context.

2. The 3.5 GHz spectrum in context

4) 3.5 GHz spectrum is high frequency spectrum and therefore requires, on a relative basis to lower frequency spectrum, more power, and therefore infrastructure (towers and radios) to keep the signal strong.

5) Currently, only fixed services are permitted in the 3.5 GHz band, and the band is allocated to various radiocommunication services, including radiolocation service, fixed-satellite service, and notably, fixed wireless access (“FWA”), which is akin to wired internet access from a premise except the service is delivered off a tower to a radio/dish, not via wireline facilities, in the “last mile”). It is unclear from the publicly available data how many Canadians rely on FWA,1 and PIAC further notes that it would be helpful for the purposes of

1 PIAC’s current estimate is an approximate upper bound of 500,000-535,000 using the CRTC’s

Communications Monitoring Report 2013 for “residential revenues by access type” (4% ‘other’, though note that includes ISDN and satellite), total residential revenues of $5.369 billion and ARPU average for the lower tier speeds. Xplornet appears to be the largest provider for FWA and celebrated their 200,000th subscriber in August 2013 (Xplornet, “200k customer celebration”) http://www.xplornet.com/xplornetcontest/) and a Globe and Mail article from July 28, 2014 suggests Xplornet has ‘near 250,000’ subscribers, though PIAC notes Xplornet provides satellite as well as FWA service. (The Globe and Mail, “Xplornet plans ‘unprecedented’ expansion of high-speed Internet to all of rural Canada” (28 July 2014).

Sasktel appears to be the next biggest provider of FWA, though their financial reports do not separate out FWA from Internet/wireless numbers. There is little evidence of subscriber numbers in filings to Industry Canada, or in Industry Canada documents. Where evidence is available it tends to point to “household availability” rather than subscription levels. Using Statistics Canada data on the amount of people in rural areas (6,329,414 in 2011), and ‘availability’ numbers from the CRTC (50-51%), leads to a much larger


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this consultation to put on the record verified evidence from the FWA incumbents about their levels of deployment and their service offerings. That said, in its 2014 report to the Canadian Radio-television and Telecommunications Commission (the “CRTC”), Wall Communications Inc. (“Wall”) observed that

While the number of satellite-based ISPs serving rural and remote areas is generally not extensive, the same is not true for fixed wireless ISPs. In the latter case, there can be a large number of small scale fixed wireless service providers serving different geographic areas scattered across rural and remote areas of a country. Some fixed wireless ISPs may serve no more than a single community.2

6) As the Department noted in its 2013 Commercial Mobile Spectrum Outlook, “Many countries are reviewing their current use of frequencies around the 3500 MHz band to allow for the introduction of commercial mobile services. As network operators look to this band in the medium-term, an equipment ecosystem, including LTE equipment, is expected to become available.”3

7) The 3.5 GHz spectrum, as the Department notes, would be suitable for adding capacity in urban areas, but is less suitable for mobile service in rural areas due to its high frequency propagation characteristics.4

8) The Department, noting that there is “strong demand for both fixed wireless broadband

services in rural areas, and mobile broadband services in urban areas”5, is proposing to reconfigure the way it licenses 3.5 GHz wireless spectrum and to licence it for fixed high-speed wireless broadband use in rural areas, and as mobile broadband in urban areas (Tier 4 service areas which contain a population centre of 30,000 or more). The Government of Canada has stated that this means that up to 36% of the 3.5 GHz spectrum could be converted to mobile use.6

‘accessibility’ estimate (~3,165,000), but that number is per person rather than per household/subscriber. Therefore 500,000 is PIAC’s current estimate.

2 Wall Communications Inc., Report prepared for the Canadian Radio-television and

Telecommunications Commission, “Price Comparisons of Wireline, Wireless and Internet Services in Canada and with Foreign Jurisdictions” (2014 update) (the “Wall Report”).

3 Commercial Mobile Spectrum Outlook, March 2013 at 35. 4 3.5 GHz Consultation Document at para. 21:

21. The propagation characteristics of the 3500 MHz spectrum are such that mobile services cannot cover a large area without significant infrastructure. Therefore, although the 3500 MHz spectrum is well suited to meet the increasing demand for mobile spectrum in urban communities to address congestion, it is less economical to use the spectrum for mobile services in rural areas. In contrast, the 3500 MHz band is well suited to meet the needs for FWA services in rural areas, as it is currently used today.

5 Ibid., at para. 13. 6 Government of Canada Press Release, “Harper Government Delivers on Its Commitment to Put

Canadian Consumers First” (19 August 2014).


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9) In addition, licensees will have six months to deploy their spectrum, or face the consequence of losing their licence.

10) Deployment using in the 3.5 GHz spectrum has generally been low 7 , and broadband penetration in Canada is also low, or available but significantly more expensive than other broadband access plans, and with greater restrictions.

11) The CRTC has reported that as of 2012 only 75% of Canadian households had internet

access at 1.5 Mbps download speeds, and only 62% had internet access at 5 Mbps download speeds. When it comes to the leading edge mobile LTE-speed of service, only 72% of Canadians had access.8 As of 2013 the 1.5 Mbps penetration rate was 77%, and the 5 Mbps penetration rate was 67%, and the LTE penetration rate increased to 81%.9 The increased in penetration are positive signs that the Department is on the right track in terms of achieving its policy objectives, which the Department has summarized in the 3.5 GHz Consultation Document as “ensuring that Canadians benefit from the availability of advanced, competitively priced telecommunications services in all regions of the country.”10

12) The figures, however, reveal a large number of Canadians who cannot access internet

service at a speed that can actually support the types of functions every Canadian should be able to use. Nor do the reported figures provide any evidence as to the affordability of wireless broadband.

13) A scan of wireline versus fixed wireless broadband service offerings in the market reveals

however that fixed wireless service offerings tend to come with higher pricing for lower speeds, and lower monthly data allowances11, and also that Canada compares “relatively less favourably” to peer jurisdictions.12

7 Decisions Concerning the Renewal of 2300 MHz and 3500 MHz Licences DGSO-004-13 (the

“Renewal Document”) at para. 29: “there has been limited deployment to date.” See also 3.5 GHz Consultation Document at para. 12.

8 CRTC 2013 Communications Monitoring Report. 9 CRTC 2014 Communications Monitoring Report. 10 3.5 GHz Consultation Document at para. 6.

Note, the Department has consistently given this overarching spectrum policy objective expression in the band-specific (AWS, 700 MHz, 2500 MHz, AWS-3 and AWS-4) policy, technical and licensing frameworks, as follows:

(i) sustained competition in the wireless telecommunications services market so that consumers and businesses benefit from competitive pricing and choice in service offerings;

(ii) robust investment and innovation by wireless telecommunications carriers so that Canadians benefit from world-class networks and the latest technologies; and,

(iii) availability of these benefits to Canadians across the country, including those in rural areas, in a timely fashion.10

11 Wall Report: “[I]n many cases satellite and fixed wireless broadband services have relatively low

monthly data allowances.” 12 Ibid., (emphasis original):


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14) The extracts from tables in the Wall Report to the CRTC illustrate this.

15) Figure 1 compares fixed wireless broadband service pricing at various usage baskets, and indicates pricing is generally less favourable in Canada than in its peer jurisdictions.

Figure 113

16) Figure 2 compares fixed wireless broadband service speeds and monthly data caps, and indicates speeds and data caps in Canada are generally lower in Canada than in its peer jurisdictions.

Figure 214

Fixed Wireless Services: Canadian fixed wireless broadband Internet services compare relatively less favourably with the services available in the other three countries [the U.S., the U.K. and Australia]. Based on the sample of surveyed fixed wireless service providers, on average, Canadian fixed wireless service speeds were found to be somewhat slower and prices higher than those of the other three surveyed jurisdictions.

13 Ibid., Table 14. 14 Ibid., Table 13.


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17) Figure 3, compares fixed wireline broadband service speeds, based on Wall’s assumed data usage requirements (indicated in parentheses) for the four broadband Internet service baskets.

Figure 315

18) Bringing some of this information together in Figure 4 reveals that fixed wireless access has higher pricing and more limited speed offerings.

Figure 4

Broadband Basket Fixed Wireless Fixed (Wireline) Pricing Data Cap

(GB) Pricing Assumed Data

usage (GB) Level 1 (Up to 3 Mbps) $61.04 38 $50.00 7.5 Level 2 (4 to 15 Mbps) $71.28 76 $55.10 30 Level 3 (16 to 40 Mbps) - - $68.60 75 Level 4 (Over 40 Mbps) - - $86.46 120

19) Additionally, the Wall analysis on monthly data caps suggests that fixed wireless caps may

be much lower than they are for fixed (wireline) access. Wall notes that “in many cases satellite and fixed wireless broadband services have relatively low monthly data allowances.”16 Figure 4 shows the monthly data caps for fixed wireless service, and the monthly assumed usage for wireline access, which Wall assumes is lower than any existing monthly data caps.17

15 Excerpt from Wall Report’s “Summary of International Price Comparison 2014” table. 16 Wall Report, Section 5.4. 17 Ibid.,, section 5. Wall notes that monthly data usage caps, where they exist for broadband service

plans, may tend to be higher than Wall’s assumed monthly usage:

Some Internet service providers (ISPs) apply monthly data usage caps to their broadband service plans. Where they are applied, they are typically set on the basis of a monthly data allowance (GB/month), with overage fees applied when the data allowance is exceeded.


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20) Despite the challenges associated with fixed wireless service, PIAC nevertheless questions (i) the need at this time for a geographically differentiated strategy designed to put more mobile spectrum to use in “urban” areas, and (ii) how the proposed urban-rural differentiation may affect customers of incumbent fixed wireless service providers currently in the band. PIAC notes that the three largest commercial mobile service providers in Canada, TELUS Communications Company, and Bell Mobility Inc. and Rogers Communications Partnership (through their Inukshuk joint venture) have been advocating for the 3.5 GHz spectrum to be converted in designation to commercial mobile service.18 On the other hand, some service providers have in the past advocated for an “unbundling” or rural areas from urban areas within licence tiers.

21) PIAC believes that an appropriate policy approach to the 3.5 GHz band should emphasize

maximizing deployment and affordability in a way that minimizes disruption to existing subscribers, and is sustainable into the future.

3. Specific Comments on Consultation Questions

Proposed New Classification of Tier 4 Service Areas — Rural vs. Urban

1.Industry Canada invites comments on its proposal to classify Tier 4 service areas as either urban

or rural for the band 3475-3650 MHz, using Statistics Canada’s 2011 definition for population

centres, as outlined in Annex A.

22) The Department has proposed to licence the 3.5 GHz on a Tier 4 basis, and to classify each Tier 4 service area into either rural or urban, with “urban” service areas being those which contain a population centre of 30,000 or more. The Department notes that this approach uses Statistics Canada’s definitions for “population centres” to classify each tier. PIAC notes

Applicable usage caps are taken into account in the study, including any overage fees that may apply once assumed usage levels are exceeded. However, most of the surveyed ISPs either have no usage caps or, where they do apply, they are high enough that no overage fees would be incurred given the data usage assumptions adopted for the defined broadband service baskets.

18 Renewal Document at para. 17:

17. Both Inukshuk and TELUS suggested changing the allocation of the band. Inukshuk would like the Department to launch a consultation regarding the band plan by early 2014, in order to add a mobile allocation before licensees deploy services. TELUS stated that after the extension, the entire band should expire, be returned to the Department on December 31, 2017, and be re-auctioned as a new mobile band (based on a possible future consultation). Its reasoning is that “FWA spectrum in Canada is not well synergized with any other market or ecosystem” and that the “transition of FWA spectrum to mobile broadband spectrum in Canada represents a fundamental reallocation to a new service.” It argued that there must be no windfall for current licensees, noting that TELUS itself holds 124 licences in the 3500 MHz band.

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that the proposed definition of “urban” actually means those service areas that have what Statistics Canada calls a “medium population centre” (30,000-99,999) and “large urban population centres” (100,000 and above).

23) PIAC notes that this approach categorized a service area as “urban” not on the basis of an overall population density, but on the basis of their being a concentration of people in a given area or areas. The result is that there may be Tier 4 service areas that are mostly rural, except for one “medium population centre”, for which FWA may still be the more suitable technology yet no longer able to benefit from that technology by virtue of the “urban designation” which requires the 3.5 GHz spectrum to be used for mobile service. PIAC expands on that concern below.

FWA in Rural Areas

Proposed Licensing Process for FWA in Rural Tiers

2. Industry Canada invites comments on its proposal to make available spectrum licences in tier

areas classified as rural, through a first-come, first-served process.

24) The Department has proposed that licensees that are fully compliant with the current conditions of licence (including deployment) will be “eligible to be issued a new one-year licence”, whereas non-compliant licenses will be returned to the Department and made available through a new licensing process.19

25) Additionally, and on the basis of the deployment data submitted by current licensees, and the amount of spectrum available in rural areas, the Department anticipates that demand for rural 3.5 GHz licenses will not exceed supply, and therefore proposes to licence the spectrum on a FCFS basis.

26) PIAC supports only issuing new licenses to incumbents that have met the minimum deployment obligations, and taking back the licences from non-compliant service providers, as a way to reward deployment and to ensure conditions of licence are taken seriously by licensees. At the same time, PIAC believes that those licensees that have complied with the conditions of licence should automatically be issued a new one-year license, rather than putting their licences at risk in a FCFS process where it is conceivable that another party could, by virtue of timing alone, take the licence away from the operating incumbent.

19 3.5 GHz Consultation Document at para. 27.


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3.Industry Canada invites comments on these licences being issued as annual spectrum licences,

defined on a per grid-cell basis and authorized only for the amount of spectrum required to operate

(refer to Section 7.3).

27) Additionally, the Department is proposing to make the 3.5 GHz spectrum available in rural areas on a grid-cell basis within the Tier 4 service area, such that service providers can more granularly target the geographies and populations they wish to serve. The Department is also proposing to make 3.5 GHz licences in rural areas available on one-year terms, with current FWA incumbents in compliance with all conditions of licence eligible for licences and with the remainder being made available on a FCFS basis.

28) PIAC appreciates that the length of other licence terms for other spectrum authorizations is typically longer than one year, and in many cases, is 20-years, to allow sufficient time to deploy and capitalize off of spectrum investments. PIAC also appreciates that annual renewals of licences granted on a grid-cell basis and in different blocks, may require more administration. Despite this, PIAC recognizes that the stated intention behind the short licence terms is to focus on deployment, as acknowledged in the Government of Canada’s press release announcing the within consultation, and PIAC therefore believes that shorter licensing is appropriate, especially in light of the future uncertainty that surrounds the band.

Treatment of Incumbents in Rural Tier Areas

4. Industry Canada invites comments on its proposal to modify the current notification period for

existing point-to-point, fixed stations such that those affecting the implementation of new FWA

systems in rural Tier 4 areas would now be afforded a notification period of six months.

29) The Department has proposed a six-month notification period to displace any remaining point-to-point fixed stations in the 3.5 GHz band.

30) As the Department has noted, this displacement has been forewarned for at least ten years. Accordingly, PIAC believes that the proposed notice period is reasonable.

5. Industry Canada invites comments on its proposal to have the transition policy described in

section 4 of Annex B apply to all FWA systems (i.e. existing FCFS and auctioned FWA systems as

listed in (v) and (vi)) within rural tiers.

31) The Department has proposed that existing FCFC and auctioned FWA systems licenced and installed within rural tiers may continue to operate, subject to any displacement and transition to a new band plan and subject to new technical rules “if and when they are established to facilitate the introduction of commercial mobile services in urban tiers.”20

20 Ibid., Appendix “B” – Proposed Conditions of Licence, s. 4.

http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10841.html#s7.3

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32) PIAC understands the trend towards designating the 3.5 GHz band for mobile service,

however questions if prioritizing this band for commercial mobile services in “urban” tiers could potentially impair rural service provision, as discussed further in response to consultation question 8 below.

FWA Band Plan in Rural Areas

33) The Department is proposing to maintain the current band plan: three 25 + 25 MHz paired blocks (DJ, EH and FK), and one unpaired (G) block, but to only authorize the use of only the amount of spectrum required for the intended operations.

34) The band plan, with requirement-specific amount authorizations, will remain in place until such time as a new band plan and other relevant technical rules may be established to facilitate the introduction of commercial mobile service in urban tiers.

35) PIAC makes no comment on the FWA band pan at this time.

Proposed Conditions of Licence for Existing and New FCFS FWA Licences

6. Industry Canada invites comments on the conditions of licence in Annex B.

36) The Department is proposing that all 3.5 GHz FWA licences have a requirement to deploy the system described in the FCFS application within six months of licence issuance, and to thereafter maintain ongoing service delivery subject to the possibility of licence suspension or revocation for failure to maintain deployment (or provide requested information).

37) PIAC notes that this condition of licence leaves it to the FCFS applicant to in effect define their deployment, and PIAC questions whether a more objective deployment condition should be imposed on the licences to avoid applicants simply applying with low coverage thresholds and not being required to serve all households within a given grid cell. While PIAC appreciates that grid-cell licensing will allow service providers to obtain authorizations for smaller service areas, and thus make licensing more accessible to smaller service providers, PIAC questions whether allowing service providers to define their own commitments is an appropriate public policy. PIAC also questions whether the mere possibility of licence suspension or revocation will serve as an appropriate incentive to deploy, and therefore suggests that the Department make suspension automatic, pending the provision of a path to compliance, failing which the licence would be automatically revoked.

38) PIAC notes with support the Department’s proposed licence term in respect of licence

amendments wherein “[t]he Minister of Industry retains the discretion to amend these terms and conditions of licence at any time”. Although PIAC is of the view that the Minister of

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Industry has that discretion by virtue of the Radiocommunication Act,21 which the proposed conditions of licence note in their preamble, PIAC believes that in light of a court challenge22 to the licence transfer framework,23 it is prudent to explicitly build that right and flexibility directly into licences.

Proposed Fundamental Reallocation of the 3500 MHz Band

7. Industry Canada invites comments on its proposal to fundamentally reallocate the 3500 MHz

band (3475-3650 MHz) to include mobile services and its proposed changes to the Canadian Table

of Frequency Allocations as found in Annex C.

8. Industry Canada invites comments on its geographically differentiated policy where mobile

services will be allowed in urban tiers, and fixed services will be allowed in rural tiers (refer to

Section 6 for the definition of urban and rural tiers).

39) On the basis that demand for mobile services is expected to be “very high in urban areas, but limited in rural areas”, the Department is proposing a “geographically differentiated spectrum utilization policy” using the proposed urban-rural schema discussed earlier whereby the 3.5 GHz will be licensed as commercial mobile spectrum in “urban” areas and as fixed spectrum in “rural” areas.

40) Those incumbents operating fixed services in “urban” areas will be subject to the proposed displacement policy whereby commercial mobile operators effectively have a right of pre-emption on the spectrum.

41) The Department has stated that “[t]he proposed fundamental reallocation and proposed spectrum utilization policy balance the demand for mobile spectrum in urban areas with the demand for fixed spectrum for FWA in rural areas by setting a geographically differentiated policy.”24 PIAC is not at this stage convinced that is the case.

42) As the Department has noted, the pathway to commercial mobile spectrum in the 3.5 GHz

band is less than clear at this stage, due to equipment issues, and current lack of a coherent band plan:

21 Radiocommunication Act (R.S.C., 1985, c. R-2), s. 5(1):

Subject to any regulations made under section 6, the Minister may, taking into account all matters that the Minister considers relevant for ensuring the orderly establishment or modification of radio stations and the orderly development and efficient operation of radiocommunication in Canada […] (b) amend the terms and conditions of any licence, certificate or authorization issued under paragraph (a);

22

TELUS Communications Company v. Attorney General of Canada et al., (FC Docket T-1295-13). 23 DGSO-003-13 - Framework Relating to Transfers, Divisions and Subordinate Licensing of

Spectrum Licences for Commercial Mobile Spectrum (June 2013). 24 3.5 GHz Consultation Document at para. 56.

http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10841.html#aC

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Although Long Term Evolution (LTE) equipment exists for fixed services, it is not currently readily available for mobile devices, such as handsets. However, as network operators worldwide look to this band in the medium term, equipment is expected to be developed for mobile services, including LTE. Once the equipment ecosystem becomes evident, the Department plans to make changes to the band (e.g. band plan, technical rules) as quickly as possible to permit mobile services. […] Additionally, “[a]lthough changes are being considered internationally to the configuration of this band in order to support mobile services, there is no clear direction at this time. 25

43) PIAC does not suggest that the Department ignore the direction that the 3.5 GHz band is

heading, globally, but at the same time, is concerned about making changes that could impact fixed service providers today, with a view to addressing the future needs of “urban” users later, resulting in fixed service providers being displaced from the band. Providing that those fixed service providers can demonstrate to the Department, on the public record, that they are putting the spectrum to use in serving subscribers, then caution is advised and the possibility of using other bands to address urban congestion should be explored.

44) If capacity is an issue in urban areas, then perhaps there is a bigger issue to be explored with spectral efficiency at the time of the further consultation the Department says it will conduct if and when the proposed fundamental reallocation occurs.26

45) In PIAC’s view, there may be challenges in categorizing sparsely populated Tier 4 service

areas as “urban” and thereby limiting the use of 3.5 GHz to mobile service, on the basis of population centre(s) in a small geographic part of the larger tier exceeding the 30,000 population mark. The Department has explicitly recognized this

The Department recognizes that in using this approach, some rural communities fall within urban tiers. There may also be some sizeable towns in rural tiers in which there is a high demand for additional commercial mobile spectrum. However, the granularity at which rural and urban areas can be distinguished such that different wireless services can be offered in the same frequency range is limited due to the ability for two services to coexist. Furthermore, as discussed above, the existing tier areas placed service area border lines through lesser populated and more remote areas wherever possible, in order to minimize potential interference problems and keep economic areas intact.27

46) The practical problem with the “mis-categorization” of a given area could be that a mobile service provider may have no interest in providing fixed service in those areas that fall under the “rural” category, but more likely is the case where a FWA provider has no interest or ability to provide mobile service to the population centres in a given Tier 4 service area given a focus on customers outside of those population centres.

25 Ibid., at para. 40. 26 Ibid., at para. 53. 27 Ibid., at para. 25.


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47) PIAC does not offer a recommended approach to this problem at this juncture, pending the ability to review evidence filed by the operators in such tiers, but suggests that it would be difficult to support the Department’s proposal if the result is to favour the mobile service needs of residents of population centres over the needs of residents in areas outside of those cores, then PIAC opposes the Department’s proposal. Similarly, if the result is to favour mobile wireless service providers over fixed service providers, PIAC also opposes the Department’s proposal.

Treatment of Incumbent Licensees in Urban Tier 4 Areas Following a Proposed Fundamental Reallocation of the 3500 MHz Band

9. Industry Canada invites comments on its two proposed options for displacement.

48) The Department has proposed two options for how incumbents in “urban” tiers would be displaced in the event of the transition to mobile.

Option 1, the shorter option, involves displacement of incumbents within a minimum of one year of the release of a future new licensing framework and 3.5 GHz band plan. Option 2, the longer option, involves displacement of incumbents only if, and as required, after commercial mobile licences are issued. Licensees would have one year to transition once notified by the Department.

49) In light of the concerns expressed above, PIAC supports giving operating incumbents more time to transition than less, and therefore favours Option 2.

4. Conclusion

50) PIAC looks forward to reviewing the comments of other interested parties and submitting reply comments in this process.

***End of document***

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PAR COURRIER ÉLECTRONIQUE ([email protected])

Montréal, le 8 octobre 2014 Directrice principale Développement et Opérations de Spectre Industrie Canada 300, rue Slater 15e étage, JETN Ottawa (Ontario) K1A 0H5 Objet : Gazette du Canada, Partie I, le 6 septembre 2014, Consultation sur les

modifications de la politique visant la bande de 3 500 MHz (3 475 – 3 650 MHz) et sur un nouveau processus de délivrance des licences dans les zones rurales (Avis n° DGSO-003-14) – Commentaires de Québecor Média inc., en son nom et celui de Vidéotron s.e.n.c.

Madame, En conformité à la procédure décrite à l’Avis n° DGSO-003-14, nous vous faisons par la présente parvenir les commentaires Québecor Média inc. dans le cadre de la consultation mentionnée en rubrique. Recevez, Madame, l’expression de notre considération distinguée.

Dennis Béland Vice-président, Affaires réglementaires Télécommunications Ligne directe : 514 380-4792 Télécopieur : 514 380-4664 Courriel : [email protected] p.j.

Consultation sur les modifications de la politique visant la bande de 3 500 MHz (3 475-3 650 MHz) et sur un nouveau

processus de délivrance des licences dans les zones rurales

Avis de la Gazette du Canada DGSO-003-14

Commentaires de Québecor Média inc., en son nom et en celui de Vidéotron s.e.n.c.

8 octobre 2014

Table des matières

I. INTRODUCTION ET SOMMAIRE 1 II. RÉPONSES DE QUÉBECOR MÉDIA AUX QUESTIONS 2

SPÉCIFIQUES

A) Nouvelle classification proposée pour les zones de 2 service de niveau 4 — rural versus urbain

B) Le service d’accès fixe sans fil (AFSF) dans les 3

zones rurales

C) La réattribution fondamentale proposée des fréquences 4 de la bande de 3 500 MHz

D) Traitement des titulaires de licence en place dans 5

les zones urbaines de niveau 4 à la suite de la réattribution fondamentale proposée des fréquences de la bande de 3 500 MHz

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I. INTRODUCTION ET SOMMAIRE 1. Québecor Média inc. (Québecor Média), en son nom et en celui de sa filiale à

part entière Vidéotron s.e.n.c. (Vidéotron), a le plaisir de déposer les présents commentaires dans le cadre de la Consultation sur les modifications de la politique visant la bande de 3 500 MHz (3 475-3 650 MHz) et sur un nouveau processus de délivrance des licences dans les zones rurales, avis n° DGSO-003-14 publié le 6 septembre dans la partie I de la Gazette du Canada (le « Document de consultation »).

2. La présente soumission sera axée autour de trois points principaux. 3. Premier point : la classification des zones de service de niveau 4 dans la bande

de 3 500 MHz en tant que zone de niveau urbain ou zone de niveau rural s’impose à titre de mesure initiale si l’on veut ultimement permettre une utilisation pleinement efficace du spectre de la bande de 3 500 MHz. Cette classification est justifiée par le fait qu’elle est le reflet fidèle de l’utilisation qui a été faite à ce jour des fréquences de la bande. Elle est également justifiée en raison des caractéristiques de propagation des fréquences de la bande.

4. Deuxième point : la réattribution fondamentale des fréquences de la bande de

3 500 MHz est inévitable, et ce, d’une part, en raison des développements au plan international qui feront de cette bande une bande toute désignée pour le déploiement des services mobiles évolués, et, d’autre part, en raison des besoins spectraux sans cesse accrus des opérateurs mobiles qui peinent à subvenir à l’explosion de la consommation de ces mêmes services mobiles évolués. De plus, la politique de différenciation géographique fondée sur une division entre le rural et l’urbain constitue la clé de voûte nécessaire à une utilisation optimale des fréquences de la bande. Combinées l’une à l’autre, les deux mesures proposées correspondent aux premières étapes cruciales d’une feuille de route claire qui mènera ultimement à une utilisation harmonieuse des fréquences de la bande, ainsi qu’à une assignation juste et équitable des fréquences mobiles en zones urbaines, puisque la réattribution fondamentale des fréquences (jumelée à la politique de différenciation géographique) entraînera la reprise de toutes les licences de spectre actuellement assignées en zone de service urbaine de niveau 4.

5. Troisième point : Québecor Média encourage fortement le ministère à choisir la

première option de déplacement qu’il a proposée, en vertu de laquelle les titulaires du service fixe des zones de niveau urbain seraient déplacés au plus tard dans l’année suivant la publication d’un nouveau et futur cadre de délivrance de licences et du plan de répartition de la bande de 3 500 MHz. Cette option, qui se démarque par son caractère net purgé de toute ambiguïté, augmentera indéniablement le niveau de certitude des opérateurs sans fil mobiles dans leurs analyses de planification stratégique.

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II. RÉPONSES DE QUÉBECOR MÉDIA AUX QUESTIONS SPÉCIFIQUES 6. La présente section contient les réponses de Québecor Média aux questions

spécifiques énumérées au Document de consultation. A) Nouvelle classification proposée pour les zones de service de

niveau 4 — rural versus urbain 1. Industrie Canada sollicite des commentaires sur sa proposition de classer les zones de service de niveau 4 en tant que zone de niveau urbain ou de niveau rural pour la bande 3 475-3 650 MHz, en se fondant sur la définition de 2011 de Statistiques Canada pour les centres de population, tel qu’il est décrit à l’annexe A. 7. Québecor Média appuie la proposition du ministère de classer les zones de

service de niveau 4 dans la bande de 3 500 MHz en tant que zone de niveau urbain ou zone de niveau rural.

8. Nous sommes d’avis que cette classification s’impose à titre de mesure initiale si l’on veut ultimement permettre une utilisation pleinement efficace du spectre de la bande de 3 500 MHz.

9. La classification proposée se justifie dans un premier temps par le fait qu’elle est le reflet fidèle de l’utilisation qui a été faite à ce jour des fréquences de la bande. Comme le mentionne le ministère au document Décisions relatives au renouvellement de licences exploitées dans les bandes de 2 300 MHz et de 3 500 MHz1, les quelques déploiements qui ont été effectués à date par les détenteurs de licences consistent principalement en des systèmes fixes permettant de fournir des services Internet haute vitesse en zones rurales2.

10. Dans un deuxième temps, la classification proposée est également justifiée par les caractéristiques de propagation des fréquences de la bande de 3 500 MHz. Citons, à cet effet, les propos du ministère au paragraphe 21 du Document de consultation :

Les caractéristiques de propagation des fréquences de la bande de 3 500 MHz ne permettent pas aux services mobiles de couvrir une vaste zone sans une infrastructure considérable. Ainsi, cette bande est bien adaptée pour satisfaire à la demande croissante de spectre mobile dans les zones urbaines et pour faire face aux problèmes de congestion, mais il est moins rentable de l’utiliser pour les services mobiles en zones rurales. En revanche, la bande de 3 500 MHz convient bien pour répondre aux besoins de services AFSF en zone rurale, tel qu’elle est exploitée aujourd’hui.

1 https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/dgso-004-13-Decision-23and35MHz-fra.pdf/$FILE/dgso-004-13-Decision-23and35MHz-fra.pdf. 2 Décisions relatives au renouvellement de licences exploitées dans les bandes de 2 300 MHz et de 3 500 MHz, DGSO-004-13, paragraphe 29.

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11. Donc, le ministère est confronté à des impératifs commerciaux différents qui s’opèrent dans deux types de zones de services aux réalités distinctes, le tout dans une bande de fréquences aux caractéristiques de propagation limitées. On voit bien, par la force des choses, qu’une gestion efficace et juste du spectre de la bande de 3 500 MHz nécessite que l’on établisse au préalable une démarcation entre les zones de niveau rural et les zones de niveau urbain.

B) Le service d’accès fixe sans fil (AFSF) dans les zones rurales 2. Industrie Canada sollicite des commentaires sur sa proposition d’offrir des licences de spectre dans les zones de niveau classées dans la catégorie rurale selon le principe du premier arrivé, premier servi. 3. Industrie Canada sollicite des commentaires sur le fait de délivrer ces licences à titre de licences de spectre annuelles, définies sur une base de cellule de grille et autorisant uniquement la quantité de spectre nécessaire au fonctionnement (se référer à la section 7.3). 4. Industrie Canada sollicite des commentaires sur sa proposition de modifier la période d’avis courante prévue pour les stations fixes point à point existantes de manière à ce que les systèmes qui entravent la mise en oeuvre de nouveaux systèmes AFSF dans les zones rural de niveau 4 disposent maintenant d’un préavis de six mois. 5. Industrie Canada sollicite des commentaires sur sa proposition d’appliquer la politique de transition décrite à la section 4 de l’annexe B à tous les systèmes AFSF (c.-à-d. les systèmes existants AFSF autorisés par enchère et suivant le principe du PAPS indiqués en (v) et en (vi)) des zones de niveau rural. 12. Québecor Média prend acte des propositions du ministère évoquées aux

questions 2, 3, 4 et 5 ci-dessus, et n’a aucun commentaire additionnel à soumettre pour l’instant.

6. Industrie Canada sollicite des commentaires sur les conditions de licence indiquées à l’annexe B. 13. Québecor Média est en accord avec la proposition d’inclure aux conditions des

licences AFSF (nouvelles et existantes, et accordées sur une base premier arrivé, premier servi) le texte de la section 4 intitulée Déplacement que l’on retrouve à l’annexe B du Document de consultation, et qui se lit comme suit :

Ces licences peuvent être assujetties à une transition vers un nouveau plan de fréquences et vers d’autres règles techniques pertinentes, dans la

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mesure où celles-ci sont établies afin de faciliter l’introduction de services mobiles commerciaux dans les zones urbaines.

14. En incluant cette section, le message du ministère aux titulaires de licences

AFSF en zone de niveau rural est très clair : advenant la mise en place d’un nouveau plan de répartition de fréquences pour la bande de 3 500 MHz, le ministère donnera priorité absolue à l’implantation de services mobiles commerciaux dans les zones de niveau urbain, et prendra toutes les mesures nécessaires pour faciliter une telle implantation, laquelle pourrait avoir des impacts sur les déploiements AFSF en zones de niveau rural.

C) La réattribution fondamentale proposée des fréquences de la

bande de 3 500 MHz 7. Industrie Canada sollicite des commentaires, d’une part, sur sa proposition de réattribution fondamentale des fréquences de la bande de 3 500 MHz (3 475-3 650 MHz) afin d’y inclure les services mobiles et, d’autre part, sur les modifications qu’il propose d’apporter au Tableau canadien d’attribution des bandes de fréquences, présentées à l’annexe C. 8. Industrie Canada sollicite des commentaires sur sa politique de différenciation géographique, en vertu de laquelle il autorisera les services mobiles dans les zones de niveau urbain et les services fixes dans les zones de niveau rural (pour la définition des niveaux urbain et rural, se reporter à la section 6). 15. Québecor Média appuie sans réserve les propositions du ministère de procéder

à la réattribution fondamentale des fréquences de la bande de 3 500 MHz afin d’y inclure les services mobiles et de mettre en place une politique de différenciation géographique autorisant les services mobiles à opérer en zones de niveau urbain et réservant aux services fixes les zones de niveau rural.

16. La réattribution fondamentale des fréquences de la bande de 3 500 MHz est,

selon nous, inévitable, dans un premier temps, en raison des développements au plan international qui feront à moyen terme de la bande des 3 500 MHz une bande toute désignée pour le déploiement des services mobiles évolués, et dans un deuxième temps, en raison des besoins spectraux sans cesse accrus des opérateurs mobiles qui peinent à subvenir à l’explosion de la consommation de ces mêmes services mobiles évolués.

17. Le ministère ne le sait que trop bien – à preuve, le paragraphe 49 du Document de consultation, qui se lit comme suit :

Au Ministère, on est conscient qu’il faut mettre des ressources spectrales suffisantes et appropriées à la disposition des fournisseurs de service mobile commercial pour faire en sorte que la population canadienne continue de profiter de services sans fil évolués. À l’échelle internationale, on reconnaît qu’il faut prévoir des fréquences supplémentaires pour

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répondre à la croissance exponentielle de la demande de service mobile. De nombreux pays envisagent la bande de 3 500 MHz comme une option pour les services mobiles commerciaux à large bande.

18. De plus, la politique de différenciation géographique en vertu de laquelle le

ministère propose d’opérer une division entre le rural et l’urbain constitue, selon Québecor Média, la clé de voûte nécessaire à une utilisation optimale des fréquences de la bande de 3 500 MHz.

19. La proposition du ministère se démarque par sa flexibilité, et, à ce titre, elle découle directement de l’une des lignes directrices mentionnées au Cadre de la politique canadienne du spectre3, à savoir que la politique et la gestion du spectre du ministère devraient appuyer le fonctionnement efficient des marchés et, à cette fin, notamment, permettre une utilisation souple du spectre dans la mesure du possible4.

20. Or, l’utilisation qui est actuellement faite des fréquences et l’évolution à moyen terme de la bande appellent toutes deux, selon nous, à une telle souplesse de la part du ministère.

21. Combinées l’une à l’autre, les deux mesures proposées par le ministère

correspondent aux premières étapes cruciales d’une feuille de route claire qui mènera ultimement à une utilisation harmonieuse des fréquences de la bande de 3 500 MHz.

22. Et qui mènera également à une assignation juste et équitable des fréquences mobiles en zones urbaines, puisque la réattribution fondamentale du spectre de la bande de 3 500 MHz (jumelée à la politique de différenciation géographique) entraînera la reprise par le ministère de toutes les licences de spectre actuellement assignées en zone de service urbaine de niveau 4.

D) Traitement des titulaires de licence en place dans les zones urbaines

de niveau 4 à la suite de la réattribution fondamentale proposée des fréquences de la bande de 3 500 MHz

9. Industrie Canada sollicite des commentaires sur les deux options qu’il propose pour le déplacement. 23. Québecor Média encourage fortement le ministère à choisir la première option

de déplacement évoquée au Document de consultation, option qui se lit comme suit :

Première option – Déplacement des titulaires de licence existants des zones de niveau urbain au plus tard dans l’année suivant la publication

3 https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/spf2007f.pdf/$FILE/spf2007f.pdf. 4 Cadre de la politique canadienne du spectre, DGTP-001-07, page 10.

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d’un nouveau et futur cadre de délivrance de licences et du plan de répartition de la bande de 3 500 MHz.5

24. Nous favorisons cette option, puisqu’elle se démarque par son caractère net

purgé de toute ambiguïté, ce qui sera à l’avantage de toutes les parties concernées par l’exploitation des fréquences de la bande de 3 500 MHz.

25. L’élément-clé, en ce qui concerne Québecor Média, réside dans le fait que le choix de la première option de déplacement augmentera indéniablement le niveau de certitude des opérateurs sans fil mobiles dans leurs analyses de planification stratégique. Quant à ce point, nous tenons à souligner la justesse des propos du ministère lorsqu’il mentionne ce qui suit au paragraphe 63 du Document de consultation :

Le Ministère est d’avis que la première option offrirait une plus grande certitude aux titulaires de licence de spectre mobile éventuels et futurs avant la tenue d’un futur processus d’attribution de licences. Ces nouveaux titulaires de licence mobiles auraient une plus grande certitude à l’égard du moment où ils pourraient déployer leurs services sans entrave dans la zone de licence. Les nouveaux titulaires mobiles auraient ainsi la possibilité de déployer les services sur-le-champ dans l’ensemble de la zone de leur licence. Étant donné qu’il y aurait une autre consultation sur un cadre de délivrance de licences, les titulaires fixes touchés seraient en mesure de continuer à desservir leurs abonnés durant au moins deux années supplémentaires avant tout déplacement en vertu de cette proposition. Ce délai laisse amplement de temps aux titulaires existants de mettre en œuvre leur stratégie de transition, particulièrement quand on tient compte du fait qu’ils ont été informés d’une possible réattribution et de la transition correspondante en 2012.

26. La deuxième option, fondée sur le principe du déplacement d’un opérateur de

système fixe en zone de niveau urbain seulement si nécessaire, aurait pour effet de priver les opérateurs sans fil mobiles de la certitude évoquée plus haut. De plus, elle risque fort de résulter en une augmentation (pourtant évitable) des cas de conflits entre déploiements fixe et mobile en zones de niveau urbain, conflits dont la résolution nécessitera l’intervention du ministère à titre d’arbitre.

27. Bref, la deuxième option de déplacement représente à nos yeux une solution fondamentalement inefficace dont le ministère serait bien avisé d’éviter la mise en œuvre.

28. Le tout, soumis respectueusement.

5 Document de consultation, paragraphe 62.

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Radio Advisory Board of Canada Conseil consultatif canadien de la radio October 8, 2014

Peter Hill Director General Spectrum Management Operations Branch

By email at: [email protected]

Subject: Canada Gazette Notice No. DGSO-003-14 — Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas

The Radio Advisory Board of Canada is pleased to respond Canada Gazette Notice No. DGSO-003-14 — Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas.

The Board’s detailed response, prepared by joint working with broad industry participation is attached. This response was balloted to Board members. 16 of the Board’s 20 members responded as follows: 9 approved, 1 approved with comments, 1 abstention and 5 disapproved with comments. The Sponsor Member’s comments (which form an integral part of the RABC’s response) are as follows: Comments from CBC:

CBC/Radio-Canada disapproves with the attached answers by the RABC. Note that CBC/Radio-Canada will also prepare a separate answer to the Industry Canada Gazette Notice DGSO-003-14 and welcome any other C-Band users to use the same approach.

The Corporation uses 421 C-Band dishes for fixe satellite services (FSS) throughout the country. C-Band reception is required for our Radio and HDTV signal distribution. It was proven in our lab (attached), in the Alion's study ordered by the NABA (attached) and also from the ITU report that the co-existence of IMT in the 3.5 GHz band will create a very large restriction zone to avoid interference on the C-Band reception making sharing unfeasible.

The following are our comments on the RABC response:

1. In the executive summary, in bullet #4, we totally support CSSIF. It should have read ''With the exception of CSSIF and CBC/Radio-Canada...''

2. In the executive summary, in bullet #5, indeed, we are very concerned as well. Again, the band sharing between IMT and C-Band reception is not feasible, studies are attached.

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3. Page 3, first line: ...'' (...) The report discusses (...) a number of studies forecasting mobile spectrum demand.'' However, a lot of studies are saying that the mobile demand are exaggerated, 3 of those are attached. Industry Canada and the RABC should consider all studies and not only the one that are in favour of the mobile industry.

4. Q1 : CBC/Radio-Canada disagrees with the proposed answer. C-Band dishes are installed downtown in several major cities of Canada, such as Montreal, Toronto, Vancouver etc... a fast implementation will cause interruption on all C-Band reception.

5. Q3: ''Grid licensing would exacerbate the adjacent-system interference issues and need for significant separation distances'': CBC/Radio-Canada do not support ANY licensing in the 3 500 MHz band. This could preclude service deployment for future fixed satellite service (FSS) in the C-Band for the Corporation.

6. Q7: CBC/Radio-Canada disagrees with the proposed answer for the reasons listed above.

Comments from Centre de service partagé Québec (CSPQ): Nous sommes contre en appui avec Radio-Canada. Comments from Canadian Satelitte and Space Industry Forum (CSSIF): CSSIF disapproves of the proposed reallocation of the 3500 MHz spectrum due to inadequate consideration of the effects of mobile interference to sensitive C-band receive sites. CSSIF requests further evaluation and consideration of expert technical reports before reallocation be approved. Comments from the Canadian Association of Broadcasters (CAB):

1. The Canadian Association of Broadcasters (CAB) is the national voice of Canada’s private broadcasters, representing the vast majority of Canadian programming services, including private radio and television stations, networks, specialty, pay and pay-per-view services.

2. Many CAB member stations rely upon C Band satellite receive earth stations for both program acquisition and national distribution of video and audio services. In addition, C Band satellite transmission is used for reception and distribution of network programming domestically and internationally.

3. Similarly, many broadcasting distribution undertakings (BDU’s) use C Band receive earth stations to receive both domestic and international broadcast services. It is estimated that there are over 1700 C Band satellite receive earth stations in Canada.

4. Telesat has over 20 broadcast customers reliant on its C Band satellite capacity on the three Anik F satellites that serve Canada. These satellites have expected lifetimes well into the 2020s.

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5. Further, Pelmorex is responsible for the National Alert Aggregation & Dissemination System (NAADS) in Canada. Pelmorex uses C Band satellite distribution as one means to send emergency alerts to broadcast stations across the country. For some broadcast stations, C Band satellite distribution will be an effective method of creating transmitter specific emergency alerts for broadcast on repeater transmitters. In certain instances, satellite reception may be the only practical means to deliver emergency alerts to remote broadcast transmitter sites where Internet access is unavailable.

6. The North American Broadcasters Association and the World Broadcasting Union have stated opposition to re-allocation of the 3500 MHz band as co-primary for mobile services because there is a clear indication of significant adjacent interference to C Band satellite reception at 3700 MHz and above.

7. In particular, page 21 of the Alion report, commissioned by NABA, illustrates potential for interference even when the frequency separation is as great as 100 MHz. The conclusion is that large coordination zones will be required in both urban and rural environments. Hence, the co-existence of mobile services operating in the band 3475-3650 MHz is not feasible adjacent to C Band satellite reception operating in the band 3700-4200 MHz.

8. Further, earth station reception from geostationary satellites in Canada requires low elevation angles due to the high latitude at most locations. For example, the elevation angle to receive Anik F1R in Edmonton is 28.6 degrees. In Toronto, the elevation angle is as low as 15.6 degrees to receive AMC 10.

9. The CAB submits the following specific comments to the RABC response: 9.1 In bullet #4 of the Executive Summary, the CAB recommends that the wording be

changed to, “With the exception of the CAB, CSSIF and CBC/Radio-Canada…” 9.2 In bullet #5 of the Executive Summary, the CAB recommends that the wording be

changed to, “The CAB, CSSIF, and CBC/Radio-Canada disapprove of the reallocation of the 3500 MHz band due to the potential for adjacent band interference to fixed satellite operations in 3700-4200 MHz”.

9.3 Re Q1: C Band satellite transmission is used as an efficient means of one-to-many distribution of video and audio services nationally. Typical receive sites are at broadcast studios, BDU head ends in urban environments and transmitter sites in both urban and rural locations across the country. It is not practical to have different performance or protection criteria between urban or rural receive locations. The CAB recommends addition of the following sentence, “If band sharing is deemed feasible then coordination with C Band receive earth stations would require a single set of criteria”.

9.4 Re Q7; The CAB recommends that the first two paragraphs be re-worded as follows;

9.4.1. “With the exception of the CAB, the Canadian Satellite and Space Industry Forum (CSSIF), and CBC/Radio-Canada, the RABC supports the proposed fundamental reallocation of the 3500 MHz band to introduce mobile services and supports the proposed changes to the Canadian Table of Frequency Allocations.”

9.4.2. “The CAB, CSSIF and CBC/Radio-Canada disapprove of the reallocation due to the potential for adjacent band interference to fixed satellite operations in 3700- 4200 MHz.”

9.5 Re Annex C; The CAB recommends that the wording be changed as follows; 9.5.1 “With the exception of the CAB, the Canadian Satellite and Space Industry Forum

(CSSIF), and CBC/Radio-Canada, the RABC supports the allocation of mobile service as a primary service with fixed and other services in this band. The changes proposed for the Canadian Table of Frequency Allocations (Annex C) are acceptable.

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Comments from Rogers Communications: Rogers does not support the displacement of existing licensees that have satisfied the conditions of licence. In the event that Industry Canada proceeds with its proposal to displace such licensees, Rogers supports Option 2 Comments from the Canadian Electricity Association (CEA): Canadian electric utilities make use of FWA services from local service providers in rural Canada. It is important for FWA service providers to have access to suitable spectrum. 3500 MHz on a FCFS basis in 10 MHz blocks seems suitable for FWA. Furthermore it is important that service areas are defined in such a way that all sparsely populated areas are classified as rural. The application of tier 4 regions may on occasion classify large sparsely populated areas as urban due to a single city within the broader tier 4 boundary (eg 4-148). Canadian Electric Utilities make use of C-Band satellite. It is important that future 3500 MHz systems not interfere with satellite stations, particularity in rural Canada. Respectfully submitted,

Roger Poirier General Manager

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Canada Gazette Notice No. DGSO-003-14 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas

Response of the Radio Advisory Board of Canada

Executive Summary

The RABC does not support the proposal for urban/rural geographic distinctions between fixed / mobile services within Canada. We believe that it would be technically challenging to control co-frequency fixed/mobile interference without significant separation distances.

The RABC believes that Tier4 licensing is appropriate for this 3500 MHz band but we do not support the use of grid licensing. Grid licensing would exacerbate the adjacent-system interference issues and need for significant separation distances.

The RABC believes that with modern broadband technologies minimum block sizes of 10MHz and multiples of 10MHz rather than 5MHz is advisable

With the exception of the Canadian Satellite and Space Industry Forum (CSSIF) the RABC supports the proposed fundamental reallocation of the 3500 MHz band to introduce mobile services and supports the proposed changes to the Canadian Table of Frequency Allocations

CSSIF has concerns regarding the allocation due to the potential for adjacent band interference to fixed satellite operations in 3700-4200 MHz

The RABC would urge caution in major changes to licensing without having defined a bandplan

The RABC would urge Industry Canada to harmonize with continental and/or international bandplans to leverage economies of scale when redefining the band plan for mobile services via future consultations.

The RABC believes that Option 2 provides better flexibility for displacement and should be applied to all blocks. We believe that Option 2 is appropriate for both urban and rural displacements.

The Radio Advisory Board of Canada ("RABC") supports the policy objectives of Industry Canada that seek to maximize the economic and social benefits that Canadians derive from the use of the radio frequency spectrum. We understand that spectrum management practices, including licensing methods, should respond to changing technology and marketplace demands. In addition, spectrum policy and management should support the efficient functioning of markets by permitting the flexible use of spectrum to the extent possible and by making spectrum available for use in a timely fashion. With the ever expanding traffic of mobile data-based services, the Canadian mobile wireless infrastructure has an increasing demand for more mobile spectrum in all regions. The projection of an increasing demand for mobile spectrum is supported by a recent Department’s report on the Canadian Commercial Mobile Spectrum Outlook (March 2013). The Report discusses, among

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other things, a number of studies forecasting mobile spectrum demand. From these findings, the Department set out as an objective in the Report to allocate a total of 750 MHz of spectrum for commercial mobile service by 20171[1]. This includes potential new mobile spectrum in the 3500 MHz band. Mobile technology and system design/functionalities have the prospect to accommodate an increasing range of broadband wireless service offerings, from full mobility to fixed broadband wireless access. We also recognize that the Government of Canada is committed to ensuring that Canadians benefit from the availability of advanced, competitively priced telecommunications services in all regions of the country. In its Economic Action Plan 2014, the Government reaffirmed its commitment to extend and enhance broadband Internet services in rural and northern communities in order to meet the continued demand for fixed services in rural areas allocating $305M for upgrading broadband services in un-served and under-served areas. Response to Specific Questions

The RABC does not support the proposal for urban/rural geographic distinctions between fixed / mobile services within Canada. We believe that it would be technically challenging to control co-frequency fixed/mobile interference without significant separation distances. Such distance separation along all urban / rural service boundary lines represents an inefficient use of spectrum in these border zones. One study suggested separation distances in excess of 80km might be needed from the field data today. Given that the 3500 MHz band is considered in WRC-15 Agenda item 1.1 and its foreseen broad use internationally for mobile services, the RABC believes that any band plan should consider the use of mobile services on a common nationwide basis. It is envisaged that such a band plan to deal with mobile services would be developed after the WRC-15 conference and available for administrations to implement shortly thereafter.

The RABC has no comments

The RABC believes that Tier4 licensing is appropriate for this 3500 MHz band but we do not support the use of grid licensing. Grid licensing would exacerbate the adjacent-system interference issues and need for significant separation distances.

1[1] Commercial Mobile Spectrum Outlook (http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09445.html)

Section 3.1, last para.: “While a precise estimate on future spectrum demands may be difficult to identify, the overall direction is clear: given current trends, additional spectrum will need to be allocated to commercial mobile services to support future requirements. As a result, Industry Canada has set an objective of allocating a total of 750 MHz of spectrum to commercial mobile services by 2017. This objective recognizes that the wireless sector must remain innovative and find ways to increase spectrum use efficiency, while at the same time acknowledging that Canada must increase the overall supply of spectrum for these services.”

Q3: Industry Canada invites comments on these licences being issued as annual spectrum licences, defined on a per grid-cell basis and authorized only for the amount of spectrum required to operate

Q2: Industry Canada invites comments on its proposal to make available spectrum licences in tier areas classified as rural, through a first-come, first-served process.

Q1: Industry Canada invites comments on its proposal to classify Tier 4 service areas as either urban or rural for the band 3475-3650 MHz, using Statistics Canada’s 2011 definition for population centres, as outlined in Annex A.

Page 7 of 8

We recognize that the move away from grid licencing may have impact on deployment rollout performance requirements. The RABC believes that with modern broadband technologies minimum block sizes of 10MHz and multiples of 10MHz rather than 5MHz is advisable. As a consequence the current band plan with 25MHz blocks is inconsistent with this 10MHz block size and would lead to inefficiencies in spectrum usage.




With the exception of the Canadian Satellite and Space Industry Forum (CSSIF), the RABC supports the proposed fundamental reallocation of the 3500 MHz band to introduce mobile services and supports the proposed changes to the Canadian Table of Frequency Allocations. The CSSIF has concerns regarding the allocation due to the potential for adjacent band interference to fixed satellite operations in 3700-4200 MHz. We note that the specific mobile service band edges may be a topic for regional and global spectrum planning dialog over the next two years and also a topic for WRC-15. Canada National Organization (CNO) has recently approved a Canadian position to allocate mobile service in this band “In order to promote globally harmonized spectrum for IMT, thereby enabling economies of scale and encouraging efficient use of spectrum, Canada proposes a Mobile Service (MS) allocation in the range 3 400-3 500 MHz and an IMT identification in the range 3 500-3 700 MHz” (the document has been approved by the CPC for submission to the CITEL meeting (Merida city, Mexico from 29th Sep – 3rd Oct 2014). The RABC would urge Industry Canada to harmonize with continental and/or international bandplans to leverage economies of scale when redefining the band plan for mobile services via future consultations. We would urge caution in major changes to licensing without having defined a bandplan.

Q7: Industry Canada invites comments on its proposal to fundamentally reallocate the 3500 MHz band (3475-3650 MHz) to include mobile services and its proposed changes to the Canadian Table of Frequency Allocations as found in Annex C.

Q6: Industry Canada invites comments on the conditions of licence in Annex B.

Q5: Industry Canada invites comments on its proposal to have the transition policy described in section 4 of Annex B apply to all FWA systems (i.e. existing FCFS and auctioned FWA systems as listed in (v) and (vi)) within rural tiers.

Q4: Industry Canada invites comments on its proposal to modify the current notification period for existing point-to-point, fixed stations such that those affecting the implementation of new FWA systems in rural Tier 4 areas would now be afforded a notification period of six months.

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As per our comments to Question 1, we have spectrum efficiency concerns with the suggested rural / urban fixed / mobile split. We recommend that a future national band plan address mobile needs in concert with international developments.

The RABC believes that Option 2 provides better flexibility for displacement and should be applied to all blocks. We believe that Option 2 is appropriate for both urban and rural displacements.



The RABC supports the allocation of mobile service as a primary service with fixed and other services in this band. The changes proposed for the Canadian Table of Frequency Allocations (Annex C) are acceptable.

Annex C Proposed Changes to Canadian Table of Frequency Allocations for the 3500 MHz Band

Annex B

Annex A

Q9: Industry Canada invites comments on its two proposed options for displacement.

Q8: Industry Canada invites comments on its geographically differentiated policy where mobile services will be allowed in urban tiers, and fixed services will be allowed in rural tiers (refer to Section 6 for the definition of urban and rural tiers).

Consultation Comments

Regarding: Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and

a New Licensing Process in Rural Areas

DGSO-003-14

Prepared: 07 October 2014

By: Kayle Tjomsaas | President

RhiCom Networks Inc. | 158 Victoria Street Kamloops, BC V2C 1Z7 | 250.434.8590 | www.rhicom.ca

Page 1 of 6

RhiCom Background Information

RhiCom Networks is a high speed Internet service provider covering nearly a quarter million British

Columbians from Kelowna to Prince Rupert. Our current ability to deliver services is directly related to the

sub-licences we hold in the 3500 MHz band.

Our story starts in 2010 when we were established as a subsidiary of Navigata Communications 2009, Inc.

Under our parent company’s ownership, RhiCom spent nearly three full years of research and development

concerning our core network, business operations environment, and business policy. The first three years

were critical to ensuring that we could build a viable and sustainable business around fixed wireless access.

In the last year, RhiCom has shifted from a development business to a sales business and has focussed

spending efforts on sales and marketing.

RhiCom’s survivability is highly dependant on licenced spectrum compatible with our currently deployed

radio assets.


Page 2 of 6

Consultation Comments

Section 6, Paragraph 21 & 22 The idea of defining a single spectrum band for two uses in two market types (fixed versus mobile and rural

versus urban) does not consider the fact that many 3500 MHz Canadian certified equipment types are

compatible with both mobile and fixed service applications. Specifically, equipment that is TD-LTE.

RhiCom suggests that a portion of the 175 MHz band plan be defined as mobile so that existing operators in

compliance can continue to utilise their fixed licence holdings. It would be prefered if Industry Canada was to

consider a spectrum based separation instead of a geographic based separation. This separation model

would also help to avoid spectrum interference across the band.

Section 6, Paragraph 23 & 24 RhiCom does not understand the need to classify urban and rural communities separately. The reality of the

classification scheme proposed by Industry Canada does not appear to reflect rural or urban living

accurately. Many of the Tier 4 blocks identified as being urban (based on the proposed 30,000 population

centre model) have a significant rural surround for which RhiCom currently delivers service to.

Current incumbent service providers in some of RhiCom’s trading areas do not fully extend to the

boundaries of the proposed definition of urban services. Or, where they do, the service could be considered

substandard.

Under the proposed changes, RhiCom would lose three of its four sub-licence holdings which would result in

the discontinuation of services to existing customers and would effectively cripple RhiCom’s business. The

immediate effects of the changes for the communities RhiCom serves would be loss of service where we are

the only terrestrial provider, the loss of competition, and the loss of employment for RhiCom’s staff.

RhiCom suggests that Industry Canada consider not to classify communities as rural and urban but rather

maintain a single market classification of Tier-4 blocks.

Section 7, Paragraph 30 Creating a grid cell licencing scheme does not seem to represent the realities of RhiCom’s operations.

RhiCom currently uses its licenced spectrum to broadcast and backhaul services to and from sites.

Managing individual grids will create a serious limitation in RhiCom’s ability to effectively deliver services

and will likely result in a great deal of difficulty managing cross cell interference from other service providers.

It is RhiCom’s opinion that a grid cell scheme is not necessary and adds a significant amount of logistic work

and technical complexity to an otherwise simple deployment.

Section 7, Comment 2 & 3 RhiCom feels that a first come, first serve process is not best suited for the spectrum band. It is a preference

of RhiCom that the current auction mechanism remain in place and that the auction be held for the entire

current Tier 4 boundaries. However, in the event a licence holder does not begin deployment in a defined

time, the licence should expire and be released for another operator to purchase.


Page 3 of 6

Holding annual auctions for the 3500 MHz band’s unused spectrum would provide access to carriers as they

expand their networks and would help to ensure spectrum does not go unused for extended periods.

Annual licence renewals provide no certainty to business. Without being afforded long term licences (10

years, for example), licence holders are not able to reliably forecast business decisions with a constant

possibility that licence holdings could be recalled. This could be perceived as a liability and may work

against service providers who are trying to obtain capital financing.

Aside from the added potential threat to a telecom business’ ability to serve its customers, having an annual

licence scheme creates an additional, unnecessary amount of paperwork/filing for both the business and

Industry Canada increasing cost and the potential for errors.

Section 7.3, General Comments RhiCom would request that Industry Canada consider moving the current band plan to a more efficient,

international (non-USA), TDD model over a transition period. Such a move would promote greater use of

TD-LTE hardware in the 3500 MHz spectrum and would better align Canada to internationally available

equipment.

Section 8, Comment 7 & 8 The reallocation to include mobility is a good thing;; however, it is extremely important that service providers

who are in compliance with their current licences are not stripped of their ability to continue to serve their

customers in their Tier 4 trading areas with the equipment they currently have deployed.

In respect to assigning mobility licences to urban centres and fixed licences to rural centres, RhiCom, again,

believes that it is better to instead create a spectrum based separation instead of a geographic based

separation. Spectrum based separation would allow operators to acquire the spectrum specific for their

business needs (mobility versus fixed).

Section 9.1, Paragraph 59 RhiCom strongly disagrees with the proposed reallocation method by which Industry Canada would have

licensees return, not renew, existing licence holdings. This process will have a detrimental and immediate

affect on RhiCom’s ability to continue as a business because its entire sustainability is based on the 3500

MHz spectrum it currently uses.

As previously noted, it is extremely important to the survivability of small service providers that those in

compliance of their licences are afforded an ability to continue using them without the threat of loss.

It is essential for Industry Canada to recognise that by recalling spectrum, service providers are likely to

have to redeploy equipment in the event they are not re-awarded the spectrum they previously had.

When preparing business and network planning, RhiCom uses a three to five year amortization model for its

assets. Given that most of RhiCom’s network is brand new (since January 2014) and in compliance with

current rules, there does not appear to be consideration to the time it takes for assets to clear their return on


Page 4 of 6

investment (ROI) period. RhiCom considers ROI to be achieved if its wireless hardware assets are in service

for a minimum of three years.

Writing off the currently deployed equipment will literally cost RhiCom hundreds of thousands of dollars.


Page 5 of 6

RhiCom Summary Comments

The four key points RhiCom considers most important through this consultation process are:

1. Not recalling, but instead renewing all licences in compliance;;

2. Non cell-based licencing - the licencing model should remain as is;;

3. Providing the security of long term licence periods (10 years);; AND

4. No geographic/market separation between urban and rural and defined by the proposal.

RhiCom feels that if these four key points are met, Industry Canada will be supporting the sustainability of

small service providers while providing Canadian consumers with continued access to the services they

currently use.

Future development use of the spectrum should include an ability for service providers to pay to convert

their licences from fixed to mobility and a new band plan to incorporate an international TDD model for better

access to commercially available hardware, especially TD-LTE.


Page 6 of 6

1

October 6, 2014

Senior Director, Spectrum Development and Operations

Industry Canada

300 Slater Street (JETN, 15th)

Ottawa, ON K1A 0A5

Email: [email protected]

Re: Canada Gazette, Part I, August 19, 2014, DGSO-003-14 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas

1. I am writing in response to the Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas, DGSO-003-14, dated August 19, 2014 (the “Consultation Paper”). In

particular I am writing to share my concerns about the potential impact of the

proposed changes on rural Internet service.

Background

2. I am a former shareholder and former Managing Director of the Brockville,

Ontario based rural Internet Service Provider known as RipNET Limited

(“RipNET”).

3. RipNET was a pioneer in the use of spectrum in the 3500MHz band to provide

high speed Internet service to rural Canadians. Our primary service area was

the United Counties of Leeds and Grenville (“United Counties”) but we also

served rural residents living in surrounding counties in Eastern Ontario.

4. Initially RipNET was awarded licenses on a first come, first served basis

(“FCFS”). Subsequently, in 2004, RipNET successfully bid on several licenses

in the initial auction of 3500 spectrum. RipNET used its frequencies as the

basis for building one of Canada’s first 3500MHz wireless networks. As a

result of our investment, and our risk taking, the United Counties was one of

the first rural areas in Canada to receive high-speed wireless Internet service.

That was in 2004.

5. Over the next few years, as other companies activated 3500MHz frequencies

in the region, we experienced first hand some of the problems associated with

2

so-called “urban” licenses and “rural” licenses. Those experiences are what

prompt me to intervene in this consultation. My partners and I sold RipNET in

2011 but I believe our experiences are relevant to the current proceedings.

Consultation Paper Questions

6. Specifically I would like to comment on Questions 1, 7 & 8 in the Consultation

Paper.

1. Industry Canada invites comments on its proposal to classify Tier 4 service areas as either urban or rural for the band 3475-3650 MHz, using Statistics Canada’s 2011 definition for population centres, as outlined in Annex A. 7. Industry Canada invites comments on its proposal to fundamentally reallocate the 3500 MHz band (3475-3650 MHz) to include mobile services and its proposed changes to the Canadian Table of Frequency Allocations as found in Annex C.

8. Industry Canada invites comments on its geographically differentiated policy where mobile services will be allowed in urban tiers, and fixed services will be allowed in rural tiers (refer to Section 6 for the definition of urban and rural tiers).

Comments

7. The stated policy objective is to extend and enhance high-speed Internet

services in rural and northern communities. At Paragraph 6, the Consultation

Paper states:

“The Government of Canada is committed to ensuring that Canadians benefit from the availability of advanced, competitively priced telecommunications services in all regions of the country. In its Economic Action Plan 2014, the Government reaffirmed its commitment to extend and enhance broadband Internet services in rural and northern communities in order to meet the continued demand for fixed services in rural areas.”

8. It is hard to see how the proposed changes could achieve this objective. Just

the opposite, the changes would put both existing and future wireless high-

speed Internet service to rural and northern areas at risk.

9. The proposals, as drafted, would claw back spectrum that is currently being

used to provide high-speed Internet service to rural Canadians. The

spectrum clawed back would then be re-allocated for “urban” mobile

telephone use. How can anyone see that as benefiting rural Canada? It

would be a step backwards for rural Canadians and contrary to the stated

goal of increasing high-speed Internet access for Canadians living in rural

areas.

10. The proposed reclassification of licensed areas would designate huge tracts of

what are now rural areas as “urban” areas. The proposal then calls for re-

classified “urban” licenses to be clawed back from rural Internet Service

Providers (ISPs) even though at least some of the licenses are active and

being used to provide high-speed Internet service to people today.

3

11. I shudder to think of the impact this would have had on my partners and I as

owners of RipNET. Under the proposals, communities surrounding Brockville

and the United Counties would be re-defined as urban. Significant portions of

the licensed RipNET service area would be clawed back for mobile telephone

use in those urban communities.

12. This would have denied high-speed Internet service to hundreds of RipNET

customers. It would have jeopardized the future viability of the company.

13. The proposed claw back is only part of the problem. Spectrum coverage

doesn’t have fixed end points. The coverage area of spectrum that would be

reclassified as “urban” won’t end at city limits. The coverage will extend well

into adjacent “rural” areas. The result will be an unusable overlapping zone

of interference.

14. In our experience the interference zone typically extends an hour driving

distance from the urban area. Frequency coordination can mitigate the issue.

But it is time consuming and expensive. It’s frustrating to the wireless

customers who can no longer depend on their wireless ISP for reliable service.

More significantly, based on our frequency coordination experiences with

RipNET, you cannot eliminate the interference. For rural residents, wireless is

often their only high-speed option and the interference from the reclassified

“urban” spectrum will render fixed wireless useless for many of them.

15. It was independent entrepreneurs like RipNET who brought Internet services

to rural Canada. My partners and I took the financial risks to build a wireless

network to bring high-speed Internet service to rural Eastern Ontario where

the density of population is low while the major ISPs like Bell and Rogers

focused on more profitable high-density urban centers. It makes the current

proposals all the more galling because those same companies – Rogers and

Bell – would be major beneficiaries of the claw back. Rogers and Bell are, of

course, major mobile operators. They are also partners in Inukshuk, a

company that is one of the single largest holders of 3.5MHz spectrum.

16. The proposal to re-classify huge tracts of rural Canada as “urban” will

inevitably jeopardize the future of rural ISPs and high-speed rural Internet

services. It certainly will not benefit “all regions of the country”, the stated

policy objective of the consultation.

17. I am shocked that the Government of Canada would put forward proposals

that would discriminate against incumbent rural ISPs to the benefit of

companies that for so many years ignored the Internet needs of rural

Canadians.

18. I oppose the proposals on the grounds that they would negatively impact

rural ISPs and rural Internet service.

19. These proposals fly in the face of the federal government’s commitment “to extend and enhance broadband Internet services in rural and northern communities in order to meet the continued demand for fixed services in rural areas.”

20. These proposals will reduce broadband service to rural Canada.

4

21. The Minister and Industry Canada should reject the proposals in the

Consultation Paper because they are fundamentally flawed.

Respectfully submitted by

Eric Rothschild

President

Robert Hersche Senior Director of Regulatory Affairs

2121 Saskatchewan Drive Regina, Saskatchewan S4P 3Y2

Telephone: (306) 777-5346 Fax: (306) 565-6216 Electronic Fax: (306) 791-1457 Internet: [email protected]

October 8, 2014 via E-mail

Lynne Fancy Senior Director Spectrum Development and Operations Industry Canada 300 Slater Street (JETN, 15th) Ottawa, ON K1A 0H5 Dear Ms. Fancy: Re: Gazette Notice No. DGSO-003-14 – Consultation on Policy Changes in the 3500

MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas Attached are the Comments of Saskatchewan Telecommunications (SaskTel), in response to the Canada Gazette notice regarding the above referenced consultation.

SaskTel thanks the Department for this opportunity to provide comments and input into the consultation process.

Sincerely,

Robert Hersche Senior Director of Regulatory Affairs AM/nb Attachment

Page 1

This document has been developed by SaskTel and has been submitted to Industry Canada as part of the consultation process of Gazette Notice DGSO-003-14 “Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas” The document is to remain in its entirety and at all times the property of SaskTel.

SaskTel Comments:

Gazette Notice DGSO-003-14

Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a

New Licensing Process in Rural Areas

October 8, 2014

Page 2


EXECUTIVE SUMMARY

1. The following represents a summary of SaskTel’s Comments in response to DGSO-

003-14, Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and

a New Licensing Process in Rural Areas.

2. SaskTel continues to urge Industry Canada to re-examine its spectrum policy to allow

the most effective and efficient use of spectrum for consumers, especially in rural

areas. In the best cases this involves a balance between meeting urban and rural

needs, and in the worst case this sometimes requires making a choice between the

priorities of urban versus rural uses.

3. As importantly SaskTel believes that spectrum policy requires the flexibility to

distinguish between the different definitions of rural in different parts of the country.

Residents in cottage country in Ontario may have different needs than more widely

dispersed population found in Saskatchewan.

4. In the case of the 3500 MHz consultation, Industry Canada places a clear priority on

the deployment of urban mobile services in this band, as demand for wireless

broadband capacity in urban areas (Tier 4 license areas with a population centre of

over 30,000) is expected to be very high as traffic is growing at exponential rates.

SaskTel foresees a microcell or picocell type deployment in this band in urban areas,

and over time this could develop into a critical band to meet growing wireless

broadband demand. SaskTel supports the department’s placement of a high priority

on urban mobile services in this band, and of putting policies in place to allow for the

future development of a band plan to support urban mobile services that is

harmonized with other international jurisdictions.

5. SaskTel also supports the Department’s attempt to make the best use of the 3500

MHz band spectrum in rural areas through the proposed policy to allow deployment of

fixed wireless access (FWA) systems on a first-come first-served (FCFS) basis. By

issuing licences with service areas defined by spectrum grid cells based on expected

coverage, strict short term deployment deadlines of six months, and authorized

bandwidths based on current needs and deployment only, it is envisioned that only

Page 3


operators with firm service plans and network designs will apply for licences, and

spectrum speculation and hoarding will be reduced or eliminated in this band.

6. However, SaskTel strongly cautions that implementation of grid-cell based licensing

for rural Tier 4 FWA systems must be accompanied by clearly defined and

established policies, processes, and procedures to ensure there is no interference

between urban mobile systems and rural FWA systems, as well as between rural

FWA systems. This includes the use of proper guard bands and sufficient separation

distances as required. SaskTel has serious concerns on this matter, and believes

that a grid-cell based licensing framework can only work if clear interference

prevention measures are included as part of the grid-cell based licence approvals.

Not having a plan to mitigate interference in place during and after the licence

application and approval stages would likely mean the spectrum will not be utilized

effectively for rural FWA, if at all.

7. SaskTel agrees in principal with the proposed definition of urban and rural Tier 4

service areas for the 3500 MHz band that are based on the presence of a population

centre of 30,000 in the Tier 4 service area. SaskTel strongly believes however that

population centres of 10,000 or more also need to be designated as urban centres for

spectrum policy matters to ensure these centres can also fully benefit from

deployment of the spectrum. SaskTel therefore recommends that Tier 4 service

areas with population centres greater than 10,000 should be designated as urban

service areas.

8. SaskTel agrees with the proposed fundamental reallocation of the 3500 MHz to

mobile, in concert with developments in this band internationally. Efforts are being

made to harmonize this band globally for mobile services, and Canada cannot afford

to be left behind. SaskTel urges the Department to fully consider all band plans and

spectrum policies being developed internationally to ensure Canadians benefit from

this harmonization.

9. In order to facilitate the introduction of mobile services in this band, a fundamental

reallocation, it is recognized that existing fixed systems will be impacted to ensure

deployment of urban mobile systems. SaskTel agrees with the proposed transition

Page 4


policies and time frames for incumbent fixed systems in urban and rural Tier 4 service

areas.

10. Industry Canada proposed two displacement options for incumbent fixed systems in

urban Tier 4 service areas. SaskTel believes Option 2 is more appropriate, as it

allows for priority deployment of urban mobile systems, but displacements of existing

systems only as required, minimizing the impact of the displacements as much as

possible.

Page 5


INTRODUCTION

11. The following represent Saskatchewan Telecommunications’ (“SaskTel’s”) Comments

in response to DGSO-003-014, Consultation on Policy Changes in the 3500 MHz

Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (“the

Consultation”).

12. The section numbering of the remainder of this document corresponds to the

numbering of the consultation paper released by the Department. Failure to address

any particular issue or item, or the Comments made by any other party, should not be

construed as agreement with those Comments where such agreement is not in the

interests of SaskTel.

SASKTEL RESPONSE TO THE CONSULTATION

6. Proposed New Classification of Tier 4 Service Areas – Rural vs. Urban

1. Industry Canada invites comments on its proposal to classify Tier 4 service

areas as either urban or rural for the band 3475-3650 MHz, using Statistics Canada’s 2011 definition for population centres, as outlined in Annex A [of the consultation].

13. SaskTel agrees with the intent of the Department to classify regions and spectrum as

urban or rural, based on the population of major centres. In many cases there needs

to be separate spectrum policies and requirements for urban and rural communities to

ensure effective utilization of scarce spectrum resources to the full benefit of all

Canadians, both urban and rural. In the past spectrum policies have tended to focus

more on urban requirements, and SaskTel commends the Department for taking the

steps to identify spectrum as urban or rural, and impose unique spectrum policies and

requirements for rural Canada.

14. In the consultation Industry Canada has proposed to use Tier 4 service areas for

licensing the 3475-3650 MHz band, and classifying the Tier 4 service area as either

urban or rural. A Tier 4 is proposed to be classified as urban if the service area

includes a major population centre greater than 30,000, based on Statistics Canada

Page 6


2011 Census population figures, as well as the typical propagation characteristics and

expected deployment of mobile services at 3500 MHz.1

15. SaskTel agrees in principal with the proposed use of Tier 4 service areas for licensing

the 3475-3650 MHz band. SaskTel believes that population centres greater than

10,000 also need to be considered as urban centres. Different parts of Canada have

different needs in smaller population centres. For example residents in cottage

country in Ontario will have different needs than more widely dispersed populations

found in Saskatchewan. The population densities in communities over 10,000 do

justify urban wireless deployments, and those living in these communities deserve to

benefit from deployment of urban networks.

16. Therefore SaskTel recommends that Tier 4 service areas with population centres

greater than 10,000 should be classified as urban service areas.

17. Although still being developed, SaskTel believes that 3500 MHz mobile services will

likely be deployed in short range microcell or even picocell type deployments, in

relatively dense population centres, to serve the urban population and/or as one

means to meet customer demand for bandwidth for existing wireless networks. We

do not foresee extensive deployments of 3500 MHz mobile systems in centres with

populations less than 10,000.

7. FWA in Rural Areas

7.1 Proposed Licensing Process for FWA in Rural Tiers

2. Industry Canada invites comments on its proposal to make available

spectrum licences in tier areas classified as rural, through a first-come, first-served process.

18. SaskTel agrees with the proposal to license the 3475-3650 MHz rural Tier 4 licence

areas using a first-come first-served (FCFS) process, with the expectation that a strict

six month deployment requirement will be imposed on licensees to ensure licenses

issued in this process are deployed in a timely manner, as stated in the Proposed

1 More details are found in Section 6, paragraphs 19-26, as well as Annex A, of the Consultation.

Page 7


Conditions of Licence.2 SaskTel believes that a timeframe of six months for licence

holders to complete their deployment and provide service to the licensed area is not

an unreasonable time frame, assuming the network service provider has completed

their planning and design work, and is ready to begin installation work when the

licence is actually issued.

19. It is envisioned that with the short time frames for deployment, combined with the

FCFS process, only service providers with firm plans for serving a given rural area will

actually apply and receive licenses. This should ensure the spectrum is utilized as

efficiently as possible because it will prevent spectrum speculation and hoarding.

20. Furthermore, SaskTel recommends that the initial licence term be only six months,

rather than one year, providing the service provider the incentive to ensure

deployment is completed in a timely manner. Once the system is deployed, the

licence term can of course be extended to one year terms. Failure to complete

deployment can result in the licence expiring and potentially then becoming available

to other providers wishing to deploy, and not remaining idle.

3. Industry Canada invites comments on these licences being issued as

annual spectrum licences, defined on a per grid-cell basis and authorized only for the amount of spectrum required to operate (refer to Section 7.3).

21. SaskTel agrees in principal with the proposal to issue annual spectrum licences

defined on a per grid-cell basis for the 3475-3650 MHz band in designated rural Tier 4

service areas, with authorizations only for the amount of spectrum required to provide

service.

22. However, SaskTel has very serious concerns about interference issues between

adjacent systems, both co-channel in adjacent grid cells and adjacent channel in the

same area. The consultation document does not discuss at all how Industry Canada

proposes to manage interference and coordination issues amongst operators.

Although there is a vague statement that “approval may be limited by other

deployments in the area”,3 no guidelines, restrictions, conditions, or considerations

2 Consultation Section 7.4 paragraph 43, and Annex B 3 Consultation, section 7.1, paragraph 31

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are discussed regarding interference mitigation between existing and future

operators. There are no proposed procedures to ensure licence approvals will not

adversely affect other licensed systems, either co-channel in adjacent areas, or within

the licence area on adjacent spectrum.

23. Grid-cell licensing will work for a small number of isolated deployments, but

deployments are expected to be concentrated in and near larger communities, and

clear guidelines need to be established to ensure each operator can effectively deploy

and operate their proposed system without harmful interference.

24. Furthermore, the larger established wireless service providers have staff and

expertise to properly conduct interference coordination, and troubleshooting

interference issues as they arise. SaskTel has significant concerns that the small

rural operators expected to deploy FWA systems under this licensing regime will not

have the skills or expertise to properly coordinate and manage their network

installations, resulting in a high potential for interference to other systems.

25. Should Industry Canada decide to implement a grid-cell based authorization scheme,

SaskTel strongly recommends that Industry Canada clearly outline the proposed

approval processes and coordination procedures that will be followed by Industry

Canada and all licensees to ensure interference issues are mitigated and properly

managed. This will have to include guard bands and/or separation distances between

networks to prevent degradation in network performance from interference.

26. SaskTel also agrees with the proposal from Industry Canada to only grant the amount

of spectrum bandwidth required to provide service, as per paragraphs 30 and 41 of

the Consultation. This will not only maximize efficient utilization of the spectrum, it

could minimize the impacts to existing licensees of potential upcoming band plan

changes.

7.2 Treatment of Incumbents in Rural Tier Areas

4. Industry Canada invites comments on its proposal to modify the current

notification period for existing point-to-point, fixed stations such that those affecting the implementation of new FWA systems in rural Tier 4 areas would now be afforded a notification period of six months.

Page 9


27. SaskTel agrees with the proposal.

5. Industry Canada invites comments on its proposal to have the transition

policy described in section 4 of Annex B apply to all FWA systems (i.e. existing FCFS and auctioned FWA systems as listed in (v) and (vi)) within rural tiers.

28. SaskTel agrees with the proposal.

7.4 Proposed Conditions of Licence for Existing and New FCFS FWA Licences

6. Industry Canada invites comments on the conditions of licence in Annex B. 29. SaskTel agrees with the proposed conditions of licence given in Annex B of the

consultation.

8. Proposed Fundamental Reallocation of the 3500 MHz Band

7. Industry Canada invites comments on its proposal to fundamentally

reallocate the 3500 MHz band (3475-3650 MHz) to include mobile services and its proposed changes to the Canadian Table of Frequency Allocations as found in Annex C [of the consultation].

30. SaskTel agrees with the Industry Canada proposal to fundamentally reallocate the

3475-3650 MHz band to include mobile services, and we agree with the proposed

changes to the Canadian Table of Frequency Allocations as given in Annex C of the

Consultation.

31. Internationally there are ongoing efforts to make the 3500 MHz band a global mobile

band. SaskTel commends the Department for placing a high priority on implementing

mobile systems in urban areas in this spectrum, which will in the upcoming years

become very important to relieve network congestion and capacity issues in urban

and metropolitan areas.

32. SaskTel notes the considerable international band plan and technical discussions

regarding mobile use of the 3500 MHz band, including upcoming discussions at the

ITU WRC-15 conference. SaskTel urges Industry Canada to consider harmonizing

Page 10


the Canadian band plan and technical requirements as much as possible with North

American and/or international band plans to take advantage of economies of scale

surrounding any equipment manufacturing.4

8. Industry Canada invites comments on its geographically differentiated

policy where mobile services will be allowed in urban tiers, and fixed services will be allowed in rural tiers (refer to Section 6 [of the consultation] 9for the definition of urban and rural tiers).

33. SaskTel agrees with the geographically differentiated policy allowing priority for high

demand mobile services in urban tiers, and fixed services in rural tiers. The short

range propagation characteristics of this spectrum will only allow economical mobile

deployments in urban areas, and SaskTel does not expect any mobile systems to be

deployed in rural areas.

34. Rural areas are underserved with broadband services, and it is important that

spectrum such as the 3500 MHz band be made available for fixed wireless access

(FWA) to allow rural residents to benefit from wireless broadband services. To do

otherwise would allow the spectrum be wasted in rural areas.

35. As stated before, SaskTel does have concerns that efforts need to be taken to ensure

that potential interference issues between fixed and mobile systems, as well as

between adjacent FWA systems deployed by different operators, are either avoided

or mitigated through established practices and guidelines, including guard bands,

separation distances, and coordination procedures between service providers. The

implementation of effective guidelines is critical to prevent interference and to ensure

the spectrum is efficiently utilized.

36. SaskTel recommends that Industry Canada include in a future consultation specific

proposals with procedure and guidelines to allow efficient implementation of both

fixed and mobile systems in the band.

4 Consultation, paragraph 53

Page 11


9. Treatment of Incumbent Licensees in Urban Tier 4 Areas Following a Proposed Fundamental Reallocation of the 3500 MHz Band

9.2 Options for Displacement

9. Industry Canada invites comments on its two proposed options for

displacement. 37. Industry Canada has proposed two options for displacement of incumbent licensees.

Option 1 provides a one year notification upon release of the future new licensing

framework and band plan. Option 2 allows for the displacement of existing licensees

in urban tiers only, and only as required, after commercial mobile licences are issued.

Incumbent licensees would have one year to transition once notified.

38. SaskTel recommends that the Department implement Option 2 for the displacement

of incumbent licensees. Considering the fact that the priority established by the

Department is for urban mobile systems, SaskTel does not see an urgent need to

transition rural incumbent licensees. Therefore, Option 2 is the better choice. Option

2 would seem to have the least impact on rural residents, while still allowing for the

timely deployment of urban mobile systems as this technology and ecosystem

develops.

CONCLUSION

39. Consumers demand for bandwidth continues to grow, and the need to increase

mobile wireless network capacity to meet this growing demand creates the need for

both new sites and more spectrum. SaskTel commends the Department for placing a

high priority on urban mobile systems for this spectrum, in step with international

efforts to make the 3500 MHz band as much as possible a global mobile band.

SaskTel sees the 3500 MHz band providing critical relief for network capacity issues

by allowing deployment of microcell type architectures in urban areas.

40. SaskTel also supports the Department’s proposals to allow the use of fixed FWA

systems in rural areas to provide wireless broadband to underserved areas. This not

only allows rural residents to benefit from the utilization of this spectrum, it also allows

for more efficient use of the band and avoids the spectrum from laying fallow in rural

areas.

Page 12


41. The proposed use of grid-cell based first-come first-served (FCFS) licensing, with

authorized bandwidth limited to that necessary to provide service, will help ensure

efficient utilization of the spectrum by allowing different operators to serve different

regions. Imposing a strict short term deployment requirement of six months will

ensure only licensees with solid plans to provide service will apply for a licence.

42. However, mixing dissimilar fixed and mobile technologies and services in the same

spectrum can introduce serious interference issues if not properly managed. Well

established licence approval processes, with procedures and guidelines to prevent

and mitigate interference, including guard bands and separation distances as

required, are essential to ensure that network operators can effectively deploy

networks without interference. Although SaskTel is in agreement with the FCFS grid-

cell based licensing, we are very concerned that the Consultation did not discuss

interference mitigation, an essential mechanism to ensure proper deployment.

43. SaskTel agrees in principal with the proposed urban / rural designation of Tier 4

service areas for the 3500 MHz band, using the presence of a population centre of

30,000 or more in a Tier 4 area to define the area as urban. SaskTel recommends

however that the urban / rural Tier 4 designation be based instead on the presence of

a population centre greater than 10,000. SaskTel believes it is advantageous for

major centres over 10,000 population to be treated as urban.

44. SaskTel agrees with the proposed transition policy and notification periods for

incumbent fixed systems in rural Tier 4 areas. For incumbent licensees in urban Tier

4 areas, SaskTel believes the Option 2 displacement policy proposed by Industry

Canada is the better choice that allows for displacement of existing systems only as

necessary, likely resulting in the least impact to rural FWA systems.

45. SaskTel thanks the Department for the opportunity to provide input into these crucial

matters. It is our hope that our comments will assist in a fuller view of the

requirements for this spectrum in all regions of Canada.

October 8, 2014 Senior Director Spectrum Development and Operations Industry Canada 300 Slater St. (JETN 15th) Ottawa ON K1A 0H5 Via e-mail: [email protected]

Re: Canada Gazette, Part 1, September 6, 2014, Notice No. DGSO-003-14 — Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas

Dear Sir/Madam:

The Satellite Industry Association (“SIA”)1 hereby submits these comments to Notice No. DGSO-003-14, Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (“the Consultation”). In particular, SIA addresses Question 7 of the Consultation, which invites comment on the proposal to reallocate the 3475-3650 MHz band to include mobile services, and to make consequential changes to the Canadian Table of Frequency Allocations. 1 SIA is a U.S.-based trade association providing worldwide representation of the leading satellite operators, service providers, manufacturers, launch services providers, and ground equipment suppliers. Many SIA members conduct business in Canada. SIA Executive Members include: The Boeing Company; The DIRECTV Group; EchoStar Corporation; Harris CapRock Communications; Intelsat S.A.; Iridium Communications Inc.; Kratos Defense & Security Solutions; LightSquared; Lockheed Martin Corporation; Northrop Grumman Corporation; SES Americom, Inc.; and SSL. SIA Associate Members include: Airbus DS SatCom Government, Inc.; Artel, LLC; ATK Inc.; Cisco; Cobham SATCOM Land Systems; Comtech EF Data Corp.; DigitalGlobe, Inc.; DRS Technologies, Inc.; Encompass Government Solutions; Eutelsat America Corp.; Globecomm Systems, Inc.; Glowlink Communications Technology, Inc.; iDirect Government Technologies; Inmarsat, Inc.; Exelis, Inc.; Marshall Communications Corporation.; MTN Government; NewSat America, Inc.; O3b Limited; Orbital Sciences Corporation; Panasonic Avionics Corporation; Raytheon Space and Airborne Systems; Row 44, Inc.; TeleCommunication Systems, Inc.; Telesat Canada; TrustComm, Inc.; Ultisat, Inc.; Vencore Inc.; ViaSat, Inc., and XTAR, LLC.


The Consultation and the documents referred to therein are lacking in factual basis and

technical analysis. For example, the demand for more spectrum for mobile services is assumed, rather than examined. The Consultation refers to the March 2013 Commercial Mobile Spectrum Outlook2 and to requests from mobile service licensees (or entities with corporate links to such licensees),3 but omits mention of studies that show that future mobile spectrum requirements have been overestimated and that spectrum already allocated for mobile services has not yet been fully utilized.4 These studies also warrant proper consideration by Industry Canada, and should inform the decisions being made.

SIA recognizes that frequency allocation tables must be living documents, adjusted periodically as technology evolves. However, the changes envisioned in the Consultation are premature. Before any fundamental changes are made, certain logically antecedent issues must be addressed. For example:

Does available data support allocation of additional bandwidth for a service? Is such data available from a source that does not stand to directly benefit from, or be

adversely affected by, the proposed change? Can any negative effect on other services due to the change be satisfactorily mitigated?

If so, what is the proposed technical framework that will permit such mitigation?

A decision to add an allocation to the frequency allocation table must be supported with appropriate technical analysis of how existing services in a band or in adjacent bands would be affected by a new service, and how the incumbents can be properly protected. In this case, while there are relatively few co-frequency earth stations in the 3500 MHz band in Canada or in the neighboring United States, the method by which these stations will be protected from mobile interference must first be considered and established.

Industry Canada itself has previously concluded that “[s]haring between mobile base stations or subscriber terminals and FSS earth stations would be very difficult.”5 This is

2 Industry Canada, Commercial Mobile Spectrum Outlook (Mar. 2013) (hereinafter, “Commercial Mobile Spectrum Outlook Report”), available at https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/Outlook-2013-en.pdf/$FILE/Outlook-2013-en.pdf. 3 Consultation, at 13. 4 LS Telcom, Anaylsis of World-Wide Licensing and Usage of IMT Spectrum (Sept. 2014), available at http://www.lstelcom.com/fileadmin/content/marketing/Press_releases/Licensing_and_use_of_IMT_Spectrum_version_101.pdf. Mehta, Aalok and Musey, J. Armand, Overestimating Wireless Demand: Policy and Investment Implications of Upward Bias in Mobile Data Forecasts (Aug. 2014), available at http://ssrn.com/abstract=2418364. 5 Commercial Mobile Spectrum Outlook Report, at 4.2.6.

https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/Outlook-2013-en.pdf/$FILE/Outlook-2013-en.pdf

https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/Outlook-2013-en.pdf/$FILE/Outlook-2013-en.pdf

http://www.lstelcom.com/fileadmin/content/marketing/Press_releases/Licensing_and_use_of_IMT_Spectrum_version_101.pdf

http://www.lstelcom.com/fileadmin/content/marketing/Press_releases/Licensing_and_use_of_IMT_Spectrum_version_101.pdf

http://ssrn.com/abstract=2418364

consistent with studies of co-frequency sharing in this band that has been submitted to the ITU.6 The challenges of interference protection for co-frequency FSS earth stations in Canada or neighboring United States may or may not be insurmountable in the 3500 MHz band. But the answers to those challenges will only be known after the effort has been made to consider and address those challenges of co-frequency sharing between mobile and FSS stations.

Industry Canada’s proposal to introduce mobile services in the 3500 MHz band may also cause adjacent band interference into the many FSS earth stations operating above 3700 MHz that are located in Canada and in the United States. There are many more FSS earth stations operating above 3700 MHz than there are earth stations in the 3500 MHz or in the adjacent 3650 MHz band, so an analysis of the adjacent band interference issues is critical.

In the U.S. Federal Communication Commission’s (“FCC”) proceeding, Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550-3650 MHz Bands (the “U.S. 3500 MHz Proceeding”),7 proponents of “small cell” mobile deployments in that band have acknowledged that “OOBE [out-of-band emission] protection zones are necessary.”8 In other words, out-of-band emissions from mobile service transmitters in the 3500 MHz band will interfere with earth stations operating in the adjacent 3700-4200 MHz band, unless adequate separation distances are maintained.9 The size of the necessary separation distances depends on the transmit power and out-of-band emissions mask of the mobile transmitters in the 3500 MHz band. Depending on the allowed in-band power levels, the out-of-band emissions mask, relative antenna orientation, and surrounding terrain, SIA’s engineering analysis suggests that the distances could be in the tens of kilometers for a single interferer (and would likely increase when aggregate interference is considered).10 Such distances suggest that mobile transmitters in this band could pose interference threats to FSS earth stations both in Canada and those just across the border in the United States.

6 ITU-R Document 4-5-6-7/584 (Annex 11, Attachment 3): Draft new Report ITU-R [C-BAND DOWNLINK] “Sharing studies between IMT-Advanced systems and geostationary satellite networks in the fixed-satellite service in the 3 400-4 200 MHz and 4 500-4 800 MHz frequency bands in the WRC study cycle leading to WRC-15”, available at https://www.itu.int/md/choice_md.asp?id=R12-SG05-C-0126!R1!MSW-E&lang=en&type=sitems. 7 Federal Communications Commission, Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550-3650 MHz Bands, Further Notice of Proposed Rulemaking, GN Docket 12-354, 29 FCC Rcd 4273 (2014). 8 Letter from Aparna Sridhar, Telecom Policy Counsel, Google Inc., to Marlene H. Dortch, Secretary, Federal Communications Commission, filed in U.S. 3500 MHz Proceeding, Declaration of Dr. Preston Marshall (“Marshall Declaration”) at 16, ¶ 30 (filed Sept. 3, 2013). 9 Filters on FSS receivers will not protect against out-of-band emissions of the mobile service transmitters that fall inside the FSS receive band, as such filters would block the wanted satellite signal as well. 10 Comments of the Satellite Industry Association, Docket 12-354 at Technical Annex (July 2014) filed in U.S. 3500 MHz Proceeding, available at http://apps.fcc.gov/ecfs/document/view?id=7521384256.

https://www.itu.int/md/choice_md.asp?id=R12-SG05-C-0126!R1!MSW-E&lang=en&type=sitems

https://www.itu.int/md/choice_md.asp?id=R12-SG05-C-0126!R1!MSW-E&lang=en&type=sitems

http://apps.fcc.gov/ecfs/document/view?id=7521384256

The Consultation suggests that the technical parameters for the new mobile service would be considered in a subsequent consultation.11 Industry Canada should analyze the conditions for sharing before reaching conclusions on whether an allocation for the mobile services should be made in the 3500 MHz band. In this regard, a recent engineering report filed by SIA in the U.S. 3500 MHz Proceeding,12 currently before the FCC, illustrates some of the potential sharing difficulties. A copy of this report is attached, for reference.13 Again, the sharing issues may or may not be insurmountable given the conditions in Canada, but Industry Canada must investigate and logically consider those issues before deciding to add an allocation for the mobile service in the 3500 MHz band.

SIA urges Industry Canada to fully develop the record before making any change to the Canadian Table of Frequency Allocations by (a) fully analyzing the need for additional mobile service spectrum and the efficiency with which current mobile service spectrum is being used; (b) proposing technical standards that would apply to mobile service transmitters that would be permitted to operate in the 3500 MHz band; (c) conducting a technical analysis of the aggregate interference effects, including out-of-band effects, should such technical standards be adopted for the mobile service; and (d) initiating a full public consultation to enable review and comment of the proposed standards and the results of the Department’s technical analysis.

Respectfully submitted,

SATELLITE INDUSTRY ASSOCIATION

Sam Black, Acting President 1200 18th Street NW, Suite 1001 Washington, D.C. 20036 (202) 503-1561

Attachments

11 Consultation, at 53. 12 Comments of the Satellite Industry Association, Docket 12-354 at Technical Annex (July 2014), available at http://apps.fcc.gov/ecfs/document/view?id=7521384256. 13 See Attachment A, Technical Annex of the Comments of the Satellite Industry Association, Docket 12-354 Technical Annex (July 2014) filed in U.S. 3500 MHz Proceeding.

http://apps.fcc.gov/ecfs/document/view?id=7521384256

RKF Engineering Solutions, LLC 1229 19

th St. NW, Washington, DC 20036

Phone 202.463.1567 Fax 202.463.0344

www.rkf-eng.com

Technical Annex

1. Protection of In-band FSS Earth Stations

1.1 In-band Interference Protection Criteria for FSS Earth Stations

Both long-term and short-term interference criteria are considered when assessing the in-band

interference into FSS receiver earth stations.

In line with Recommendation ITU-R S.1432, the following criterion is identified for use for the long-

term case when assessing in-band interference into FSS receive earth stations:

This criterion corresponds to the aggregate interference from a co-primary allocation for of a given

month.

In line with Recommendation ITU-R SF.1006, the following criterion is identified for use for the

short-term case when assessing single-entry in-band interference into FSS receive earth stations:

which may be exceeded up to time.

For cases in which the long-term interference criterion applied, of the allowable interference to

the FSS earth station receiver was allocated to CBSD systems.1 This results in a reduction of the

protection criterion by dB:

For cases in which the short-term interference criterion was applicable, of the interference

allowance was allocated to the CBSD system.

The SAS will have to calculate the total interference power at each FSS earth station in order to

determine if the protection criterion is exceeded. This determination can be performed using an

aggregate Effective Power Flux Density (EPFD) calculation methodology. Use of EPFD rather than PFD is

preferable because the FSS earth station pointing direction is taken into account in the EPFD

interference calculation. In contrast, using PFD would require using the worst-case assumption

regarding the FSS earth station pointing angle (5% elevation angle).

1 This apportionment reflects the fact that there are other co-primary users in the band (e.g., Federal allocations).

RKF Engineering Solutions, LLC 1229 19th Street NW, Washington DC 20036 Page 2

1.2 Challenges in Protecting FSS Earth Stations

The total received interference power from CBSDs at an FSS earth station receiver will be a function of:

(i) the EIRP density of each CBSD transmitter in the direction of the FSS receiver (which depends on the

CBSDs maximum EIRP density and the antenna pattern and orientation); (ii) the FSS receiver gain in the

direction of each CBSD transmitter (which depends on the FSS receivers antenna pattern and

orientation); (iii) the distance between the FSS receiver and each CBSD transmitter; and (iv) the

intervening terrain between each CBSD transmitter and the FSS receiver.

In order to accurately determine whether the prescribed aggregate protection criterion is met, the

following technical challenges and shortcomings have to be addressed:

a. Many technical and operational characteristics of CBSDs that will significantly affect

potential interference into the FSS earth stations have not been defined, including whether

the CBSDs will be TDD or FDD, can use beamforming to increase terminal gain, use power

control, dynamically assign traffic, etc.

b. In theory, if an SAS database could calculate the aggregate interference from all CBSD

transmitters in real time at a given FSS receiver location, it would be able to ensure that the

aggregate CBSD transmissions will not exceed the prescribed aggregate criterion by

instructing individual CBSDs either to not transmit on a particular frequency or to reduce

power. This is at best a very complicated calculation that will have to be updated constantly

in real time to account for a broad variety of changing circumstances. Some of the modeling

challenges are discussed in the paragraphs that follow.

c. The SAS will have to take into account constantly changing CBSD deployments. The number

and location of active CBSDs will change over time, with more significant impacts from

CBSDs dynamic traffic scheduling on a frame basis (e.g. msec or msec frames). On each

frame, the CBSD Base Stations (BS) can be communicating with different user terminals, and

the user terminals may also have different resource block assignments on each frame.

Modulation will be changing, and user terminals may use power control. The practical

feasibility of taking into account this variation in traffic over time has not been proven.

d. Another significant technical obstacle is with regards to changes in CBSD deployment and

traffic variations. Conservative propagation models that include significant fade margins to

account for inaccuracies and variability would be needed to ensure protection of the FSS

earth stations. Propagation modeling will be non-line-of-site (NLOS), which means a rapidly

changing multipath environment. Without conservative propagation models, it is not clear

how the SAS deployment modeling will handle this variability. Most propagation models are

two dimensional, but it will be necessary to take into account the multipath in three

dimensions to model NLOS environments. It will be important to investigate the accuracy of

proposed modeling approaches, as the variation in propagation loss can be quite large even

in small geographic areas. In addition, these models cannot be expected to include up-to-


date clutter. Construction and other changes to the landscape would have to be kept up-to-

date.

If aggregate measurements into the FSS receiver are not accurate or if worst case modeling assumptions

are not used, FSS earth stations may experience interference despite SAS analysis showing the

applicable interference criteria are met. It is not clear that the SAS can then measure and identify the

terminals causing the highest levels of interference in a deployment of thousands of terminals. The

ability of an SAS to police compliance with the aggregate criterion would, of course, have to be

validated (with strong security measures to prevent bypass), as discussed in Section 3 below.

1.3 Sample Receive Power Limit Calculation

For any given CBSD deployment, the aggregate interference from all of the CBSDs will have to be

evaluated. Given an I/N threshold and depending on both FSS earth station and CBSD system

characteristics and deployment scenarios, a received power limit for the aggregate interference power

from all CBSDs managed by the SAS can be calculated. For example, for an I/N = -13 dB, assuming an FSS

earth station receiver system noise temperature of and a CBSD bandwidth of , we can

evaluate the FSS earth station noise power . Therefore in this case, the

aggregate interference power from all CBSDs managed by the SAS would have to be less than

at the FSS receiver in order not to exceed the long-term threshold of .

This aggregate power may change depending on the FSS earth station and CBSD system characteristics

and deployment scenarios. As described in Section 1.2, the SAS will need to manage and calculate all of

these changing characteristics in real time to ensure protection of FSS receivers based on the

appropriate receive power characteristics for that particular FSS earth station and CBSD deployment

characteristics.

1.4. Single Entry CBSD Interference Simulations

It is important to note that a single user could exceed the interference criteria if deployed within a

certain proximity to an FSS earth station. The following analysis calculates a protection area (or contour)

around each of the 37 in-band FSS receive earth stations2 in which a single CSBD could exceed the

interference criteria. If deployment of CBSDs is permitted within this protection area, the SAS will need

to be capable of implementing the necessary measures (as described in discussion points a-d in

Section 1.2) in order to ensure that the aggregate interference criteria is not exceeded.

The protection areas were determined as described below, using the modeling assumptions of the FSS

earth stations, CBSD transmitters and propagation path described in sections 1 through 3 of the

Appendix.

For each FSS earth station (ES) pointing direction to the GEO arc (with ES elevation angle

varying from 5°East to 5°West), a contour was generated via the following methodology:

2 Per FNPRM Appendix 2, table of FSS earth stations in 3600-3650 MHz.


o Two CBSD terminal types (a non-rural base station (BS) and a fixed point-to-

point station) were modeled with EIRP densities of and

, respectively.

o A single CBSD interferer was oriented at a given azimuth angle relative to the ES

location. The CBSD station distance was varied relative to the ES location to find

the maximum distance where the CBSD interference exceeded the interference

criteria.

o This calculation was repeated for every azimuth direction from the ES to

produce a maximum interference contour.

The protection area contour is the maximum envelope of all the above contours.

The resulting contours around each FSS earth station, for single-entry interference simulation described

above, are illustrated in Figures 1 and 2 for the long-term interference case ( dB not exceeded

for more than of the time) and Figures 3 and 4 for the short-term interference case ( dB

not exceeded for more than of the time), where the FSS earth station is at in all

figures.

Figure 1: Single-Entry Protection Area Contour in km (East(right), West(left), North(top), South(bottom)) - Non-rural CBSD

(BS) EIRP density = 30 dBm/10 MHz for the long-term interference case.


Figure 2: Single-Entry Protection Area Contour in km (East(right), West(left), North(top), South(bottom)) Fixed Point-to-

Point CBSD EIRP density = 53 dBm/10 MHz for the long-term interference case.

Figure 3: Single-Entry Protection Area Contour in km (East(right), West(left), North(top), South(bottom)) - Non-rural CBSD

(BS) EIRP density = 30 dBm/10 MHz for the short-term interference case.


Figure 4: Single-Entry Protection Area Contour in km (East(right), West(left), North(top), South(bottom)) Fixed Point-to-

Point CBSD EIRP density = 53 dBm/10 MHz for the short-term interference case.

Figure 5 and Figure 7 show the four protection area contours around two representative FSS earth

stations: #12 in Medley, FL, and # 29 in Alexandria, VA, in Google Earth. Figure 6 and Figure 8 show the

size of the corresponding contours.

Figure 5: Single-Entry Protection Area Contours around FSS earth station in Medley, FL (ES #12) at 25.85528 N, 80.33111 W.

From innermost contour, the contours correspond to Long-term interference with CBSD EIRP density=30dBm/10 MHz

(Green), Long-term interference with CBSD EIRP density= 53dBm/10 MHz (Blue), Short-term interference with CBSD EIRP

density=30 dBm/10 MHz (Red filled), and Short-term interference with CBSD EIRP density=53 dBm/10 MHz (Red unfilled).


Figure 6: Protection Area Contours around FSS earth station in Medley, FL (ES # 12).

Figure 7: Single-Entry Protection Area Contours around FSS earth station in Alexandria, VA (ES #29) at 38.79333 N, 77.16639

W. From innermost contour, the contours correspond to Long-term interference with CBSD EIRP density=30dBm/10 MHz

(Green), Long-term interference with CBSD EIRP density=53dBm/10 MHz (Blue), Short-term interference with CBSD EIRP

density=30 dBm/10 MHz (Red filled), and Short-term interference with CBSD EIRP density=53 dBm/10 MHz (Red unfilled).


Figure 8: Protection Area Contours around FSS earth station in Alexandria, VA (ES # 29).

As indicated by the simulation results, protection areas are large, and there is variation among the 37

FSS earth stations. Using the long-term interference criterion, the protection areas have radii tens to

hundreds of kilometers (for the higher CBSD EIRP), and using the short-term interference criterion, the

protection areas have radii hundreds of kilometers long. The protection areas vary with the ES azimuth

direction toward the interferer and the ES pointing direction to the GEO arc. These results also imply

that CBSDs deployed in the United States could cause interference into FSS earth stations deployed in

neighboring countries.

1.5 Aggregate CBSD Interference Simulations

In order to understand the magnitude of the interference problem that will have to be managed, an

aggregate small-cell CBSD deployment was simulated around several FSS earth stations. The CBSDs

deployment parameters were chosen according to the assumptions in Section 2 of the Appendix.

As indicated in Section 2 of the Appendix, the CBSDs were deployed assuming they were supporting a

macro cell operating in another frequency band. Macro cells were determined to be urban or suburban

according to the population density in each area as described in the Appendix. For each Suburban macro

cell, one CBRS small cell was deployed. For each urban macro cell, three CBRS small cells were deployed.

In each small cell, a CBSD base station with an EIRP density of was assumed.

The parameters used in the simulations were not based on a worst-case scenario. For instance, even

though the FNPRM does not preclude macro cells in the 3.5 GHz band, macro cells were not included in

the simulation. Additionally, even though the FNPRM is proposing to allow high-power fixed point-to-

point links and rural terminals (with EIRP densities of and respectively), no such

deployments were assumed. Finally, no user terminals were assumed in this simulation. If user terminals

and higher power CBSDs were included in the simulations, this would lead to more stringent margins for

protection for the FSS.


Table 1 lists the three FSS earth stations that were evaluated with characteristics per Section 1 of the

Appendix.

Table 1: List of FSS earth stations used in aggregate interference analysis

FSS Earth Station

No.3

City, State Call Sign Coordinates

2 Malibu, CA E980066 34° 04 52.6 N, 118° 53 52.9 W

13 Miami, FL KA407 25° 48 35 N, 80° 21 10 W

20 Hagerstown, MD KA262 39° 35 57 N, 77° 45 23 W

The aggregate interference was calculated with CBSD deployment as described above and with no

minimum distance between the CBSD and the FSS earth station. A second simulation was performed

excluding CBSDs in the protection area, as determined in the single-entry interference analysis

(Section 1.4).

Assuming again an FSS earth station noise temperature of 100K and a CBSD bandwidth of 10MHz,

resulting in an aggregate interference power limit from all CBSDs managed by the SAS to be less than

Table 2 provides the calculated margins relative to the aggregate interference

power limit. As can be seen from the negative margins, without additional protective measures, it is

possible that a deployment will cause interference levels well above protection threshold limits. With

CBSD deployment included within the protection area, the aggregate interference limit is exceeded by

about dB, and with the CBSD deployment excluded from the protection area, the limit is still

exceeded by about dB. In other words, even with CBSDs excluded from the protection area,

significant constraints on CBSD operations will be needed to meet the aggregate interference criterion

to the FSS earth stations.

Table 2: Example calculated Margin relative to aggregate interference power limit (-121.6dBm/10 MHz) at FSS earth stations

from a deployment of CBSDs (dB)

FSS Earth Station

Location

CBSD Deployment

included within the

protection area

CBSD Deployment

excluded within the

protection area

Malibu, CA -64.50 -34.19

Miami, FL -65.21 -30.58

Hagerstown, MD -65.51 -29.33

Based on the deployment scenarios described above, Table 3 and Figures 9 through 11 show the

minimum number of CBSDs that would have to shut down to meet the example calculated aggregate

interference power of dBm/ MHz at each FSS earth station (assuming the same FSS earth

station and CBSD characteristics as above). These plots were provided to allow investigation into how

3 The Earth Station No. corresponds to the list in the FNRPM, Appendix 2, table of FSS earth stations in 3600-

3650 MHz.


difficult it will be for the SAS to identify and mitigate the interference. The figures show that for the

selected FSS earth stations, a large population of CBSD terminals (on the order of 1000s or 10,000s)

would have to be shut off or otherwise have their powers significantly reduced in order to meet the

aggregate limit. Furthermore, as indicated, this is true even if there is no CBSD deployment in the

protection area.

For reference, the CBSDs were deployed up to from each FSS earth station as their contribution

was assumed to be negligible beyond that. This resulted in the total number of CBSDs indicated in

parentheses in Table 3.

Table 3: The minimum number of CBSDs that have to be shut-down (out of the total population of CBSDs) to meet the long-

term I/N criterion at each FSS earth station.

FSS Earth Station CBSDs included within

protection area

CBSDs excluded within

protection area

Malibu, CA 24,906 (97,123) 20,776 (92,993)

Miami, FL 11,229 (69,000) 6,180 (63,951)

Hagerstown, MD 9,637 (229,835) 6,751 (226,949)

Figure 9: Distribution of received power from deployed CBSDs at Malibu, CA FSS earth station showing the minimum number

of CBSDs that would have to be shut-down to meet the long-term I/N criterion.


Figure 10: Distribution of received power from deployed CBSDs at Miami, FL FSS earth station showing the minimum number

of CBSDs that would have to be shut-down to meet the long-term I/N criterion.

Figure 11: Distribution of received power from deployed CBSDs at Hagerstown, MD FSS earth station showing the minimum

number of CBSDs that would have to be shut-down to meet the long-term I/N criterion.

2. Protection of adjacent band FSS Earth Stations

2.1. Interference Protection Criterion

In line with Recommendation ITU-R S.1432, the following criterion is identified for use when

assessing the out-of-band interference into FSS receive earth stations:


The aggregate interference from all other sources of interference is considered for of the time

where is the clear-sky satellite system noise as described in Recommendation ITU-R S.1432.

To account for other interference sources, of the permissible interference to the FSS earth station

receiver was allocated to CBSD systems. This results in a reduction of the protection criterion by

3 dB:

Therefore, for an , assuming an FSS earth station noise temperature of 100K and a CBSD

bandwidth of , the calculated aggregate interference power limit from all CBSDs managed by the

SAS would have to be less than at the FSS earth station.

2.2. Out-of-Band Emission Limit

The FNPRM mentions three OOBE limits , and )4 and asks

for comment on which is appropriate. Using the FSS earth station characteristics described in Section 1

of the Appendix, Figure 12 shows the required line-of-sight (LOS) separation distance between a CBSD

and an FSS earth station as a function of OOBE limit and the FSS earth station off-axis angle, such that

the out-of-band interference criterion ( ) is not exceeded. It is clear from the figure that

significant separation distances will be needed to control aggregate interference with an OOBE limit of

, while the required separation distances with a tighter OOBE limit of are

between and depending on the FSS earth station off-axis angle.

Figure 12: Required LOS separation distance between a CBSD and an FSS earth station as a function of OOBE limit and the FSS

earth station off-axis angle (degrees), such that the out-of-band interference criterion is not exceeded.

4 See FNPRM at ¶ 81 & ¶ 83.

0.1

1

10

5 15 25 35

Lin

e-o

f-S

igh

t

Se

pa

rati

on

Dis

tan

ce (

Km

)

Earth Station Off-axis Angle

-13 dBm/MHz

-40 dBm/MHz

-50 dBm/MHz


3. Validation of the SAS

A multi-step process will be needed to confirm whether an SAS is capable of ensuring that interference

protection levels are not exceeded.

a. Initially, it is anticipated that an SAS will conduct simulations of the proposed CBSD

deployments, model the associated multipath transmission loss of each of the CBSD users in the

cells, and compute the aggregate interference at each of the FSS earth stations. It will be

necessary for an SAS to have data regarding the CBSD deployment characteristics at each of the

FSS earth stations, as well as the FSS earth station receivers antenna patterns over the

complete hemisphere and their effective noise temperature in order to perform this modeling.

Additionally, it will be necessary for an SAS to model the multipath transmission loss over the

terrain for each of the CBSD terminals (both base stations and user terminals, which may be

mobile). If the model shows that the shared performance is acceptable, the SAS would then

authorize the CBSD deployment. The feasibility of performing all of this modeling of a highly

uncertain reality must be proven prior to moving forward with CBSD deployment.

b. If deployment of the CBSD system is ultimately approved, additional challenges emerge in the

deployment phase. CBSD users must first be validated and regulated in a way that prevents

abuse of protection levels and is capable of being modeled by an SAS. A deployed SAS will need

to test actual interference at one or more reference FSS earth stations in order to validate the

predicted levels of interference. This validation is necessary because of the limited accuracy of

the multipath transmission loss models.

c. It will be very difficult for an SAS to measure aggregate interference levels. A key concern

regarding SAS monitoring is the extreme difficulty in measuring aggregate interference levels, as

described in points a-d of section 1.2. It will be especially difficult to identify the terminals

causing the protection level to be exceeded or significantly contributing to the interference

exceedance, unless the interference is substantially above allowed limits

d. For long-term interference, a possible reference measurement approach would require

integration of a pseudo random noise signal, transmitted from each CBSD. This would be

required to pull the interference above the FSS receiver noise. Before a CBSD is allowed to

transmit traffic, it should first transmit a pseudo random code that could be received at the FSS

earth station. The signal would probably have to be received for at least several days to

characterize the long-term propagation statistics. This would help to calibrate the SAS

propagation modeling for long-term statistics. Note that short-term statistics would still have to

be extrapolated from the limited number of measurements taken. Furthermore, for this to

work, someone would have to develop a box that could receive all the CBSD pseudo random

codes at the reference FSS earth station(s).


e. The measurements described above will not verify compliance with the aggregate interference

criterion or help identify the CBSDs causing the most significant interference over time. For this,

there needs to be regular measurements. Since an FSS earth stations traffic and multipath

propagation conditions are constantly changing, measurements of the CBSD interference would

need to be taken at regular intervals to verify the continued compliance with the aggregate

interference criterion. This could mean turning off CBSD traffic at regular intervals and

transmitting pseudo codes that can be received at the FSS earth station.

f. An additional validation method might be performed while the CBSD carried traffic. Each CBSD

user would dedicate one or more resource blocks (180 KHz per resource block) to continuously

transmit a pseudo-random code identifying the user during frame transmission. The number of

resource blocks needed would have to be analyzed and have to be sufficient to pull the

interference above the satellite receive signal and noise (at the FSS earth station) during a single

CBSD frame. Results could then be averaged continuously to determine the variation of the

multipath propagation. The validation receiver at the FSS earth station would have to be able to

pick out the individual codes from all the CBSDs so that aggregate interference could be

calculated and the CBSDs causing the most interference identified.


Appendix

Assumptions Used in the Technical Annex:

1- FSS System Parameters and Criteria

Table 1 contains typical downlink FSS parameters for the 3.5 GHz band that were used in the study.

Table 4

Downlink FSS parameters

Parameter Value

Range of operating frequencies 3600-3650 MHz (in-band)

3600-4200 (out-of-band)

Elevation angle 5° (aggregate interference simulation)

See single-entry section for simulation assumption

Antenna off-axis reference pattern Recommendation ITU-R S.465-6

Antenna diameter 2.4 m

Antenna height above ground 3.0 m

Receiving system noise temperature 100 K

5° is considered as the minimum operational elevation angle.

2- Deployment-related Parameters for CBSD

Table 2 contains CBSD parameters that were used in the study.

Table 5

CBSD Parameters

Outdoor small cell suburban Outdoor small cell urban

Deployment density (small cell)

Cell radius (macro-cell)

1 per suburban macro cell

0.6 km per suburban macro cell

3 per urban macro cell

0.3 km per urban macro cell

Antenna height (m) 6

Antenna pattern Omni

Base station transmit EIRP (dBm) 30 (aggregate and single-entry simulations)

53 (single-entry simulation)

Base station bandwidth (MHz) 10


To make the CBSD deployment as realistic as possible, cell deployment related parameters (for bands

between 3 and 6 GHz) from Table 4 of Report ITU-R M.2292 “Characteristics of terrestrial IMT-Advanced

systems for frequency sharing/interference analyses” were used, as indicated in the first row (Cell

radius/Deployment density) above.

To determine if a cell is Urban or Suburban, the population density database from the Census Bureau

from 2000 was used. Urban was estimated to have 250 or more people per km2. Suburban was

estimated to have 50 to 249 people per km2.

The CBSD base station EIRP levels were based on the FNPRM proposal of for non-rural CBSDs

(¶ 74) and for Fixed point-to-point stations (¶ 75), per bandwidth.

3- Propagation Model and Terrain

The propagation model defined in Recommendation ITU-R P.452 was used.

Terrain information was taken into account by using the Shuttle Radar Topography Mission (SRTM)

database. The SRTM includes in addition to terrain information, building or vegetation heights. The

SRTM is a surface database taken by radar measurements from a Space Shuttle mission and contains

measurements of where the radar waves are reflected off the surface of the earth.

Consultation on Policy Changes in the 3500 MHz Band

(3475‐3650 MHz) and a New Licensing Process in Rural Areas

Seaside Wireless Communications Inc. is a privately held corporation based in Nova Scotia. It is

part of the Seaside Communications group of companies that was founded in 1975. The

Seaside Group as a whole provides cable television, high‐speed Internet and telephone services

to 21,000 customers in north eastern Nova Scotia. Seaside Wireless is the largest provider of

fixed wireless Internet services in Nova Scotia and an important partner with the Province of

Nova Scotia in carrying out the Broadband for Rural Nova Scotia (BRNS) initiative.

Over the past ten years Seaside has deployed fixed wireless technology (using both lightly

licensed and unlicensed frequencies) over rural areas of Nova Scotia covering almost 30,000

square kilometers. The cost of our network to date exceeds $40‐million and it comprises over

300 communications towers and poles stretching from Amherst on the New Brunswick border

to the northern tip of Cape Breton Island.

In the process we have connected approximately 10,000 subscribers, i.e. virtually 100% of the individuals, businesses and institutions who wanted service within our territory. To meet the challenge of providing virtually 100 per‐cent coverage in areas served, Seaside has developed solutions that include the deployment of a variety of radio technologies in the 900 MHz, 2.4 GHz, 3.65 GHz and 5.8 GHz spectrums, each with their own propagation characteristics, advantages and drawbacks (i.e. Unlicensed spectrum being a drawback).

The biggest challenge for us now is to increase Internet speeds in as many areas as

economically feasible.

Seaside Wireless Communication Responses to Industry Canada Questions

1. Industry Canada invites comments on its proposal to classify Tier 4 service areas as either

urban or rural for the band 3475‐3650 MHz, using Statistics Canada’s 2011 definition for

population centres, as outlined in Annex A.

Seaside agrees with classifying Tier 4 areas as rural or urban for the use of the 3500MHz

band. We would like to see the population centre size required to deem an area urban

raised from 30,000 to 150,000.

There is still a need for FWA in urban areas. A blanket reassignment of the whole band to

mobile would be an inefficient use of the spectrum as there are multiple technologies

mobile providers have not yet deployed or implemented (e.g. LTE, 700MHz spectrum).

Assigning 3500MHz spectrum solely for mobile applications in urban areas before these

technologies are implemented is counterproductive to Industry Canada aims including those

articulated in the Connecting Canadians broadband policy.

2. Industry Canada invites comments on its proposal to make available spectrum licences in tier

areas classified as rural, through a first‐come, first‐served process.

Seaside recommends that all existing license holders that have met deployment

requirements and have shown use of the spectrum in the past should be provided access to

licenses before any new FCFS licenses are issued. New applications should be required to

provide a plan to deploy equipment in a timely manner to prevent license warehousing.

3. Industry Canada invites comments on these licenses being issued as annual spectrum licenses,

defined on a per grid‐cell basis and authorized only for the amount of spectrum required to

operate (refer to Section 7.3)

One year is insufficient time within which licensees would be required to engineer/design,

purchase and deploy equipment, offer services, and recoup the investment made. Annual

renewals offer insufficient and unrealistic notice for prudent business planning, and could

seriously hinder investments.

Seaside recommends keeping the ten year licenses with deployment conditions to ensure

the spectrum is optimally used. If that is not possible, five year licenses should be the

absolute minimum considered.

4. Industry Canada invites comments on its proposal to modify the current notification period

for existing point‐to‐point, fixed stations such that those affecting the implementation of the

new FWA systems in rural Tier 4 areas would now be afforded a notification period of six

months.

Seaside agrees with the proposed notification period of six months.

5. Industry Canada invites comments on its proposal to have the transition policy described in

section 4 of Annex B apply to all FWA systems (i.e. existing FCFS and auctioned FWA systems

as listed in (v) and (vi)) within rural tiers.

There are numerous fixed wireless Internet service providers throughout the country

operating in rural areas as a consequence of prior government and Industry Canada

initiatives and incentives. The imminent Connecting Canadians initiative further underscores

future government policy in this area. It will be detrimental to that policy to deny use of the

3500MHz spectrum to fixed wireless ISPs and their customers. Reallocation of this spectrum

solely for mobile applications will jeopardize the service to large segments of the population

throughout Canada.

6. Industry Canada invites comments on the conditions of license in Annex B.

The license term should remain at ten years, with appropriate deployment conditions.

Seaside has no objections to the annual license fees.

7. Industry Canada invites comments on its proposal to fundamentally reallocate the 3500 MHz

band (3475‐3650) to include mobile services and its proposed changes to the Canadian Table

of Frequency Allocations as found in Annex C.

Seaside agrees with a reallocation of the 3500MHz band that may include mobile services,

based on those mobile services only operating in an Urban Tier 4 environment (Urban being

defined as a population centre of 150,000 or more).

8. Industry Canada invites comments on its geographically differentiated policy where mobile

services will be allowed in urban tiers, and fixed services will be allowed in rural tiers (refer to

section 6 for the definition of urban and rural tiers).

Seaside recommends Industry Canada continue to issue and renew FWA licenses in urban

areas at least until mobile providers have implemented and saturated technologies such as

LTE and the 700MHz spectrum in those same urban areas.

9. Industry Canada invites comments on its two proposed options for displacement.

Option 2 is acceptable. The mobile provider should provide evidence that all other options

(LTE, 700Mz, etc.) have been exhausted and that there is equipment and capacity available

to use mobile wireless in the 3500MHz band. This will mitigate against the prospect that

Industry Canada will receive multiple license applications, only to have licensees

“warehouse” the spectrum.

Documents

DGSO - Language · PDF fileOctober 8, 2014. Senior Director. Spectrum Development and Operations . Industry Canada . 300 Slater Street (JETN, 15th) Ottawa, Ontario K1A 0H5 . VIA E-Mail: