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FCC 15-47 Spectrum Sharing in the 3.5GHz Band

Explanation of FCC 15-47 Comments and their importance to IEEE 802.11, the submission process, and future regulatory responses.

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FCC 15-47 Spectrum Sharing in the 3.5GHz Band

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  1. FCC 15-47 Spectrum Sharing in the 3.5GHz BandComments Approval Date: 2015-07-13 Authors: Rich Kennedy, MediaTek

  2. Abstract This presentation is intended to explain the Comments for FCC 15-47, previously approved by the Regulatory SC and the 802.11WG, the process we should use to have it submitted to the FCC, and why we should use this process in future regulatory responses. Rich Kennedy, MediaTek

  3. Summary • The 3.5 GHz Band Today and the Report & Order • The FCC 15-47 Comments reflect what is important to IEEE 802.11 • Why did the 802 EC not approve our May document • What the current EC rules allow • Modification of the May document • Approval and submittal Rich Kennedy, MediaTek

  4. The 3.5 GHz Band Today • 3550-3650 MHz • Federal radars • Fixed Satellite Services (FSS) • 3650-3700 MHz • FSS • WiMAX including utility networks • IEEE 802.11y • Exclusion zones • Naval radars • FSS Rich Kennedy, MediaTek

  5. The 3.5 GHz Band Rich Kennedy, MediaTek

  6. Footnote US349: The band 3650-3700 MHz is also allocated to the Federal radiolocation service on a non-interference basis for use by ship stations located at least 44 nautical miles in off-shore ocean areas on the condition that harmful interference is not caused to non-Federal operations. Rich Kennedy, MediaTek

  7. Federal Exclusion Zones Rich Kennedy, MediaTek

  8. FSS Protection Zones in 3650-3700 MHz Rich Kennedy, MediaTek

  9. FCC 15-47 Report & Order • Final rules for operation in this band • Three level spectrum sharing • Spectrum Access System (SAS) database control • Licensed incumbents • Part 96: Priority Access Licenses (PALs) and General Authorized Access (GAA) • Changes from FCC 12-148 NPRM • 3-year PAL non renewable term vs 1-year renewable 5 times • Federal exclusion zones reduced by 77% • No 5-year limit on grandfathered FSS • Addition of Environmental Sensing Capability (ESC) • New categories: • Category A CBSDs for lower-power (e.g., small cell) • Category B CBSDs, authorized for higher-power, directional, higher-gainuse • No reservation for Contained Access Facilities (“CAFs”). Rich Kennedy, MediaTek

  10. The Tiers • First Tier - Incumbents • Federal users • Fixed Satellite Services (FSS) • Second Tier – Priority Licenses (PALs) • Must not interfere with Tier 1 • 10 MHz channels in the 3550-3650 MHz band [none in 3650-3700 MHz] • On a census-tract basis, for three-year terms, no option to renew • Dynamically assigned via Spectrum Access System (SAS) • A maximum of 70 MHz in any census tract • Licensees may hold a maximum of four licenses in any area, i.e. 40 MHz • Third Tier – General Authorized Access • Must not interfere with Tiers 1 and 2 • License-by-rule framework • May access PA spectrum when it is not in “use” Rich Kennedy, MediaTek

  11. TX Power Limits Rich Kennedy, MediaTek

  12. Comments Approved in May • IEEE 802.11 will not develop a standard, and the industry will not develop silicon with the current restrictions • Coastal exclusion zones prevent use in some major metropolitan areas; timing of proposed further reductions is unclear • FSS protection zones eliminate other population centers • Similar restrictions prevented hindered 802.11y development • Unclear spectrum availability slowing 802.11af development • The FCC should understand that Wi-Fi’s success is based on low-cost silicon, enabled by spectrum certainty Rich Kennedy, MediaTek

  13. Why the EC Rejected the May Comments • Two members asked to make wording changes which would have softened what needs to be a strong message • Although the document claimed to represent IEEE 802, it was actually narrowly representative of 802.11 • There was concern that the 802.11 message was not aligned with what 802.22 would like to see in the response • 802.22 did not develop a response of their own • The 802.18 Chair abstained because he objected to 802.11/15 sending it directly to the EC, and not through his group Rich Kennedy, MediaTek

  14. How We Will Submit it to the FCC • What the 802 EC allows • Working Group documents can be submitted to government agencies under their WG name and the WG Chair’s signature • Sponsor subgroup communications shall be identified in the first paragraph as the view of only the Sponsor subgroup and shall be issued by the Sponsor subgroup(s) Chair(s) and shall include the Sponsor Chair in the distribution. Such statements shall not bear the IEEE, the IEEE-SA, or IEEE 802 LMSC logos • This effort • Adrian has submitted the updated document to the EC for 5-review in the expectation that the WG will approve the updated document. • TBC – no motion to block was made, and we can proceed with the motion on the updated document. • TBC – or a motion to block was made, and failed, and we can proceed. • TBC – A motion to block succeed. • TBC … • Approve the updated document in the 802.11 Opening Plenary Edit options when outcome of opening EC known Rich Kennedy, MediaTek

  15. What I Changed in the May Document • Changed all references to IEEE 802 to IEEE 802.11 • Added a sentence to the conclusion • IEEE 802.11 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate. • This will prevent some of the potential blocking votes Rich Kennedy, MediaTek

  16. Motion • Approve transmission of document 11-15/683r4 (https://mentor.ieee.org/802.11/dcn/15/11-15-0683-04-0reg-comments-in-fcc-15-47.docx) to the FCC in response to FCC docket 15-47, granting the 802.11 WG chair editorial license • Moved by: • Seconded by: • Discussion? • Vote: • The motion is approved / not approved Rich Kennedy, MediaTek

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