VIA ELECTRONIC FILING Re: Ex Parte Presentation, ET Docket ... · 6 Wireless industry proponents first identified this request back in 20177 Indeed, . the issue of how to achieve

1400 16th Street, NW · Suite 600 · Washington, DC 20036 · www.ctia.org

February 24, 2020

VIA ELECTRONIC FILING

Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554

Re: Ex Parte Presentation, ET Docket No. 18-295; GN Docket No. 17-183

Dear Ms. Dortch:

CTIA commends the Commission for moving forward with plans to auction 350 megahertz of mid-band spectrum this year, which is essential to keeping the United States competitive with where other nations are today in terms of mid-band spectrum availability. Merely matching other countries’ spectrum investments, however, will not be enough for the U.S. to lead in our new 5G economy because these nations are not finished. Other leading countries are on track to make available four times as much licensed mid-band spectrum as the U.S. by the end of 2020, with nations like Japan and South Korea pushing ahead with plans for additional mid-band spectrum in the next few years totaling 1,000 megahertz and 600 megahertz, respectively,1 and China recently releasing an additional 100 megahertz to bring its mid-band total to 460 megahertz. And the U.S. is an outlier as compared to benchmark countries in that it is making substantially more spectrum available on an unlicensed and shared basis than other key countries.2 As a nation, we need additional licensed mid-band spectrum to remain competitive.

CTIA has therefore urged the Commission to take a balanced approach to the unprecedented 1,200 megahertz of spectrum under consideration in the 6 GHz band proceeding by making available opportunities for both licensed and unlicensed use. To that end, CTIA provides the Commission with a new report prepared by Comsearch that analyzes the potential to relocate licensed fixed incumbents

1 See Letter from CTIA to FCC, ET Docket No. 18-295, et al. (filed Jan. 31, 2020). 2 See David Abecassis, et al., International Comparison: Licensed, Unlicensed, and Shared Spectrum, 2017-2020, ANALYSYS MASON (Jan. 2020), attached to Letter from CTIA to FCC, ET Docket No. 18-295 et al. (filed Feb. 3, 2020) (“CTIA Feb. 3 Letter”).

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out of the 6.525-7.125 GHz band, and concludes that “large-scale relocation of 6 GHz assignments into 7/8 GHz, to operate along with the approximately 9000 federal assignments, appears feasible,” with a projected relocation cost to the new licensees of $2.8 billion3—a small fraction of the potential value of the band.4

To facilitate a balanced approach to the 6 GHz band, CTIA and other commenters in the proceeding have requested that the agency issue a Further Notice of Proposed Rulemaking on licensing the upper portion of the 6 GHz band (6.525-7.125 GHz) while relocating incumbent users at the expense of winning bidders pursuant to the Emerging Technologies policies.5 To that end, CTIA and others have urged the Commission to work with NTIA to explore shared use of the 7.125-8.4 GHz band by adding a non-federal allocation to that spectrum and moving licensed upper 6 GHz incumbents to that frequency range or other comparable spectrum or facilities.6 Wireless industry proponents first identified this request back in 2017.7 Indeed, the issue of how to achieve the appropriate balance of licensed and unlicensed services in the 6 GHz band has been an issue since stakeholders first sought to reform the 6 GHz band, as recognized in a 2017 licensed/unlicensed stakeholder coalition letter.8

3 Comsearch, Analysis for 6 GHz Relocation (6525-7125 MHz), at 32 (Feb. 3, 2020) (“Comsearch Report”) (attached) (defining the “7/8 GHz band” to include 7.125-8.5 GHz). 4 See Jennifer M. Fritzsche, et al., Life After C-Band . . . A Spectrum Desert Or Oasis?, WELLS FARGO SECURITIES (Dec. 19, 2019) (projecting that auction of the 6.525-7.125 GHz band could be valued at “north of $22 B”). 5 See Letter from CTIA to FCC, ET Docket No. 18-295, et al. (filed Jan. 10, 2020) (“CTIA Jan. 10 Letter”); see also Comments of CTIA, ET Docket No. 18-295 (filed Feb. 15, 2019) (“CTIA 6 GHz Comments”); Reply Comments of CTIA, ET Docket No. 18-295 (filed March 18, 2019) (“CTIA 6 GHz Reply Comments”); Comments of Ericsson, ET Docket No. 18-295 (filed Feb. 15, 2019); Reply Comments of U.S. Cellular, ET Docket No. 18-295 (filed Mar. 18, 2019); Reply Comments of Nokia, ET Docket No. 18-295 (filed Mar. 18, 2019); Letter from T-Mobile to FCC, ET Docket No. 18-295, at 2 (filed Jan. 9, 2020); Reply Comments of Verizon, ET Docket No. 18-295 (filed Mar. 18, 2019); Letter from National Association of Broadcasters to FCC, ET Docket No. 18-295, at 3 (filed Nov. 6, 2019) (noting that an auction of the upper portion of the 6 GHz band could potentially help make more mid-band spectrum available). 6 See, e.g., CTIA Jan. 10 Letter at 3-4; see also Reply Comments of CTIA, GN Docket No. 17-183, at 13-14 (filed Nov. 15, 2017) (encouraging the Commission to “work with NTIA to examine whether the 7.125-8.4 GHz band can be converted to a shared band that would enable non-federal point-to-point microwave operations, consistent with the 2010 petition for rulemaking filed by Fixed Wireless Communications Coalition”) (internal citations omitted). 7 See, e.g., Comments of Ericsson, GN Docket No. 17-183 (filed Oct. 2, 2017); Reply Comments of T-Mobile USA, Inc., GN Docket No. 17-183 (filed Nov. 15, 2017); Reply Comments of Competitive Carriers Association, GN Docket No. 17-183 (filed Nov. 15, 2017). 8 See Comments of The Mid-Band Spectrum Coalition to FCC, GN Docket No. 17-183, at 14 (filed Oct. 2, 2017) (signed by CTIA, ITI, Wi-Fi Alliance, Apple, Broadcom, Cisco, Comsearch, Ericsson, Hewlett-Packard Enterprise, Intel, Google and Alphabet Access, Nokia, Samsung, T-Mobile USA Inc., and Verizon) (“The coalition has reached consensus that an NPRM should be opened expeditiously to establish rules for terrestrial broadband use of the 6425-7125 MHz band, as discussed above.

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To advance consideration of this request, CTIA provides the attached in-depth report that evaluates relocation options for non-federal fixed point-to-point links licensed in the 6.525-7.125 GHz band and considers channelization and occupancy of the relocation bands, including the federal 7.125-8.5 GHz band. The report makes the following findings:

• Relocating fixed links out of the 6.525-7.125 GHz band would cost an estimated $148,291 per link, for a total of approximately $2.82 billion.9 The band is also used by the Broadcast Auxiliary Service, Cable Television Relay Service, Fixed Satellite Service, and Satellite Digital Audio Radio Service feeder links, which will also need to be accommodated.10

• Historic data of fixed assignments across the federal 7/8 GHz bands shows limited use (8,300 fixed assignments) and predicted flat growth.11 Channelization used for federal systems appears to fit well with the characteristics of non-federal systems in the 6.525-7.125 GHz band.12

• There are many shorter path lengths among the incumbent fixed links in the 6.525-7.125 GHz band, and these links could be candidates for relocation to the 11 GHz and 18 GHz bands. Moreover, the 11 GHz and 18 GHz bands “have sufficient channel bandwidth in most cases to accommodate shorter-length relocated paths[.]”13

Ultimately, the Comsearch report underscores the opportunity the 6 GHz band presents to enable both licensed and unlicensed operations while accommodating fixed incumbent licensees in different bands (thereby eliminating their exposure to interference risks)—a win-win-win for the public interest. CTIA encourages the Commission to promptly issue a Further Notice of Proposed Rulemaking seeking comment on licensing the 6.525-7.125 GHz band for flexible-use services and relocating incumbent Fixed Service operations from that portion of the band to other comparable facilities, while working with NTIA

However, some coalition members believe this band is best suited for unlicensed use, while other coalition members believe it is best suited for licensed use.”). 9 Comsearch Report at 56, 59-60. Specifically, with more than 30,000 fixed service frequency assignments in the 6.525-6.875 GHz segment, the cost to clear these incumbents is estimated at approximately $2.2 billion. The 6.875-7.125 GHz segment, with about 5,200 fixed service assignments, is estimated to cost $668 million to clear. Id. at 32. 10 Id. at 8. 11 Id. at 27. CTIA welcomes the opportunity to obtain more recent data and encourages the Commission to work closely with NTIA to evaluate the potential for sharing with classified systems, if any, that may operate in the 7/8 GHz band. 12 Id. at 27-29. 13 Id. at 42.

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to gain shared access to spectrum above 7.125 GHz as one option for relocation, and exploring other incumbent accommodations. This approach to the 6 GHz band would be more consistent with global developments and help maintain U.S. leadership in wireless in the dawn of 5G.14 And, importantly, as CTIA has noted, a further notice need not delay the introduction of unlicensed operations in the lower 6 GHz band, provided the Commission adopts a robust interference protection regime.

* * * Pursuant to Section 1.1206 of the Commission’s rules, this notice is being filed in ECFS. Please do

not hesitate to contact the undersigned with any questions. Sincerely, /s/ Scott K. Bergmann Scott K. Bergmann Senior Vice President, Regulatory Affairs Attachment

14 CTIA recently highlighted global developments that underscore the need to take a second look at creating a better balance in the 6 GHz band. See CTIA Feb. 3 Letter at 2. Among other things, CTIA highlighted that the International Telecommunication Union (“ITU”) will study the 6.425-7.025 GHz band for potential International Mobile Telecommunications (“IMT”) identification at the 2023 World Radiocommunication. See World Radiocommunication Conference 2019 (WRC-19), Provisional Final Acts, Resolution COM6/2 (Provisional Resolution 245), Studies on frequency-related matters for the terrestrial component of International Mobile Telecommunications identification in the frequency bands 3300-3400 MHz, 3600-3800 MHz, 6425-7025 MHz, 7025-7125 MHz, and 10.0-10.5 MHz, https://www.itu.int/pub/R-ACT-WRC.13-2019/en (indicating the WRC will study an IMT identification for the 6425-7025 MHz band in Region 1 and for the 7025-7125 MHz band on a global basis). Additionally, CTIA highlighted that many EU countries are looking at only making the lower 6 GHz band available for Wi-Fi. See CTIA Feb. 3 Letter at 2.

https://www.itu.int/pub/R-ACT-WRC.13-2019/en

https://www.itu.int/pub/R-ACT-WRC.13-2019/en

Analysis for 6 GHz Relocation (6525 – 7125 MHz)

February 11, 2020

© 2020 Comsearch, A CommScope Company. All Rights Reserved. 2

Table of Contents Analysis for 6 GHz Relocation (6525 – 7125 MHz) ......................................................................... 1

1 Background ............................................................................................................................. 4

2 Introduction ............................................................................................................................ 6

3 Phase 1 – Statistics of Current Usage ..................................................................................... 7

3.1 Link and Frequency Assignment Counts .......................................................................... 7

3.2 Counts by Area Classification ........................................................................................... 9

3.3 Counts in the Top 20 CMAs ............................................................................................ 11

3.3.1 Fixed Links in the Top 20 CMAs .............................................................................. 11

3.3.2 Mobile / Temporary Fixed Licenses in the Top 20 CMAs ....................................... 14

3.4 Path length ..................................................................................................................... 15

3.5 Fade Margin ................................................................................................................... 18

3.6 Receive Bandwidth ......................................................................................................... 21

3.7 Antenna Sizes and Performance .................................................................................... 21

3.8 Sites with Space Diversity Antennas .............................................................................. 25

4 Phase 2 - Potential for Relocating 6 GHz Links ..................................................................... 26

4.1 Federal 7/8 GHz Systems ............................................................................................... 26

4.2 Fixed Service Channel Availability in 7/8 GHz ................................................................ 31

4.3 Potential Relocation to Other Commercial Bands ......................................................... 32

4.4 Other Challenges ............................................................................................................ 34

4.4.1 Frequency Coordination ......................................................................................... 34

4.4.2 Technical Rules ........................................................................................................ 35

4.4.3 Additional Comments Based on Previous Relocation Experience .......................... 36

5 Phase 3 – Trends for Fixed Service Bands ............................................................................. 37

5.1 Paths by Band and Year .................................................................................................. 38

5.2 Frequency Assignments by Band and Year .................................................................... 40

5.3 Average Number of Frequencies per Path ..................................................................... 42

5.4 Average Channel Bandwidth .......................................................................................... 43

5.5 Frequency Assignments by Bandwidth .......................................................................... 44

5.6 Growth by Market .......................................................................................................... 47

6 Phase 4 – Estimated Costs for Relocation ............................................................................ 52

6.1 Relocation Process ......................................................................................................... 52

6.2 Relocation Scenarios ...................................................................................................... 54

https://commscope.sharepoint.com/teams/TM_Mid-BandWG/Shared%20Documents/6%20GHz/CTIA%20Report/Comsearch%20Analysis%20for%206%20GHz%20Relocation%20U-NII-7%20U-NII-8.docx#_Toc31383750

https://commscope.sharepoint.com/teams/TM_Mid-BandWG/Shared%20Documents/6%20GHz/CTIA%20Report/Comsearch%20Analysis%20for%206%20GHz%20Relocation%20U-NII-7%20U-NII-8.docx#_Toc31383750


6.3 Relocation Costs ............................................................................................................. 55

6.4 New System Costs .......................................................................................................... 58

7 Appendix ............................................................................................................................... 61

7.1 Phase 1 - Path length Distribution Charts ...................................................................... 61

7.2 Phase 1 - Digital Receiver Fade Margin Distribution Graphs ......................................... 63

7.3 Phase 1 - Antenna Size and Performance Charts ........................................................... 67

7.4 Phase 3 –CMA Site Counts for U-NII-7 & U-NII-8 combined .......................................... 69

7.5 Phase 3 –CMA Frequency Assignments for U-NII-7 & U-NII-8 combined ...................... 70

7.6 Phase 4 – Relocation Cost Estimates for Top 20 CMAs in the U-NII-7 Band ................. 71

7.7 Phase 4 – Relocation Cost Estimates for Top 20 CMAs in the U-NII-8 Band ................. 72

Contact Us ..................................................................................................................................... 73


1 Background

The FCC released a Notice of Proposed Rulemaking (NPRM) in October 2018 regarding use of

1200 MHz of spectrum in the 5925 to 7125 MHz (6 GHz) band.1 The NPRM proposes unlicensed

use consistent with existing technical rules applicable to Unlicensed National Information

Infrastructure (U-NII) devices under Part 15 that exist in the 5 GHz band just below this 6 GHz

spectrum. The proposal contemplates co-existence of these unlicensed devices with the

present licensed fixed service (FS) microwave users under certain conditions and limitations in

various portions of the band (see Figure 1), recognizing the primary status of licensed

incumbents and their rights to be protected from harmful interference.

1 Unlicensed Use of the 6 GHz Band, Notice of Proposed Rulemaking, GN docket No. 18-295, et al., FCC 18-147 (rel. Oct. 24, 2018) (“NPRM”).


Figure 1: 6 GHz band segments showing incumbent use and proposed unlicensed use


Certain stakeholders have argued that the Commission can take an alternate approach to the

band by making a portion available for licensed use. Additionally, some Fixed Service

incumbents have argued that unlicensed use without reliable AFC control may necessitate

relocation of incumbents due to harmful interference likely to happen from deployment and

operation of a very large number of anticipated unlicensed devices. The purpose of this study is

to determine the feasibility of relocating microwave incumbents from the top half of the band

and to examine the potential associated costs and barriers.

2 Introduction

This study provides an analysis of 6 GHz Relocation (in the 6525 to 7125 MHz portion of the band)

of existing point-to-point microwave incumbents by evaluating four key components, each

comprising a phase of the study:

• Phase 1 – Statistics of the current usage broken down by U-NII band segments

looking at geographical and system elements of importance;

• Phase 2 – Potential for relocation into other bands (including the federal 7/8 GHz

bands) and the challenges anticipated;

• Phase 3 – Identification of trends for the current usage and anticipated growth; and

• Phase 4 – Estimation of relocation costs on an individual and aggregate basis.

The combination of these components will help inform the magnitude, scope, and feasibility of

relocating incumbents out of the upper portion of the 6 GHz band.


3 Phase 1 – Statistics of Current Usage

3.1 Link and Frequency Assignment Counts

Table 1 shows the link and frequency assignment counts by band segment. Links and frequency

assignments are counted from the Comsearch proprietary database of licensed and applied-for2

microwave links as of December 10, 2019, supplemented by FCC data for the band segments

that include mobile assignments for Broadcast Auxiliary Service (BAS), Local Television

Transmission Service (LTTS), and Cable Television Relay Service (CARS). The counts are for the

Continental U.S. (CONUS) only, including the Gulf of Mexico, but excluding Alaska, Hawaii, and

all U.S. territories.

Band Segment U-NII-7 U-NII-8 Total

Fixed Links 14,797 4,591 19,388

Fixed Link Call Signs 16,589 4,693 21,282

Frequency Assignments 30,284 5,243 35,527

Temp. Fixed/Mobile Licenses 0 356 356

Temp. Fixed/Mobile Freq. Assignments

0 875 875

Table 1: Fixed Link and Frequency Assignments by band segment

The Fixed Link Call Signs refers to the number of unique licensed sites which can have more

than one link emanating from it, while the Fixed Link counts refer to the unique number of

microwave links. Each link may also have more than one frequency assignment and those are

counted in each direction (i.e. a typical link may have two or more frequency assignments).

2 Applied-for links are links that have not yet been granted a license by the FCC but have a pending application in the FCC’s Universal Licensing System (ULS).


Additionally, links using XPIC (cross-polarization, interference cancellation) are counted as two

frequency assignments in each direction since they have the same frequency operating on both

polarizations (vertical and horizontal).

The U-NII-73 band segment has the largest number of existing incumbents comprising over

30,000 frequency assignments in U-NII-7 (often referred to as the upper 6 GHz microwave

band). These bands are used by the common carrier and private operational fixed microwave

services. Originally split as a common carrier band for lower 6 GHz and a private microwave

band for upper 6 GHz, both band segments now include both types of microwave users and

support a variety of critical services including public safety, utilities, railroads, oil & gas

companies, etc., and are heavily used for mobile backhaul.

The U-NII-8 band segment is used by BAS, CARS, and some microwave4 users for both fixed links

and mobile / temporary fixed services. Typical fixed link uses include TV studio transmitter

links, TV intercity relay links and TV translator relay links and may transmit on both a

permanent and temporary fixed basis. Mobile licenses in these band segments are often

licensed by point-and-radius, statewide, or nationwide to represent a broadcaster or cable

company’s service area. These licensed uses are for services such as TV pickup including

3 For ease of reference, the 6525-6875 MHz and 6875-7125 MHz bands are referred to as the “U-NII-7” and “U-NII-8” bands, respectively, consistent with their characterization in the Commission’s NPRM. Use of the unlicensed identifier is not meant to endorse such regulatory status for these band segments. 4 While Part 101 microwave links are allowed in the proposed U-NII-8 segment (6875-7125 MHz), large exclusion zones by the broadcast users for TV pickup limit the microwave usage to very rural areas with a large part of the country excluded.


electronic news gathering transmitting to central receive stations and studios. The mobile and

temporary fixed licenses may include a range of frequencies in the band segments to allow

flexibility for multiple broadcasters to cover events.

3.2 Counts by Area Classification

Counts by area classification were totaled based upon the following area classification

definitions from the U.S. Census Bureau:

• Rural: All census tracts that fall outside the Census Bureau’s Urban Areas and Urban

Clusters that have a population density less than 1,000.

• Suburban: All Census Bureau Urban Clusters (regardless of pop density) plus Urban

Areas that have pop density less than 5,000, plus any tracts outside the Urban Areas

and Urban Clusters with pop density greater than or equal to 1,000.

• Urban: All Census Bureau Urban Areas that have a pop density greater than or equal

to 5,000 but less than 20,000.

• Heavy Urban: All Census Bureau Urban Areas that have pop density greater than or

equal to 20,000.

The area classification counts are for frequency assignments associated with a particular site

and its location within one of the four classifications. The frequency assignment counts are

shown in

Table 2 and a map of the four area classifications for the U.S. is shown in Figure 2.


Class U-NII-7 U-NII-8 Total

Rural 23,804 3,322 27,126

Suburban 5,659 1,524 7,183

Urban 747 365 1,112

Heavy Urban 74 32 106

Total 30,284 5,243 35,527

Table 2: Frequency Assignments by area classification

Figure 2: Area classification map


3.3 Counts in the Top 20 CMAs

Counts of sites and frequency assignments in the Top 20 CMAs were split into the categories of

Fixed Links in the U-NII-7 and U-NII-8 band segments, and Mobile / Temporary Fixed licenses in

the U-NII-8 band segment. The counts presented for the Top 20 CMAs are useful in

determining the encumbrances to deployment in major market areas. Assuming the most

populous markets would be launched with licensed flexible use services first, then these counts

can guide the initial extent of a microwave relocation effort.

3.3.1 Fixed Links in the Top 20 CMAs

An intersection of the fixed link sites with the top 20 CMA boundaries yielded the counts in

Table 3. The frequency assignments for these sites are tallied in Table 4.


Number of Sites

CMA Name U-NII-7

(6525-6875 MHz)

U-NII-8

(6875-7125 MHz)

Grand Total

2 - Los Angeles-Long Beach/Anaheim 901 130 1,031

9 - Dallas-Fort Worth, TX 419 50 469

1 - New York, NY-NJ/Nassau-Suffolk 291 31 322

10 - Houston, TX 167 32 199

3 - Chicago, IL 176 17 193

26 - Phoenix, AZ 191 28 219

18 - San Diego, CA 157 30 187

4 - Philadelphia, PA 214 22 236

17 - Atlanta, GA 250 19 269

7 - San Francisco-Oakland, CA 225 51 276

14 - Baltimore, MD 223 8 231

19 - Denver-Boulder, CO 175 44 219

8 - Washington, DC-MD-VA 188 10 198

12 - Miami-Fort Lauderdale-Hollywood 187 60 247

20 - Seattle-Everett, WA 156 18 174

11 - St. Louis, MO-IL 81 24 105

22 - Tampa-St. Petersburg, FL 163 22 185

15 - Minneapolis-St. Paul, MN-WI 127 33 160

5 - Detroit/Ann Arbor, MI 122 21 143

6 - Boston-Lowell-Brockton-Lawrence 81 27 108

Grand Total 4,494 677 5,171 Table 3: Fixed Link Sites in the Top 20 CMAs


Number of Frequency Assignments

CMA Name U-NII-7

(6525-6875 MHz)

U-NII-8

(6875-7125 MHz)

Grand Total

2 - Los Angeles-Long Beach/Anaheim

965 135 1,100

9 - Dallas-Fort Worth, TX 441 50 491

1 - New York, NY-NJ/Nassau-Suffolk

175 32 207

10 - Houston, TX 306 32 338

3 - Chicago, IL 204 28 232

26 - Phoenix, AZ 179 32 211

18 - San Diego, CA 181 17 198

4 - Philadelphia, PA 193 62 255

17 - Atlanta, GA 218 23 241

7 - San Francisco-Oakland, CA 256 19 275

14 - Baltimore, MD 231 51 282

19 - Denver-Boulder, CO 183 44 227

8 - Washington, DC-MD-VA 227 8 235

12 - Miami-Fort Lauderdale-Hollywood

193 10 203

20 - Seattle-Everett, WA 156 18 174

11 - St. Louis, MO-IL 81 30 111

22 - Tampa-St. Petersburg, FL 129 33 162

15 - Minneapolis-St. Paul, MN-WI 171 22 193

5 - Detroit/Ann Arbor, MI 122 21 143

6 - Boston-Lowell-Brockton-Lawrence

81 29 110

Grand Total 4,692 696 5,388

Table 4: Fixed Link Frequency Assignments in the Top 20 CMAs


3.3.2 Mobile / Temporary Fixed Licenses in the Top 20 CMAs

Counts of the mobile / temporary fixed licenses and frequency assignments in the U-NII-8 band

segment that are within the top 20 CMAs are estimated in Table 5. These counts are not as

precise as the fixed link counts simply because they include licenses and frequencies that are

not fixed within a licensee’s area of operation. Some of these areas of operation include

nationwide, statewide, city-based, and “other” area designations. There are some licenses and

assignments nationwide that cannot be included in our tally since the locations are

indeterminate.

Mobile / Temporary Fixed Licenses and Frequency Assignments

U-NII-8 (6875-7125 MHz)

CMA Name Number of Licenses Number of Frequency

Assignments

2 - Los Angeles-Long Beach/Anaheim 23 46

1 - New York, NY-NJ/Nassau-Suffolk 26 89

6 - Boston-Lowell-Brockton-Lawrence 6 11

19 - Denver-Boulder, CO 7 34

4 - Philadelphia, PA 7 24

10 - Houston, TX 7 49

9 - Dallas-Fort Worth, TX 6 30

17 - Atlanta, GA 10 17

8 - Washington, DC-MD-VA 11 32

3 - Chicago, IL 14 29

14 - Baltimore, MD 5 25

12 - Miami-Fort Lauderdale-Hollywood 1 5

5 - Detroit/Ann Arbor, MI 4 4

26 - Phoenix, AZ 1 1

7 - San Francisco-Oakland, CA 5 20

20 - Seattle-Everett, WA 1 14

15 - Minneapolis-St. Paul, MN-WI 1 3

22 - Tampa-St. Petersburg, FL 3 3

11 - St. Louis, MO-IL 3 4

18 - San Diego, CA 0 0

Grand Total 141 440 Table 5: Fixed Link Frequency Assignments in the Top 20 CMAs


3.4 Path length

Figure 3 shows a distribution of path lengths for the microwave links in the U-NII-7 band

segment. This helps identify the number of links that may be able to move to a higher

frequency band such as 11 or 18 GHz rather than just to a comparable frequency band like the

federal 7/8 GHz bands. In average rain conditions, links up to 15 km could be candidates for

relocation to 11 GHz, and links up to 5 km could be candidates for relocation to 18 GHz. In

areas with less rain fade or by using a stronger link budget (e.g. larger antennas), distances of

20 km and 10 km may be feasible for 11 GHz and 18 GHz, respectively. Of course, actual link

range is very much dependent on the rain region where the link is located (e.g. Florida and Gulf

coast links would need to be much shorter).


Figure 3: Link Length for U-NII-7 band segment


Figure 4: Link Length for U-NII-8 band segment


A path length distribution chart for the U-NII-8 band segment is shown in Figure 4 while the

other segments are included in the Appendix.

3.5 Fade Margin

Graphs were generated that show the digital receiver flat fade margin5 calculated from path

data in the Comsearch database considering actual link parameters (antennas, radios, transmit

powers, etc.). This information helps to understand the link design considerations needed for

possible relocation to a different band. Link fade margin is a main component in the

determination of link performance (e.g. 99.999% or 99.9999%). A comparable path

performance is typically required for relocation to a different frequency band.

Table 6 shows the digital receiver fade margin statistics for the U-NII-7 and U-NII-8 band

segments. A minimum and maximum value is calculated to account for the digital receivers

with Adaptive Coding and Modulation (ACM). ACM radios can adapt to lower modulations (and

lower throughputs) to combat fading conditions. Therefore, the fade margin varies over these

modulations from a minimum to a maximum.

5 The digital receiver flat fade margin is the difference between the unfaded receive signal level (RSL) and the receiver sensitivity / threshold at a given BER (e.g. 10-6).


Digital Receiver FM Statistics U-NII-7 U-NII-8

Median Min Fade Margin (dB) 40.40 47.23

Median Max Fade Margin (dB) 42.39 48.67

Average Min Fade Margin (dB) 40.01 45.53

Average Max Fade Margin (dB) 43.30 48.36

St Dev Min Fade Margin (dB) 7.19 10.81

St Dev Max Fade Margin (dB) 7.89 8.51 Table 6: Digital Receiver Fade Margin Statistics by band segment

Figure 5 shows a cumulative distribution graph of the U-NII-7 minimum ACM Fade Margins.

Additional graphs are included in the Appendix for the other band segments.


Figure 5: U-NII-7 Minimum ACM Fade Margins


3.6 Receive Bandwidth

The receive bandwidth of the microwave link closely relates to the amount of throughput

achievable. Larger bandwidths are generally capable of supporting larger throughputs. Table 7

shows the distribution of receive bandwidths for the incumbent systems in these band

segments. As can be seen from the data, the largest number of frequency assignments are for

10 MHz bandwidth systems. When relocating to another band, the new band (such as the

federal 7/8 GHz bands) must be able to accommodate the appropriate bandwidth radios.

Frequency Assignments by Bandwidth

Bandwidth (MHz) U-NII-7

(6525-6875 MHz) U-NII-8

(6875-7125 MHz) Grand Total

5 or less 8,483 5 8,488

10 15,068 62 15,130

20 206 82 288

25 80 5,094 5,174

30 6,447 0 6,447

40 0 0 0

50 0 0 0

60 0 0 0

Grand Total 30,284 5,243 35,527 Table 7: Receive bandwidth distribution by band segment

3.7 Antenna Sizes and Performance

Figure 6 shows the breakdown of antennas by size and performance for the U-NII-7 band

segment. These counts are of the main antenna (typically a transmit and receive antenna) and

are classified by performance type for each diameter size. The category A, B1, and B2 refer to

FCC antenna standards in Part 101.115 regarding maximum beamwidth, minimum gain, and

minimum radiation suppression for directional antennas. Generally, category A performance is


better than category B1 and B2 except for the backside angles for category B2 which are a

higher performance standard than A and B1. This is because the category B2 was created to

accommodate smaller antennas in the band with a larger beamwidth but that still have good

performance. Additionally, within category A there are different levels of performance

(standard, high performance and ultra-high performance) related to antenna designs currently

in the marketplace. For example, an ultra-high performance antenna may have a deeper dish

and larger shroud for better signal suppression outside the main lobe. These are used in

congested areas or hub site locations to mitigate interference and improve frequency

availability.

The antenna size and performance have an impact on the cost associated for the antenna and

the lease costs for an antenna on a tower. For example, a larger antenna may command a

higher price from the tower owner to lease space on the tower. Higher performance antennas

also generally reduce the potential for harmful interference at small angles off the antenna

boresight. Higher performance antennas typically cost more than a standard performance

antenna.

Figure 7 shows the antenna breakdown for the U-NII-8 band segment only. The other

individual band segment graphs can be found in the Appendix.


Figure 6: Antenna Size and Performance breakdown for U-NII-7


Figure 7: Antenna Size and Performance breakdown for U-NII-8


3.8 Sites with Space Diversity Antennas

Counts of microwave sites with space diversity antennas are shown in Table 8. Sites in this tally

constitute one end of a link. Sites may have other links emanating from them without space

diversity antennas. Most of the microwave sites with space diversity antennas are in the U-NII-7

band segment. These sites and links are least likely to be transitioned to a higher frequency

band (e.g. above 10 GHz) because the space diversity antennas were most likely needed to

combat multipath fading and/or allow them to be longer in length and still meet their desired

link reliability objective. Thus, if space diversity was required for 6 GHz, it will likely still be

required for operation in the 7/8 GHz bands.

Additionally, these sites may be more costly to relocate due to the additional costs associated

with space diversity configurations (additional material, installation costs, tower leasing cost,

etc.).

Band Sites with Space

Diversity Total Sites

% of Sites with Space Diversity

U-NII-7 (6525-6875 MHz) 7,416 28,600 25.93%

U-NII-8 (6875-7125 MHz) 135 4,859 2.78%

Totals 7,551 33,459 22.57%

Table 8: Sites with Space Diversity Antennas


4 Phase 2 - Potential for Relocating 6 GHz Links

In this section we discuss the potential for relocating fixed links and temporary fixed/mobile

systems from the 6 GHz bands into the federal 7/8 GHz bands (7125-8500 MHz), or into other

bands. We also address challenges that we anticipate in such an effort.

4.1 Federal 7/8 GHz Systems6

The federal 7/8 GHz bands (7125-8500 MHz) are allocated for fixed service across the entire

segment. The spectrum has designations for a 7 GHz band (7125-7750 MHz) as shown in Error!

Reference source not found. and an 8 GHz band (7750-8500 MHz) as shown in Figure .7 The

segments 7250-7300 and 7900-8025 are secondary allocations to the fixed service; otherwise,

the bands are fixed-service primary. Fixed service plans are laid out for channels of 2.5, 5, 10,

20, and 30 MHz bandwidth. The 30 MHz channels are listed in Table 9 and Table 10 with

additional designation of first and second assignment priority, and paired and unpaired usage.8

While the channels shown as unpaired may be used in non-standard pairings or for one-way

links, they may also be used in paired fashion.

6 Comsearch requested data from NTIA on the 7/8 GHz bands. We were told that no data is publicly available yet. We will continue to work with NTIA to obtain any data on systems operating in the 7/8 GHz bands. We were able to use data and information previously released in reports as mentioned herein. 7 Manual of Regulations and Procedures for Federal Radio Frequency Management (“NTIA Red Book”), 2017, pp. 4-216 to 4-217. 8 Id., pp. 4-219, 4-221.


Additional federal allocations in the 7/8 GHz spectrum9 are for satellite services (fixed, mobile,

meteorological, and earth-exploration), and space research. Space research (deep space)

(earth-to-space) in the 7145-7190 MHz segment is limited to Goldstone, CA. Furthermore,

footnotes to the allocation table allow:

• Passive sensor measurements of the earth from space from below 7125 to 7250 MHz

• Space operations services at up to two sites in 7125-7155 MHz

• GOES (Geostationary Operational Environmental Satellites) uplinks in 7190-7235 MHz at

not more than five sites (no satellite protection from fixed service)

• Non-federal (in addition to federal) EESS (earth exploration satellite service) (space-to-

earth) on a primary basis with case-by-case EMC analysis

In Figure 8 and Figure 9 regulatory status of each service is indicated by all capital letters for

primary and lower-case for secondary. For the satellite services, an up arrow indicates earth-

to-space transmission, while a down arrow indicates space-to-earth.

Government data showed about 8300 fixed assignments and about 10,000 total assignments in

the late 1990s and predicted flat growth.10 Described as “the Federal Government’s traditional

point-to-point microwave band”, the 7/8 GHz spectrum included about 4000 fixed assignments

for the FAA, 2200 for the military branches and coast guard, 1300 for DOE and TVA, and 400 for

DOJ.11 There also appears to be some concentration of the government assignments at

9 See 47 C.F.R. §2.106. 10 NTIA Report 00-378, “Spectrum Usage for the Fixed Services”, March 2000, p. 62. 11 Id., p.63.


facilities like military bases, test ranges, and energy installations -- the ability of commercial and

federal links to share the band would be enhanced to the extent there is a tendency for

geographical separation.


Figure 8: NTIA 7 GHz Channel Plan

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 MHz (E) 1 2 3 4 5 6 7 8 9 10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

30 MHz Plan Paired / First Priority Unpaired / Optional Pairing / First Priority Paired / First Priority

FIXED

fixed

SPACE RESEARCH ↑

FIXED-SATELLITE ↓

MOBILE-SATELLITE ↓

mobile-satellite ↓

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 GHz (E)11'

12'

13'

14'

15'

16'

17'

18'

19'

20'

21'

22'

23'

24'

25'

26'

27'

28'

29'

30'

31'

32'

33'

34'

35'

36'

37'

38'

39'

40'

41'

42'

43'

44'

45'

46'

47'

48'

49'

50'

51'

52'

53'

54'

55'

56'

57'

58'

59'

60'

61'

62'

63'

64'

65'

66'

67'

68'

69'

70'

71'

72'

73'

74'

75'

76'

77'

78'

79'

80'

81'

82'

30 MHz Plan Paired / First Priority Unpaired / Optional Pairing / First Priority Paired / First Priority

FIXED

FIXED-SATELLITE ↓

mobile-satellite ↓

METEOROLOGICAL-SATELLITE ↓

74

50

75

10

76

30

77

50

72

10

74

50

73

30

A2 A3 A4 A5 A6

C14 C15 C16 C17 C18

A7 A8 A9 A10

B10B8 B9

C13

B5 B6

C5 C6 C7 C8 C9 C10

B7

7 GHz Channel Plan (Low)

A1

D11 D12 D13 D14 D15D7 D8 D9 D10 D16 D17

C1 C2 C3 C4

71

50

B1 B2 B3

C11 C12

B4

A6' A7' A8' A9' A10'

D1 D2 D3 D4 D5 D6

A1' A2' A3' A4'

C28 C29 C30

B15

C19 C20 C21 C22 C23 C24 C25 C16 C27

7 GHz Channel Plan (High)

B11 B12 B13 B14

A5'

B13' B14' B15'

C1' C2' C3' C4' C5'

B5' B6' B7' B8' B9' B10'B1' B2' B3' B4'

C14' C15' C16' C17'C6' C7' C8'

B11' B12'

D18' D19' D20' D21' D22'D6' D7' D8' D9'

C30'C29'C9' C10' C11'

D26' D27' D28' D29' D30' D31'

C24' C25' C26' C27' C28'C18' C19' C20' C21" C22' C23'C12' C13'

D23' D24' D25' D38' D39' D40' D41'D32' D33' D34' D35' D36' D37'D16' D17'D10' D11' D12' D13' D14' D15'


Figure 9: NTIA 8 GHz Channel Plan

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 GHz (E) 35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

450

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

30 MHz Plan Paired / Second Priority Unpaired / Optional Pairing / Second Priority Paired / Second Priority

FIXED

fixed

METEOROLOGICAL-SATELLITE ↓

FIXED-SATELLITE ↑

MOBILE-SATELLITE ↑

mobile-satellite ↑

EESS ↓

Frequencies

30 MHz (A)

20 MHz (B)

10 MHz (C)

5 MHz (D)

2.5 GHz (E)

107'

108'

109'

110'

111'

112'

113'

114'

115'

116'

117'

118'

119'

120'

121'

122'

123'

124'

125'

126'

127'

128'

129'

130'

129'

130'

129'

130'

129'

130'

129'

130'

129'

130'

129'

130'

30 MHz Plan Paired / Second Priority Unpaired / Optional Pairing / Second Priority Paired / Second Priority

FIXED

SPACE RESEARCH ↓

METEOROLOGICAL-SATELLITE ↑

FIXED-SATELLITE ↑

mobile-satellite ↑

EESS ↓

78

70

80

50

81

10

82

30

84

10

84

70

85

00

8 GHz Channel Plan (Low)

C59 C60 C61 C62 C63 C64 C65 C66C40 C41 C42 C43

8 GHz Channel Plan (High)

D63 D64 D65 D65 D65 D65 D65 D65 D65D54 D55 D56 D57 D58 D59 D60 D61 D62D45 D46 D47 D48 D49 D50 D51 D52 D52D36 D37 D38 D39 D40 D41 D42 D43 D44D27 D28 D29 D30 D31 D32 D33 D34 D35D18 D19 D20 D21 D22 D23 D24 D25 D26

C58' C59' C60' C61' C62' C63' C64' C65' C66'C49' C50' C51' C52' C53' C54' C55' C56' C57'C40' C41' C42' C43' C44' C45' C46' C47' C48'C31' C32' C33' C34' C35' C36' C37' C38' C39'

B25' B26' B27' B28' B29' B30' B31' B32' B33'B16' B17' B18' B19' B20' B21' B22' B23' B25'

A20' A21' A22'

D52 D54 D55 D56 D57 D58 D59D49 D50 D51 D52 D62 D63 D64 D65D60 D61

A11' A12' A13' A14' A15' A16' A17' A18' A19'

C31 C32 C33 C34 C35 C36 C37 C38 C39

D44 D45 D46 D47 D48

C50 C51 C52 C53 C54 C55 C56 C57 C58

D35 D36 D37 D38 D39 D40 D41 D42 D43D33

A22

B16 B17 B18 B19 B20 B21 B22 B23 B25 B25 B26 B27 B28 B29 B30 B31 B32 B33

A11 A12 A13 A14 A15 A16 A17 A18 A19 A20 A21

D34

C49

D18 D19 D20 D21 D22 D23 D24 D25 D26 D27 D28 D29 D30 D31 D32

C44 C45 C46 C47 C48


Channel (Frequency in MHz)



FIRST PRIORITY CHANNELS

A1/A1' (7165 / 7465) A7/A7' (7345 / 7645) A9/A9' (7405 / 7705)

A2/A2' (7195 / 7495) A8/A8' (7375 / 7675) A10/A10' (7435 / 7735)

SECOND PRIORITY CHANNELS

A11/A11' (7765 / 8125) A13/A13' (7825 / 8185) A21/A21' (8065 / 8425)

A12/A12' (7795 / 8155) A14/A14' (7855 / 8215) A22/A22' (8095 / 8455) Table 9: The Center Frequencies of the 30 MHz Paired ChannelsTable 3: The Center Frequencies of the 30 MHz Unpaired Channels




FIRST PRIORITY CHANNELS A3 (7225) A6 (7315) A5' (7585)

A4 (7255) A3' (7525) A6' (7615)

A5 (7285) A4' (7555)

SECOND PRIORITY CHANNELS A15 (7885) A19 (8005) A17' (8305)

A16 (7915) A20 (8035) A18' (8335)

A17 (7945) A15' (8245) A19' (8365)

A18 (7975) A16' (8275) A20' (8395)

Table 10: The Center Frequencies of the 30 MHz Unpaired Channels

4.2 Fixed Service Channel Availability in 7/8 GHz

In total, the frequency plans show 22 pairs of 30 MHz bandwidth channels in the 7 and 8 GHz

bands. These pairs are designated A1/A1’ through A22/A22’. Of the 22 pairs, 7 occupy the

segments where the fixed service is secondary to other services, particularly satellite services,

while 15 pairs are primary fixed service spectrum. Pairs A4/A4’ and A5/A5’ are secondary and

in downlink spectrum for the fixed- and mobile-satellite services, while pairs A16/A16’ through

A20/A20’ are secondary and in uplink spectrum for the fixed- and mobile-satellite services. The

interference potential is terrestrial fixed service into earth station in downlink spectrum and


earth station into terrestrial fixed service in uplink spectrum. Therefore, A16 through A20 may

be usable without coordination difficulty if earth stations are not nearby12, whereas using A4

and A5 could require coordination with earth stations and agreement of the military within

large contours.

The 15 primary and 22 total pairs of 30 MHz bandwidth may be compared to 5 pairs of 30 MHz

bandwidth in U-NII-7 (6525-6875 MHz). The U-NII-8 band (6875-7125 MHz) has 10 pairs of 25

MHz. These bands all have plans for narrower channels. The U-NII-7 band presently

accommodates about 30,200 assignments, while the U-NII-8 band has only about 5200 fixed

assignments but is also used for TV pickups. The assignment data shows 10 MHz channels are

most common in U-NII-7 (with significant 30 MHz usage), and 25 MHz channels are most

common in U-NII-8.

Based on comparison of the spectrum and channels available, large-scale relocation of 6 GHz

assignments into 7/8 GHz, to operate along with the approximately 9000 federal assignments,

appears feasible.

4.3 Potential Relocation to Other Commercial Bands

There may also be opportunity to move some of the 6 GHz assignments to other commercial

bands. Likely candidate bands are 11 and 18 GHz because they have channel plans up to 80

12 Potential interference into geostationary satellites may also require management by power restrictions for small azimuth ranges towards the geostationary arc.


MHz bandwidth -- wide enough for capacity equal to or greater than 6 GHz. However, the path

lengths that may be used in these bands are limited by fading that occurs due to signal

attenuation in rain. For high availability, these bands will not accommodate the longer 6 GHz

links but may handle short to medium distances if the path length, rain region, and link budget

allow.

For example, Table 11 shows typical link distances at 11 and 18 GHz based on the location rain

fade conditions. About 20.6% of the existing U-NII-7 assignments are on links below the typical

11 GHz distance for average rain fade, 15.1 km. About 2.0% of the existing U-NII-7 assignments

are on links below the typical 18 GHz distance for average rain fade, 4.8 km. While there are

many factors involved, we expect that 11 GHz could accommodate a significant fraction of 6

GHz links. The 18 GHz band could also be considered to relocate some short 6 GHz links.

Table 11: Typical 32 QAM/100 Mb/s Link Distance at 99.999% Availability. Antenna diameter 4’ at 11 GHz, 2’ at 18 GHz.13

Similarly, it may be possible to relocate some of the U-NII-8 fixed links, and even some of the U-

NII-7 links in rural areas, to the 13 GHz band (12700-13200 MHz) where there are plans for 25

and 50 MHz bandwidth channels.

13 Kizer, G., Digital Microwave Communication (2013), pp. 442-443.

Rain Fade Example City 11 GHz Distance

(km) 18 GHz Distance

(km)

Good Seattle 18.3 9.5

Average Chicago 15.1 4.8

Poor Miami 10.1 3.3


4.4 Other Challenges

4.4.1 Frequency Coordination

Effective frequency assignment and coordination processes are needed for the 7/8 GHz bands

both initially to relocate 6 GHz links and on an ongoing basis for lengthier links that may no

longer have a home in 6 GHz. Finding coordination methods that work for all parties is a key

task for effective sharing. Interference analyses must consider the federal data for both

classified and non-classified systems, but non-classified data may not be shared with

commercial licensees and coordinators, and classified data would certainly not be shared.

Depending on federal methods such as the IRAC process to assign non-federal frequencies

could be too burdensome on the government and too lengthy and uncertain for non-federal

users. One possibility is to install a trusted band manager with cleared access to the federal

data to interface with commercial coordinators. This approach could give results on frequency

availability to non-federal users nearly as quickly as the existing Part 101 analysis and

coordination while properly protecting the federal data.

4.4.1.1 Accommodation of Mobile and Temporary Fixed Assignments

In addition to fixed links, the U-NII-8 band also has mobile and temporary fixed usage. For

example, this mobile and temporary fixed usage includes services such as TV Pickups and

helicopter video feeds within a licensed service area. We understand that federal usage of the


7/8 GHz bands also includes some similar temporary services.14 Coordination of non-fixed

operations in U-NII-8 relies on an informal system of local coordination where the licensees

work together to manage the mutual interference potential. Accommodating the U-NII-8 non-

fixed assignments in the 7/8 GHz bands would appear to require a similar system of local

coordination among the federal users and non-federal licensees. Further, segregation of these

operations onto certain channels or segments may be necessary to limit the possibility of

interference with permanent fixed links.

4.4.2 Technical Rules

Technical rules need to be added for commercial links in 7/8 GHz. We anticipate that most

likely Part 101 would be modified to cover 7125-8500 MHz. In particular, we note the following

considerations.

4.4.2.1 Wideband Channels

The FCC has added a plan of 60 MHz bandwidth channels to U-NII-515, and usage of these wide

channels is growing. To relocate the U-NII-5 paths and accommodate future growth,

implementing plans for 60 MHz channels in 7/8 GHz by concatenating channels from the

existing 30 MHz plans would be necessary. However, U-NII-7 and U-NII-8 bands have largest

channel bandwidths of 30 and 25 MHz respectively and can be accommodated in the current

NTIA band plans.

14 NTIA staff indicated in discussions that there are systems authorized for United States and Possessions (“US&P”) service area used for e.g. law enforcement surveillance and systems for tactical radio relay (“TRR”) temporary fixed links typically located at military bases. 15 There are also plans for 80 MHz bandwidth channels in the 11 and 18 GHz bands.


4.4.2.2 Antenna Performance Requirements

The 7/8 GHz antenna requirements in the federal NTIA Red Book are less stringent compared to

the Part 101 requirements for the 6 GHz bands. The federal requirement is simply for at

minimum a standard performance 4-foot diameter parabolic antenna. Following this existing

standard for relocation and future growth of commercial links in 7/8 GHz would be detrimental

to frequency re-use and sharing. We recommend that commercial links should be required to

use antennas comparable to the existing 6 GHz requirements which are, generally, high

performance antennas 6-foot diameter and above as Category A, standard performance

antennas 6-foot diameter and above as Category B1, and high performance 3-foot and 4-foot

diameter antennas as Category B2. Further, a 4-foot diameter high or ultra-high performance

antenna may be permissible as Category A for 7/8 GHz.

4.4.2.3 Minimum Payload Capacity

Part 101 has a minimum payload capacity requirement of 4.4 bps/Hz in the 6 GHz bands to

ensure efficient spectrum usage. Adaptive links must meet the minimum payload 99.95% of

the time.16 These requirements should also apply to commercial links in the 7/8 GHz bands.

4.4.3 Additional Comments Based on Previous Relocation Experience

Based on our previous experience working with NTIA and the Federal Agencies, we would

strongly suggest working together early with all stakeholders to agree on calculation

methodologies and criteria (propagation models, interference objectives, etc.) to avoid delays

16 See 47 C.F.R. §101.141.


and discrepancies. In AWS relocation when issues were identified, many licensees had to

submit multiple design scenarios until they received approval. Transparency in calculations and

agreed-upon options for mitigation would be beneficial and streamline the relocation effort.

5 Phase 3 – Trends for Fixed Service Bands

In order to identify trends in the Fixed Service bands, we compiled data from snapshots of the

Comsearch database for the past five years. The first snapshot was taken from the database as

of December 31, 2015 and then at the end of each calendar year up to December 31, 2019. As

was done in Phase 1 of this report, we tabulate all licensed and applied-for17 links and included

only links in CONUS plus the Gulf of Mexico. Paths that include passive repeaters are counted

as one path and the frequency assignments for those reflect the number of actual radio

terminals.

The trending data is intended to inform on which bands are growing, declining, or static to

better understand the implications of such for relocation. Declining or static trends may inform

that the counts and associated costs to relocate are fairly stable, while in the growing band

segments the costs to relocate may increase over time. Additionally, we provide trending data

for the 11 and 18 GHz bands to help inform whether these bands could be useful in relocation

of shorter links.

17 Applied-for links are links that have not yet been granted a license by the FCC but have a pending application in the FCC’s Universal Licensing System (ULS).


5.1 Paths by Band and Year

Table 12 and Figure 10 show the path counts for each band over the last five years. The growth

trends are seen in the 11 GHz band and to a lesser extent the 18 GHz band, while static trends

for the 6.7 GHz (U-NII-7) and 7 GHz (U-NII-8) bands are apparent.

Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-

19700 MHz) Grand Total

2015 15,325 4,792 34,724 18,060 72,901 2016 14,940 4,821 38,538 18,354 76,653 2017 14,860 4,629 43,060 18,478 81,027 2018 14,767 4,592 47,227 18,839 85,425 2019 14,855 4,592 51,363 19,020 89,830

Table 12: Number of paths by band 2015 - 2019

Figure 10: Number of paths by band 2015 – 2019


For a different view of this data we calculated the percentage year-over-year (YOY) differences

in the Figure and Table below. The 11 GHz band growth rate is significantly higher than the

others which could present congestion issues if a large number of shorter-length paths attempt

to move to 11 GHz.

Figure 11: Percentage change in number of paths year-over-year

Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-


2015 2016 -2.51% 0.61% 10.98% 1.63% 5.15% 2017 -0.54% -3.98% 11.73% 0.68% 5.71% 2018 -0.63% -0.80% 9.68% 1.95% 5.43% 2019 0.60% 0.00% 8.76% 0.96% 5.16%

Table 13: Percentage change in number of paths year-over-year


5.2 Frequency Assignments by Band and Year

Like the previous section, frequency assignments are tabulated by band over the last five years

(2015 – 2019). Similar growth trends appear for the 11 GHz band and static trends for the U-

NII-7 and U-NII-8 bands are apparent. The dip in frequency assignments for the 18 GHz band in

2019 is because of a large number of private cable frequency deletions in that band.

Figure 12: Number of Frequency Assignments 2015 to 2019


Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-


2015 30,746 5,227 93,069 54,064 183,106 2016 30,070 5,266 103,611 54,701 193,648 2017 29,986 5,066 118,356 55,551 208,959 2018 30,012 5,049 133,561 56,790 225,412 2019 30,424 5,247 148,303 54,610 238,584

Table 14: Number of frequency assignments 2015 - 2019

The year-over-year percentage change in frequency assignments by band is shown in the Figure

and Table below.

Figure 13: Percentage change in number of Frequency Assignments year-over-year


Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-


2015 2016 -2.20% 0.75% 11.33% 1.18% 5.76% 2017 -0.28% -3.80% 14.23% 1.55% 7.91% 2018 0.09% -0.34% 12.85% 2.23% 7.87% 2019 1.37% 3.92% 11.04% -3.84% 5.84%

Table 15: Percentage change in number of Frequency Assignments year-over-year

5.3 Average Number of Frequencies per Path

The tabulation of average number of frequencies per path is useful to see trends in deploying

additional frequencies on a path that can increase capacity payload. This trend could inform

the need for multiple frequency assignments in a relocation band. Table 16 and Figure 14

below show a general trend of increased average number of frequencies per path with the

exception of the U-NII-8 band.

Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-


2015 1.56 2.83 2.12 1.9 2.1025 2016 1.57 1.38 2.16 1.94 1.7625 2017 1.55 2.13 2.22 1.85 1.9375 2018 1.86 1.48 2.59 2.22 2.0375 2019 2.28 1.52 3.1 2.7 2.4

Grand Total 1.764 1.868 2.438 2.122 2.0744 Table 16: Average number of frequencies per path 2015 -2019


Figure 14: Average number of frequencies per path 2015 – 2019

5.4 Average Channel Bandwidth

The average channel bandwidth trend data can inform on whether wider bandwidth channel

options are needed for the relocation band. FCC Rules in the past limited channel bandwidth to

10 MHz in the 6.7 GHz (U-NII-7) band. The largest available channel bandwidth available now is

30 MHz for 6.7 GHz which has become increasingly popular in recent years. As seen in Figure

15 and Table 17 below this trend of increased bandwidth channels is apparent in all bands

except U-NII-8 where it has remained constant. This data also shows that the 11 and 18 GHz

bands should have sufficient channel bandwidth in most cases to accommodate shorter-length

relocated paths from U-NII-7, & U-NII-8.


Year U-NII-7

(6525-6875 MHz)

U-NII-8 (6875-7125

MHz)

11 GHz (10700-

11700 MHz)

18 GHz (17700-


2015 10.6 24.7 35.6 35.8 26.68 2016 11 24.7 37 36.5 27.30 2017 11.5 24.7 38.6 37.8 28.15 2018 11.9 24.7 40.1 39.1 28.95 2019 12.5 24.7 42 42.9 30.53

Table 17: Average channel bandwidth 2015 -2019

Figure 15: Average channel bandwidth 2015 – 2019

5.5 Frequency Assignments by Bandwidth

The frequency assignment counts by bandwidth show which channel bandwidths are on the

rise or are declining over the last five years. The trends for the larger channel bandwidths in U-


NII-7 (30 MHz) are on the rise over this time while the smaller bandwidths in U-NII-7 (5 and 10

MHz) are on the decline, and the U-NII-8 band is static. The 11 GHz and 18 GHz bands also

show a rise in use of wider channels over the 2015 to 2019 time period.

Figure 16: Frequency Assignments by Bandwidth for U-NII-7 2015 – 2019


Figure 17: Frequency Assignments by Bandwidth for U-NII-8 2015 – 2019

Figure 18: Frequency Assignments by Bandwidth for 11 GHz band 2015 – 2019


Figure 19: Frequency Assignments by Bandwidth for 18 GHz band 2015 – 2019

5.6 Growth by Market

Counts of sites and frequency assignments in the top 20 CMAs from 2015 to 2019 are

presented in the following Figures. The associated tabular data can be found in the Appendix.


Figure 20: Site Counts for U-NII-7 & U-NII-8 combined (2015 – 2019)


Figure 21: Frequency Assignments for U-NII-7 & U-NII-8 combined (2015 – 2019)

To provide a better view of some of the markets in the graph, we removed the Los Angeles and

Dallas CMAs as shown below.


Figure 22: Site Counts for U-NII-7 & U-NII-8 combined (2015 – 2019) minus L.A. & Dallas


Figure 23: Frequency Assignments for, U-NII-7 & U-NII-8 combined (2015 – 2019) minus L.A. & Dallas


6 Phase 4 – Estimated Costs for Relocation

This phase provides cost estimations to relocate existing microwave links from the upper portion

of the 6 GHz band (6525 -7125 MHz) into other licensed bands like the commercial 11 GHz and

18 GHz bands, and federal 7/8 GHz band. Relocation scenarios presented in this study are based

on path length. Our modeling assumes that links up to 5 km can be relocated to the 18 GHz band,

links between 5 and 15 km can be relocated to the 11 GHz band, and links greater than 15 km

can be relocated to the 7/8 GHz band. Links utilizing space diversity antennas will likely transition

to the 7/8 GHz band because they were most likely designed to combat multipath fading and/or

allow them to be longer in length and still meet their desired link reliability objective.

Based on our experience in other bands (e.g., PCS, AWS) we expect up to 2% of the links to be

non-operational. These links will have a licensed status in the FCC’s Universal Licensing System

(ULS) but are not being utilized by the incumbents. Negotiation may be required with these

incumbents and a certain cost may be associated with updating the records in ULS. Cost estimates

have been derived based on previously obtained quotes from equipment manufactures and

third-party installation companies. The typical relocation process is described below to help

provide context to the tasks involved with relocating microwave systems.

6.1 Relocation Process

1. Spectrum Sharing Studies / Interference Analysis: This effort identifies the most critical

links requiring relocation and will provide an understanding of the impact the


incumbent systems will have from new entrants. We would undertake this analysis to

prioritize links or systems for relocation.

2. Site Audits and RF Measurements: Prior to initiating relocation process, in-field RF

measurements can be performed to verify if the incumbent’s link is operational and

confirm the configuration is consistent with the license.

3. Estimate Comparable Relocation Costs: The first step for relocation cost estimation is

to prepare an as-built, link design review to provide a baseline estimate of the

performance of the existing fixed service (FS) links. This estimate is necessary for

comparison with replacement link designs towards the goal of providing the licensee

with comparable facilities. The next step is to determine what is the most economical

relocation option. Depending on various factors such as path length, geographical

location and frequency availability the link can be relocated to either 7/8 GHz, 11 GHz or

18 GHz bands. In some cases, providing backhaul via fiber could be a prudent option.

4. Incumbent Negotiation and Contract Execution: Negotiation is typically the key

element to the successful and timely clearing of spectrum. The goal of each negotiation

will be to outline the relocation terms and conditions for a turnkey installed solution or

a cash settlement. The signed agreement will serve as the basis for the ongoing project

management of the incumbent’s progress in meeting their relocation commitment.


6.2 Relocation Scenarios

Based on the results from Phase 1 (Table 1), we know there are 19,388 unique fixed microwave

links in the upper portion of the 6 GHz band. Microwave link counts based on path length in U-

NII 7 and U-NII 8 are provided in Table 18.

Table 18: 6 GHz fixed microwave link counts based on path length

All space diversity links are included in the above count. Temporary fixed and mobile licenses

have not been included in this study.

Existing links in the 6 GHz band can be relocated to other licensed bands based on path length.

Relocation options are discussed below.

1. Relocation to 11 GHz band: Existing links in the 6 GHz (6525-7125 MHz) band with path

length under 15 km may be relocated to the 11 GHz band. This is dependent on rain

region in which the link resides. (e.g. Florida and Gulf coast links would need to be much

shorter.)

2. Relocation to 18 GHz band: Existing links in the 6 GHz (6525-7125 MHz) band with path

length up to 5 km may be relocated to the 18 GHz band. This is dependent on rain

Number of Links Path Length

Band Up to 5 km 5-15 km >15 km Total

6.7 GHz (6525-6875 MHz) U-NII 7 345 2,753 11,699 14,797

7 GHz (6875-7125 MHz) U-NII 8 136 727 3,728 4,591

Totals 481 3,480 15,427 19,388


region in which the link resides. (e.g. Florida and Gulf coast links would need to be much

shorter.)

3. Relocation to 7/8 GHz band: Existing links in the 6 GHz (6525-7125 MHz) band with

path length greater than 15 km may be relocated to a comparable federal frequency

band of 7/8 GHz.

4. Decommissioned Links: Based on our experience in other bands, we expect up to 2% of

the links to be non-operational. These links will have a licensed status on FCC ULS but

are not being utilized by the incumbents. Negotiation may be required with these

incumbents and a certain cost may be associated with updating the records on ULS.

6.3 Relocation Costs

Relocation cost estimates for scenarios discussed in section 6.2 are provided below. A per-link

turnkey relocation cost of $148,291 has been used to relocate existing 6 GHz links to other

licensed bands. The breakdown of this per-link cost is shown in Table 23 of Section 6.4.

Negotiation fee of $10,000 has been used for decommissioned links.


Table 19 below provides relocation cost estimates for the 6.7 & 7 GHz bands.

Relocation Scenario: 6.7 & 7 GHz Bands

Number of Links Cost Per Link Total Cost

7/8 GHz 15,118 $148,291 $2,241,863,338

11 GHz 3,411 $148,291 $505,820,601

18 GHz 471 $148,291 $69,845,061

Decommissioned 388 $10,000 $3,880,000

Totals 19,388 (n/a) $2,821,409,000

Table 19: Relocation cost estimates for 6.7 & 7 GHz bands

Table 20 below provides relocation cost estimates for links in U-NII 7.

Relocation Scenario: U-NII 7


7/8 GHz 11,465 $148,291 $1,700,156,315

11 GHz 2,698 $148,291 $400,089,118

18 GHz 338 $148,291 $50,122,358

Decommissioned 296 $10,000 $2,960,000

Totals 14,797 (n/a) $2,153,327,791 Table 20: Relocation cost estimates for links in U-NII 7

Table 21 below provides relocation cost estimates for links in U-NII 8.

Relocation Scenario: U-NII 8


7/8 GHz 3,653 $148,291 $541,707,023

11 GHz 713 $148,291 $105,731,483

18 GHz 133 $148,291 $19,722,703

Decommissioned 92 $10,000 $920,000

Totals 4,591 (n/a) $668,081,209 Table 21: Relocation cost estimates for links in U-NII 8


Assuming the most populous markets would be launched with licensed flexible use services

first, relocation cost estimates for the 6.7 and 7 GHz bands in the top 20 CMAs are provided in

Table 22. All microwave links with at least one end located within these CMAs have been

included to derive estimated relocation cost estimates. If each end of the link is in different top

20 CMAs, the link has been counted twice. Relocation cost estimates for U-NII-7 and U-NII-8

bands individually are provided in the appendix.


CMA Name

Link Counts – 6.7 & 7 GHz Bands

Decommissioned Links

Relocated to 7/8, 11 & 18 GHz

Bands

Cost Per Link - Decommissioned

Links

Cost Per Link -

Relocation to 7/8, 11 & 18 GHz

Bands

Total Relocation

Cost

Atlanta 156 3 153 $10,000 $148,291 $22,718,523

Baltimore 130 2 128 $10,000 $148,291 $19,001,248

Boston 76 2 74 $10,000 $148,291 $10,993,534

Chicago 126 2 124 $10,000 $148,291 $18,408,084

Dallas 284 6 278 $10,000 $148,291 $41,284,898

Denver - Boulder

156 3 153 $10,000 $148,291 $22,718,523

Detroit 91 1 90 $10,000 $148,291 $13,356,190

Houston 136 3 133 $10,000 $148,291 $19,752,703

Los Angeles 645 12 633 $10,000 $148,291 $93,988,203

Miami 161 3 158 $10,000 $148,291 $23,459,978

Minneapolis 106 3 103 $10,000 $148,291 $15,303,973

New York 197 4 193 $10,000 $148,291 $28,660,163

Philadelphia 149 3 146 $10,000 $148,291 $21,680,486

Phoenix 147 3 144 $10,000 $148,291 $21,383,904

San Diego 115 3 112 $10,000 $148,291 $16,638,592

San Francisco

185 4 181 $10,000 $148,291 $26,880,671

Seattle 115 2 113 $10,000 $148,291 $16,776,883

St. Louis 75 2 73 $10,000 $148,291 $10,845,243

Tampa 109 2 107 $10,000 $148,291 $15,887,137

Washington 122 2 120 $10,000 $148,291 $17,814,920

Totals 3,281 65 3,216 (n/a) (n/a) $477,553,856 Table 22: Relocation cost estimates for links in the top 20 CMAs (6.7 & 7 GHz bands)

6.4 New System Costs

Based on quotes previously obtained from equipment manufacturers and third-party installation

companies, a per-link turnkey relocation cost of $148,291 is derived below in Table 23. Our data

indicates radio pricing for a typical link does not vary significantly based on frequency band;

therefore, the same per-link relocation cost has been used for all three licensed bands.


While radio costs can vary depending on factors such as throughput, power requirements

(standard or high power) and redundancy configuration (1+0, 1+1, MHSB), our modeling assumes

these variances would average towards the typical cost over the scope of the entire project.

There can also be additional costs involved if a structural analysis is required due to increase in

antenna size.

Sample quote to relocate a 6 GHz link into the 11 GHz band is provided below in Table 23.

WORK / PRODUCT DESCRIPTION Unit Price Qty Extended Qty Extended TOTAL

Initial Assessment

Interference Analysis (per market) $5,000 1 incl 1 incl $5,000

Site Audits and RF Measurement (per link) $4,000 incl incl $4,000

Subtotal Initial Assessment $9,000 $ - $ - $9,000

Frequency Coordination & Licensing

Interference Analysis and PCN Response (per link)

$1,170 1 incl 1 incl $1,170

FCC Licensing with FCC Fees (per site) $1,040 incl incl $1,040

Subtotal Coordination & Licensing $2,210 $ - $ - $2,210

MICROWAVE EQUIPMENT

Radio 11 GHz, NP, Std Power $24,019.71 1 $24,019.71 1 $24,019.71 $48,039.42

Orderwire, Rack & Fuse Panel, Software, Manuals, Node License,

incl incl incl

Cables, connectors, hardware and misc. incl 1 incl 1 incl

Subtotal Radio Equipment $21,836.10 $24,019.71 $24,019.71 $48,039.42

Antenna Systems

6' Cat A Standard Antenna with radome (strut included)

$2,805.00 1 $2,805.00 1 $2,805.00 $5,610.00

Elliptical Waveguide 11ghz $13.20 120 $1,584.00 305 $4,026.00 $5,610.00

Elliptical Waveguide Connector Fixed Tuned $294.41 2 $588.82 2 $588.82 $1,177.64

Twist-flex waveguide adaptor (2') CPR/CPR $467.26 1 $467.26 1 $467.26 $934.52

Pressure Window for EW90 $66.52 2 $133.04 3 $199.57 $332.61

EW90 Hanger Kit (pkg of 10) $31.27 12 $375.18 11 $343.92 $719.10

3/8" X 1" Hardware Kit with Lockwasher & Nut (pkg of 10)

$9.42 12 $113.05 11 $103.63 $216.67

Hoisting Grip for EW63 $36.00 1 $36.00 2 $ 72.01 $108.01

Dehydrator $3,124.14 1 $3,124.14 1 $3,124.14 $6,248.28

4 Port pressure manifolds with valves & gauges $263.72 1 $263.72 1 $263.72 $527.44

Dehydrator Wall Mount Shelf $172.25 1 $172.25 1 $172.25 $344.50


Waveguide Wall Feed Through Single EW90 $33.72 1 $33.72 1 $33.72 $67.44

Entry Port Boot for EW90 (4") $165.00 1 $165.00 1 $165.00 $330.00

$ - $ - $ - $ -

Subtotal Antenna Systems $7,481.91 $9,861.19 $12,365.03 $22,226.21

Ancillary

Universal ground buss bar kit (bar and hardware), 1/4" x 4" x 12"

$44 1 $44 1 $44 $88

Isolator Kit $72 1 $72 1 $72 $143

Bracing Kit $39 1 $39 1 $39 $77

Ground Bar $58 1 $58 1 $58 $117

Subtotal Ancillary $212.30 $212.30 $212.30 $424.60

Installation Services

Kickoff Meeting $347 1 $347 1 $347 $693

Site Survey $2,357 1 $2,357 1 $2,357 $4,715

System Engineering & Traffic Planning $1,368 1 $1,368 1 $1,368 $2,737

MOP Generation and Sign off $138 1 $138 1 $138 $275

Project Management $1,650 1 $1,650 1 $1,650 $3,300

Equipment Delivery (Warehouse to Site(s)) $1,341 1 $1,341 1 $1,341 $2,681

Antenna System Installation (Antenna, Mounts etc.)

$4,998 1 $4,998 1 $4,998 $9,997

Waveguide Installation $12 150 $1,815 150 $1,815 $3,630

Pressurization System Install $825 1 $825 1 $825 $1,650

Path Alignment and Testing $1,320 1 $1,320 1 $1,320 $2,640

Radio Equipment Installation, (Lab Assembly, Field Installation)

$4,620 1 $4,620 1 $4,620 $9,240

Radio Equipment Testing $1,438 1 $1,438 1 $1,438 $2,877

Ancillary Equipment install $825 1 $825 1 $825 $1,650

Cutover from old system to new $1,320 1 $1,320 1 $1,320 $2,640

De-installation of 2.1 GHz System $4,763 1 $4,763 1 $4,763 $9,526

Mobilization / Demobilization $3,520 1 $3,520 1 $3,520 $7,040

Job Completion Documentation $550 1 $550 1 $550 $1,100

Subtotal Installation Services $33,195.19 $33,195.19 $66,390.37

Sales Tax (if applicable)

TOTAL $67,288.38 $69,792.22 $148,291

Table 23: Estimated cost for turnkey microwave link relocation


7 Appendix

7.1 Phase 1 - Path length Distribution Charts



7.2 Phase 1 - Digital Receiver Fade Margin Distribution Graphs





7.3 Phase 1 - Antenna Size and Performance Charts



7.4 Phase 3 –CMA Site Counts for U-NII-7 & U-NII-8 combined

Number of

Sites CMA

Year Atl

anta

Bal

tim

ore

Bo

sto

n

Ch

icag

o

Dal

las

De

nve

r -

Bo

uld

er

De

tro

it

Ho

ust

on

Los

An

gele

s

Mia

mi

Min

ne

apo

lis

Ne

w Y

ork

Ph

ilad

elp

hia

Ph

oe

nix

San

Die

go

San

Fra

nci

sco

Seat

tle

St. L

ou

is

Tam

pa

Was

hin

gto

n

Total

2015 250 219 146 202 343 200 138 236 1,007 228 189 321 232 239 173 271 186 110 169 204 5,063

2016 250 224 134 208 372 203 184 208 1,003 226 180 327 234 230 170 279 184 107 171 202 5,096

2017 263 226 129 191 427 209 204 205 1,022 232 155 323 232 229 170 273 182 108 183 205 5,168

2018 260 226 109 196 450 212 182 199 1,017 230 187 316 243 222 178 275 182 107 187 201 5,179

2019 269 234 108 195 469 217 143 199 1,088 247 162 323 236 217 185 276 174 107 185 198 5,232


7.5 Phase 3 –CMA Frequency Assignments for U-NII-7 & U-NII-8 combined

Number of

Frequency

Assignments CMA

Year Atl

anta

Bal

tim

ore

Bo

sto

n

Ch

icag

o

Dal

las

De

nve

r -

Bo

uld

er

De

tro

it

Ho

ust

on

Los

An

gele

s

Mia

mi

Min

ne

apo

lis

Ne

w Y

ork

Ph

ilad

elp

hia

Ph

oe

nix

San

Die

go

San

Fra

nci

sco

Seat

tle

St. L

ou

is

Tam

pa

Was

hin

gto

n

Total

2,015 254 219 148 212 347 205 138 254 1,046 238 203 334 235 244 184 273 188 120 169 212 5,223

2,016 255 228 136 222 376 208 184 225 1,044 236 193 340 241 235 183 283 186 113 171 211 5,270

2,017 269 230 131 203 438 215 204 213 1,074 241 159 339 239 239 185 277 182 114 187 214 5,353

2,018 266 230 111 204 467 220 182 207 1,080 239 190 327 248 233 197 279 182 113 195 212 5,382

2,019 275 238 110 202 491 225 143 207 1,155 255 164 339 241 230 209 282 174 113 193 203 5,449


7.6 Phase 4 – Relocation Cost Estimates for Top 20 CMAs in the U-NII-7 Band

CMA Name

Link Counts

- U-NII-7

(6525-6875 MHz)



Bands


Links

Cost Per Link -

Relocation to 7/8, 11 &

18 GHz Bands

Total Relocation

Cost

Atlanta 137 3 134 $10,000 $148,291 $19,900,994

Baltimore 122 2 120 $10,000 $148,291 $17,814,920

Boston 49 1 48 $10,000 $148,291 $7,127,968

Chicago 109 2 107 $10,000 $148,291 $15,887,137

Dallas 237 5 232 $10,000 $148,291 $34,453,512

Denver - Boulder 114 2 112 $10,000 $148,291 $16,628,592

Detroit 70 1 69 $10,000 $148,291 $10,242,079

Houston 104 2 102 $10,000 $148,291 $15,145,682

Los Angeles 519 10 509 $10,000 $148,291 $75,580,119

Miami 104 2 102 $10,000 $148,291 $15,145,682

Minneapolis 74 2 72 $10,000 $148,291 $10,696,952

New York 168 3 165 $10,000 $148,291 $24,498,015

Philadelphia 127 3 124 $10,000 $148,291 $18,418,084

Phoenix 120 2 118 $10,000 $148,291 $17,518,338

San Diego 85 2 83 $10,000 $148,291 $12,328,153

San Francisco 134 3 131 $10,000 $148,291 $19,456,121

Seattle 100 2 98 $10,000 $148,291 $14,552,518

St. Louis 49 1 48 $10,000 $148,291 $7,127,968

Tampa 87 2 85 $10,000 $148,291 $12,624,735

Washington 113 2 111 $10,000 $148,291 $16,480,301

Totals 2,622 52 2570 (n/a) (n/a) $381,627,870


7.7 Phase 4 – Relocation Cost Estimates for Top 20 CMAs in the U-NII-8 Band

CMA Name

Link Counts

- U-NII-7

(6525-6875 MHz)



Bands


Links

Cost Per Link -

Relocation to 7/8, 11 & 18 GHz

Bands

Total Relocation

Cost

Atlanta 19 0 19 $10,000 $148,291 $2,817,529

Baltimore 8 0 8 $10,000 $148,291 $1,186,328

Boston 27 1 26 $10,000 $148,291 $3,865,566

Chicago 17 0 17 $10,000 $148,291 $2,520,947

Dallas 47 1 46 $10,000 $148,291 $6,831,386

Denver - Boulder 42 1 41 $10,000 $148,291 $6,089,931

Detroit 21 0 21 $10,000 $148,291 $3,114,111

Houston 32 1 31 $10,000 $148,291 $4,607,021

Los Angeles 126 2 124 $10,000 $148,291 $18,408,084

Miami 57 1 56 $10,000 $148,291 $8,314,296

Minneapolis 32 1 31 $10,000 $148,291 $4,607,021

New York 29 1 28 $10,000 $148,291 $4,162,148

Philadelphia 22 0 22 $10,000 $148,291 $3,262,402

Phoenix 27 1 26 $10,000 $148,291 $3,865,566

San Diego 30 1 29 $10,000 $148,291 $4,310,439

San Francisco 51 1 50 $10,000 $148,291 $7,424,550

Seattle 15 0 15 $10,000 $148,291 $2,224,365

St. Louis 26 1 25 $10,000 $148,291 $3,717,275

Tampa 22 0 22 $10,000 $148,291 $3,262,402

Washington 9 0 9 $10,000 $148,291 $1,334,619

Totals 659 13 646 (n/a) (n/a) $95,925,986


Contact Us

Joe Marzin Director, Technology Group

19700 Janelia Farm Blvd, Ashburn VA 20147 USA Office: +1 703 726 5642 | [email protected]

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