October 8, 2014
SENT BY EMAIL: [email protected]
Senior Director Spectrum Development and Operations Industry Canada 300 Slater Street (JETN, 15th) Ottawa, ON K1A 0H5
Re. Canada Gazette, Part I, August 2014, Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas, DGSO-003-14
ccROUTE Inc. is in receipt of DGSO-003-14 dated August 2014 and appreciates the opportunity to submit commentaries on this revised Consultation for the renewal of 3500Mhz Spectrum.
In reviewing the Document, ccROUTE reads that the general purpose of DGSO-003-14 is to obtain feedback regarding best practices in enabling both fixed and mobile services to operate in the 3500 MHz band: (a) differentiate between urban and rural areas by reclassifying Tier 4 Service Areas; (b) a new licensing process to be used for fixed wireless access (FWA) licences; (c) a fundamental reallocation of the 3500 MHz band to introduce mobile services; and (d) a transition policy that could take effect pending decisions made following this consultation.
In the following sections of this submission, ccROUTE has set out its position of the issues raised in the Consultation Document.
Sincerely,
Michael Fiorini VP & General Manager ccROUTE Inc.
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
Introduction
1. ccROUTE Inc. was founded in1999 with the goal of providing ISP and data services, to residents and businesses in the Kawartha Lakes Region. In 2002 ccROUTE Inc. was granted a FWA License on a FCFS basis in the 3500Mhz range. In 2004 ccROUTE was awarded three Tier 4 Service Areas through the 3500Mhz FWA Auction.
2. ccROUTE is not unlike many other small, independent rural ISPs from across Canada. Rural FWA licensees are aggressive companies who work hard at servicing their customers. We invest millions of dollars annually to ensure rural Canadians have the best Internet experiences possible.
3. To maintain and grow our business we require policy consideration which is equally aggressive and agile in supporting the needs of independent, rural Licensees. Such a policy would envisage the following;
a. A refined policy position on spectrum supply and consumer demand. Currently many licensees like ccROUTE require more spectrum to keep up with consumer demand for bandwidth.
b. A refined policy position on unused spectrum where spectrum is repatriated if a Licensee does not launch and meet conditions of license within 6 months.
c. A preferential licensing process for Incumbents seeking additional spectrum. First right of refusal should be afforded to Incumbents who can prove their need for additional spectrum.
d. A preferential policy position on FCFS Licensing for Incumbents seeking to grow their operations to new areas.
e. A refined policy on the Competitive Licensing Process in rural areas to use this type of Licensing as a last resort to First Rights of Refusal and FCFS for small, independent Incumbents.
4. To support the above preferred treatment I would like to point out that the CRTC recognizes smaller, independent cable operators and provides preferential treatment through “Small System Exemption Orders”. ccROUTE sees no reason why Industry Canada could not adopt a similar position regarding the treatment of small, independents; more specifically small, independents who are existing Licensees.
5. ccROUTE is thankful to Industry Canada for creating the initial opportunity to compete in the Licensee’s FWA marketplace. We look forward to having our opinions and feedback considered in moulding a fair and equitable renewal process.
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
Commentary:
Industry Canada proposal to re-classify Tier 4 Service Areas:
6. At first look, we do not agree with an urban vs rural distinction of Tier 4 Service Areas. ccROUTE over the past 10 years has spent millions of dollars towards infrastructure and ongoing operations in providing services to rural customers. Our whole approach to investing in 3500 Mhz FWA Spectrum was that it was a perfect fit for our rural area. Additionally, there were several viable equipment manufacturers to choose from.
7. The proposal as outlined in the Consultation Paper is in contradiction of Industry Canada’s Digital Canada 150 Policy. In this policy it is mandated that all citizens (including those in low density areas) have access to broadband connectivity of no less than 5 Mbps.
8. ccROUTE is extremely concerned that the resultant renewal process, if followed as written, would have services taken away from our rural customers for no other reason than an administrative label of lines on a map. An assessment of Tier 4 Service Areas and alternative options is required for this Consultation to remain fair and equitable for all players involved.
9. Most Tier 4 Service areas in rural Canada show an aggregate population which does not necessarily mean they are rural or urban. For instance, ccROUTE currently holds a license for the Tier 4 Service Area 4-074 (Peterborough) which shows a population of 151,081 however only the City of Peterborough can truly be classified as urban while the rest of this Service Area is comprised of hamlets, crossroads and cottage area clusters which clearly are not urban.
10. It would be a mistake to not identify Tier 4 Service Areas such as 4-074 Peterborough as predominantly rural with an urban component. This could be done on a grid cell classification and licensing allocation basis.
11. It makes sense to offer Licenses in Rural designated Service Areas on a grid cell basis where a Tier 4 boundary covers a geographic typology in which hamlets, villages and small residential clusters surround an urban population (medium and large as defined by Industry Canada).
12. In this instance this would allow for the reallocation of spectrum for mobile services within grid cells which overlay an urban population while allowing the outlying grid cells to maintain their FWA status.
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
Rural Designated Service Area Licensing on a First-Come, First-Served Basis
Incumbents:
13. Incumbents who have launched FWA services and have met their Conditions of License must be provided preferred access to additional spectrum. Licensees like ccROUTE are the FIRST to make use of 3500 Mhz spectrum and require special considerations.
14. As a first to deploy provider, ccROUTE has spent the past 10 years building infrastructure and delivering reliable services to residents and businesses in what is recognized as a rural, high cost serving area. Despite not receiving any government subsidies, it is first to deploy providers like ccROUTE (launched in early 2003) who have helped Industry Canada meet its rural broadband program mandates.
15. FCFS Licensing should be offered initially to those who were first to deploy and have met their conditions of license. After these Licensees are taken care of then we agree to further FCFS Licensing in rural areas.
16. ccROUTE is insistent on its position here for no other reason than our obvious need for additional Spectrum. It is no secret that consumer demand for bandwidth intense content is taking our networks to the point of exhaustion with no current process in place from Industry Canada to allow for expansion.
17. Contrary to the Consultation Paper, demand for service is exceeding supply. More spectrum is what ccROUTE requires and in order to ensure that the investments we have made to date are not threatened by a competitive come-one, come-all process, allocation for additional spectrum should be done on a first right of refusal basis for incumbents who have met their conditions of license.
New Entrants:
18. FCFS Licenses should be issued to new entrants except where an Incumbent has made a similar application. In this case first right of refusal should be awarded to the Incumbent.
Rural Service Area Licensing on an Annual, Grid-Cell, and Spectrum Need Basis:
Annual Licencing Basis:
19. In order for any business to invest properly, a reasonably defined term is required. All issued Licenses must allow for the Licensee to go through the cycle of investment and benefit. Offering Licenses on an annual basis, especially without any renewal guarantees, provides no incentive for Licensees to make significant, ongoing investments in areas that have already been identified as rural, high cost serving areas.
20. Additionally, annual Licensing is contrary to the Spectrum Policy Framework for Canada (SPFC) in looking at spectrum allocation as an ecosystem in which all participants should benefit. Although a 5-year term in an urban area is reasonable in medium and larger urban centers, a longer 10 year term is needed for less densely populated rural area deployments to enable sustainability.
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
Grid Cell Basis:
21. It is possible that without careful consideration in moving to a grid cell approach in rural areas that propagation of FWA systems will overdrive neighbouring grid cells. ccROUTE recommends that the grid cell approach within Tier 4 service areas only be utilized where there is an obvious urban population within a Tier 4 boundary.
22. It makes sense to offer Licenses in Rural designated Service Areas on a grid cell basis where a Tier 4 boundary covers a geographic typology in which hamlets, villages and small residential clusters surround an urban population (medium and large as defined by Industry Canada).
23. This would allow for the reallocation of spectrum for mobile services within grid cells that overlay an urban population while allowing the outlying grid cells to maintain their FWA status.
24. Once distinctions have been made with respect to urban vs rural grid cells, existing Licensees should be provided a first right of refusal to transition their systems to mobile services. This would eliminate issues of interference as they would be managed on a one- stop basis by the existing Licensee.
Spectrum Needs Basis:
25. ccROUTE expects that where Licensees fail to meet conditions of license, the associated spectrum will be reclaimed by Industry Canada and made available for immediate use. This should be done immediately on existing conditions of license and after 6 months on newly issued licenses where the Licensee fails to comply with deployment terms.
26. It is imperative that preferred access to this reclaimed spectrum be provided to Incumbents who have already launched FWA services and have met their Conditions of License. This will provide for long term sustainability for all existing FWA systems and incentive to invest in newer, more sexy technology.
27. ccROUTE believes that there is a misconception within the Consultation Paper with respect to demand and supply of spectrum. With the high bandwidth requirements of companies like Netflix and other Video Streaming OTT players, the need for spectrum has never been higher. ccROUTE has been in need of additional spectrum for almost 2 years yet has been unable to obtain any due to the lengthy consultation process surrounding 3500 Mhz license renewal. It is our hope that Industry Canada will provide a preferential licensing process for Incumbents like ccROUTE.
28. ccROUTE understands that Industry Canada’s current position is that where demand is high for spectrum, a competitive licensing process is required however, given the true state of rural FWA systems across Canada, a come-one, come-all competitive licensing approach would likely result in the distribution of the same amount of spectrum across a higher number of providers.
29. That is to say, through the competitive licensing process, it would very likely result in denying any relief to the existing shortage of supply (for spectrum/bandwidth) which
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
Incumbents are realizing today. By offering reclaimed spectrum from those who do not meet the current conditions of license on a first right of refusal basis to Incumbents, the gap between current supply and demand would be satisfied.
Notification for Spectrum Relocation for Existing Point-to-Point, Fixed Stations:
Amateur Stations and Existing Radiolocation, FSS Earth Stations:
30. Although allowing operators of these classifications to have continued access to the 3475-3500 Mhz rage is important, it is necessary to note that side band interference does present significant issues with the lower frequency blocks currently held or to be issued.
31. To mitigate these issues, Licensees in the 3500-3650 Mhz range must have knowledge of these operations. Continued station updates on such systems must be undertaken in a similar fashion to the License Conditions imposed on 3500-3650 Licensees.
Fixed Point-to-Point Systems:
32. A 10 year notice is quite generous. These systems need to be identified and displaced/relocated.
FWA and FCFS Systems:
33. ccROUTE maintains a FCFS license in the same frequency blocks as its FWA Auctioned Tier 4-075 (Lindsay) Service Area. This FCFS license was issued on a Grid Cell selection basis. Some of these Grid Cells do overlap into neighbouring Tier 4 Service Areas.
34. While we appreciate comments in the Consultation Paper whereby “existing FCFS and auctioned FWA systems licensed and installed within rural tiers … may continue to operate”, the suggestion that these licenses would be subject to future band plan changes is a scary proposition.
35. To add, a 6 month transition requirement would very likely result in ccROUTE ceasing operations all-together. As a rural, small, independent Licensee, ccROUTE would be significantly affected by any notice imposing possible band plan changes. Such a change would impose costs on ccROUTE which would far exceed our start-up costs at day 1.
36. Any changes to the current band plan in favour of another would displace thousands of customers and place undue burdens on ccROUTE operations. ccROUTE would be required to undertake; revised tower sharing negotiations, regulatory reporting updates, millions of dollars’ worth of equipment wreck-out and millions of dollars’ worth of new equipment.
37. In the face of these challenges many rural, small, independents including ccROUTE would be faced with a real decision of ceasing operations. In considering this outcome, it is fair to say that the suggestion of being subject to band plan changes is contrary to the Spectrum Policy Framework for Canada whose objective is to maximize the economic and social benefits Canadians derive from the use of our systems.
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
38. We do not need a band plan change in rural areas, we need more spectrum. Furthermore, the addition of mobile spectrum to the 3500 Mhz rage should not come at the expense of existing Licensees and their customers.
Annex B. S4 – Transition Policy for all FWA Systems (FCFS and Auctioned) Within Rural Tiers:
39. Section 4 of Annex B states that Licenses may be subject to a transition to a new band plan and other relevant technical rules, if and when they are established, to facilitate the introduction of commercial mobile services in urban tiers.
40. Without repeating sections 23-28 above, ccROUTE believes that Section 4 should not be imposed on rural designated Service Areas unless there is an urban population within the boundaries of a Tier 4 Area. In such an instance, it would be prudent to require an incumbent to meet Section 4 criteria on a grid cell basis only and only as it relates to grid cells in otherwise rural Tier 4 Service Areas that overlay an urban population.
41. In the above noted scenario, this would be an acceptable condition to meet as it would not require a small, independent to consider the alternative of wrecking out its entire systems in that given Tier 4 area.
42. ccROUTE expects that if there is a band plan change, that it would require a new and separate Consultation process and not be determined without the input of Licensees. Additionally, significant consideration must still be afforded to small, independent rural operators like ccROUTE as we will be impacted the most by such a change.
Annex B – Conditions of License:
43. with the exception of our commentaries above (s. 29-32) ccROUTE’s position on the entire Annex B – Proposed Conditions of Licence is as follows:
a. Transition: This is a difficult proposition to accept. Moving to a different band could possibly mean Licensees like ccROUTE would have to wreck out millions of dollars of base station and customer premise equipment and by way of that, cutting off services to thousands of customers. We expect that there would be a separate consultation in the event that a transition due to band plan change is proposed.
b. License Term: A license term of one year otherwise described previously in the Consultation Paper as Annual Licencing, does not meet the overall SPFC mandate. For any business, in order to invest properly, a reasonably defined term is required. For this reason, this condition of license must allow for the Licensee to go through the cycle of investment and benefit. Offering Licenses on an annual basis provides no incentive for Licensees to make significant, ongoing investments in areas which have already been identified as rural, high cost serving areas.
c. Implementation of Spectrum Usage: A six month deployment requirement although acceptable, must be accompanied by a strict and swift enforcement policy. Without such enforcement continued ‘sitting’ will occur. ccROUTE would
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
like to see a policy revision for a process that would reclaim a license where this deployment requirement is not met.
Proposal to Reallocate 3500 Mhz Band to include Mobile Services and Changes to CTFA:
44. ccROUTE recognizes the need to be on par in coordinating a global Spectrum Plan. We also recognize Industry Canada’s position on differentiating urban and rural service areas.
45. However, the addition of mobile services spectrum to the current FWA 3500 Mhz band plan should not come at the expense of those who have met their conditions of license and the customers they serve.
46. When including mobile services in the 3500 Mhz Band we wish to reiterate that it makes sense to offer licenses in rural designated service areas on a grid cell basis where a Tier 4 boundary covers a geographic typology in which hamlets, villages and small residential clusters surround an urban population (medium and large as defined by Industry Canada).
47. In this instance this would allow for the reallocation of spectrum for mobile services within grid cells which overlay an urban population while allowing the outlying grid cells to maintain their FWA status.
48. Additionally, any reclaimed spectrum by way of mobile services distinction or return from licensees who have not met condition of license must be offered to Incumbents who are intent and have proven their determination in making use of valuable spectrum on a first right of refusal basis.
Geographical Differentiation, Mobile Services in Urban Tiers & FWA in Rural Tiers:
49. ccROUTE recognizes Industry Canada’s distinction between urban and rural areas as it pertains to spectrum usage needs. As mentioned in the Consultation Paper the proposed reallocation and spectrum utilization policy does balance the demand for mobile spectrum in urban areas with the demand for fixed spectrum for FWA in rural areas.
50. In addition to consideration of aforementioned sections 6-12, the Consultation Paper position on this subject is sound however it is only practical if all existing Tier 4 Service Areas are analysed to identify both urban and rural components.
51. For ccROUTE, all 4 of our licenses have a geographical boundary in which both urban and rural populations exist.
52. This distinction must be made on a grid cell basis. Our existing FCFS License (issued in 2002) which falls inside Tier 4-075 is a perfect example of how this should be done. The Town of Lindsay is not included in this Licence while the areas around Lindsay (which are clearly rural) are included.
53. Additionally, any reclaimed spectrum by way of mobile services distinction or return from licensees who have not met condition of license must be offered to Incumbents who are
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
intent and have proven their determination in making use of valuable spectrum on a first right of refusal basis.
Proposed Options for Displacement of FWA Licensees in Urban Tiers:
54. Given these two options, ccROUTE feels Option 2 is preferred with the below considerations being added.
55. ccROUTE views the Renewal Decision quite unfair with respect to the position whereby Licensees in urban areas would not be issued renewals and spectrum would be returned. There needs to be a process in which renewals are offered on a conditional basis for urban Incumbents and must offer a much more reasonable time frame.
56. This would allow urban Licensees to maintain their systems precluding loss of service to Canadians who are utilizing that service. Additionally, a reasonable timeline for transition would allow a Licensee a manageable timeline to migrate to the new band plan.
57. The current proposal for displacement, as written, provides no incentive for urban Licensees to make future investments in this proposed band plan and will leave them with no other option than to shut off all their customers.
Summary:
58. ccROUTE recognizes the need to be on par in coordinating a global Spectrum Plan. However, there is already ample spectrum available for mobile services. Most of this spectrum is unused and is being held without threat of being removed from the Licensee.
59. The addition of mobile services spectrum to the current FWA 3500 Mhz band plan should not come at the expense of those who have met their conditions of license and the customers they serve.
60. ccROUTE is interested in participating in any Working Group to discuss issues of band plan change, interfering system identification and necessary displacement/relocation of identified systems.
61. ccROUTE wishes to thank Industry Canada for its consideration of our submission.
****** END OF DOCUMENT ****
16 Cable Road Fenelon Falls Ontario K0M 1N0 Toll Free 1-866-887-6434 Tel (705) 887-6433 Fax (705) 887-2580 [email protected] www.cablecable.net
October 8, 2014
Peter Hill Director General Spectrum Management Operations Branch
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
CCI Wireless is pleased to respond to 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. We hope the outcome of this consultation will further signify the importance of rural Broadband in Rural Canada. This is especially important, as high-speed Internet has now become an integral part of Rural Canadian life, since Broadband connectivity has become the remedy for the isolation challenges faced by rural communities.
Introduction
Rural communities make significant contributions to Canada’s economic growth. Rural areas supply food, water and energy for rapidly growing urban centres and sustain industries that contribute to Canada’s economic prosperity. The natural-resource industries supported by rural communities generate 13 per cent of Canada’s gross domestic product (GDP)1.
Much of the economic growth that has taken place in recent years has resulted from the use of broadband networks to improve productivity, provide new products and services, support innovation in all sectors of the economy, and access new markets in Canada and abroad. Communities without robust broadband access are denied full participation in the global economy and access to distant markets. The importance of telecommunications infrastructure to Canada’s rural communities cannot be overstated.
We appreciate Industry Canada’s recognition of the importance of rural Broadband and its funding to improve broadband coverage and capacity for rural communities. The federal “Broadband Canada: Connecting Rural Canadians” program invested $225 million in improving rural broadband networks from 2010-2012. The new “Connecting Canadians” Initiative by Industry Canada is allocating another $305M to rural broadband in 204-2019 to enhance the network capacity to provide 5 Mbps service to rural communities.
With the help of all three levels of Government (Federal, Provincial and Municipal) and private investment significant progress has been made for rural Broadband in Canada. This industry segment has been transformed from small localized independent ISPs into carrier-grade telecommunication companies with significant investment in infrastructure and technology. Spectrum is a fundamental building block of this progress and with the Industry Canada policies for rural Broadband, rural Canadians are not an afterthought anymore, when it comes to robust Internet. Any disruption to the rural Internet market will be very costly for rural Canada.
1 http://www.fcm.ca/Documents/corporate-resources/policy-statements/Rural_Communities_Policy_Statement_EN.pdf
Comments on DGSO-003-14 1 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
Executive Summary
• CCI Wireless does not support the proposal for urban/rural geographic distinctions between fixed / mobile services within Canada. Our analysis, based on Statistics Canada data, shows that 50% of Rural Canada will be deprived of robust high-speed Internet with the proposed gegrahpcal separation. We also believe that it would be technically challenging to control co- frequency fixed/mobile interference without significant separation distances. CCI Wireless beleives the same band plan needs to be used for all Service Areas across the Country, with the provision of both fixed and mobile services.
• CCI Wireless does not support grid-cell licensing for FWA 3500 MHz band. CCI Wireless believes that Tier 4 licensing is appropriate for provision of FWA in 3500 MHz band. Grid-cell licensing would create significant inter-system interference resulting in significant separation distances between adjacent cells and substantial spectral inefficiency.
• CCI Wireless would urge Industry Canada to ensure the spectrum that is currently in-use to provide high-speed Internet Service to rural communities is not taken back and services are not disrupted, as the result of 3500 MHz band spectrum consulting and reallocation. However, we are in full support of Industry Canada clawing back the unused spectrum.
Comments on DGSO-003-14 2 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
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¶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omments for Question 1 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. CCI7. Wireless FWA does in Rural not support Areas the proposal for urban/rural geographic distinctions between fixed / mobile services within Canada. CCI Wireless is proposing that Industry Canada adopt a national Band 7.1 Proposed Licensing Process for FWA in Rural Tiers Plan with provision of both Fixed and Mobile services for all Tier 4 SAs. $XFWLRQHG):$OLFHQFHVLQWKH0+]EDQGKDGD\HDUWHUPDQGLQFOXGHGFRQGLWLRQVRI OLFHQFHVXFKDVGHSOR\PHQW7KHVHOLFHQFHVEHJDQH[SLULQJLQ0DUFKDQGFRQWLQXHWRH[SLUHXQWLO Further Comments'HFHPEHU $VVWDW HGLQWKH5HQHZDO'HFLVLRQOLFHQVHHVWKDWDUHLQFRPSOLDQFHZLWKDOOFRQGLWLRQV RIOLFHQFH LQFOXGLQJGHSOR\PHQW DUHHOLJLEOHWREHLVVXHGDQHZRQH\HDUOLFHQFH/LFHQFHVZKLFKDUH TheQRWHOLJLEOHIRUUHQHZDOZLOOEHUHWXUQHGWRWKH'HSDUWPHQWDQGZRXOGE Consultation paper divides the Tier 4 Service Areas (SAs) intoHPDGHDYDLODEOHWKURXJKDQHZ Urban and Rural Service Areas. In OLFHQVLQJSURFHVV reality however, it is practically impossible to geographically separate Urban Canada from Rural Canada. Rural Canadian population is distributed across both “proposed Urban Tier 4” SAs as well as “proposed Rural Tier 4” SAs. Our analysis, based in Statistics Canada data, shows that almost 50% of 6HHSDUDJUDSKV RIWKHDecisions Concerning the Renewal of 2300 MHz and 3500 MHz Licences rural Canadians KWWS ZZZLFJFFDHLFVLWHVPW are located in JVWQVIHQJVIKWPOthe “proposed Urban Tiers” 4 SAs. 6HH6WDWLVWLFV&DQDGD&HQVXV'LFWLRQDU\GHILQLWLRQV KWWS ZZZVWDWFDQJFFDFHQVXV In MayUHFHQVHPHQWUHIGLFWJHR D 2011 the CRTC defined broadbandHQJFIP goals for Canada as being a downlink speed of at least 5 Mbps, and an uplink speed of 1 Mbps to be achieved by 2015. No doubt these targets will be further increased by the year 2020 as Canadians continue to embrace such innovative services as NetFlix, and other Internet based services. The wire-line solutions such as Fiber, cable and Asymmetric Digital Subscriber Line (ADSL) technologies are seldom available to rural communities. Rural Canadians, generally, have access to Internet services through Dial-up, Satellite and Fixed Wireless Access (FWA) solutions. FWA is becoming the main source of high-speed Internet for rural Canada.
In relatively dense rural communities, available throughput/capacity is the main challenge in providing robust Broadband to those communities. In such situations where capacity is the main challenge, FWA is the only robust solution to ensure that sufficient throughput and capacity is available to the end users. This is achieved by adding more base stations (similar to cell-splitting in cellular network) or using more spectrum, as needed. Having implemented arguably the most dense FWA network on 3.5GHz in Canada today, CCI Wireless currently faces this challenge in many of our rural deployments.
Since FWA can provide better capacity/throughput when it comes to Broadband solutions, we argue that the rural communities within “suggested Urban Tier 4” SAs have even more pressing needs for FWA solutions. This is due to the higher density of population (while still rural) in those communities,
Comments on DGSO-003-14 3 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
which results in higher demand for throughput/capacity in those communities. Taking away FWA spectrum from rural communities in “proposed Urban Tier 4” SAs will leave many rural communities without a viable Broadband solution.
Technical Comments Due to inherent Time Division Duplex (TDD) interference provided by the deployment of TDD Long Term Evolution (LTE) systems, the geographical separation as proposed in the IC’s Consultation Paper will make the co-existence of Mobile/Fixed services in Urban/Rural Tier Service Areas very inefficient. Based on Industry Canada’s proposal, the practical distance between the sites should be in the order of 80-120 Km for proper operation of the same channel, in order to mitigate the inter-system interference. This makes the deployment very challenging and the frequency reuse very inefficient.
CCI’s Recommendation CCI Wireless proposes not to separate Tier 4 SAs in categories such as "Urban" or "Rural". The proposal is to define a new Band Plan, which includes provision of Mobile and Fixed services irrespective of the SA, i.e. using the same Band Plan for all SAs. The high-level band plan is captured in the following Figure:
Other Fixed Mobile
3400 3500 3600 3700
The details of the band-plan, including the amount of spectrum allocated to each service, as well as the exact channels to be provisioned to each service need to be further identified. However, we believe that at least 100 MHz of 3500 MHz is required to serve rural Canada’s Broadband needs.
Such a nation-wide band plan has the following benefits: - Availability of both FWA as well as Mobile services in all Tier 4 SAs, therefore avoiding the challenge of geographical separation and inter-system interference - Allowing the rural residences access FWA (Broadband services) in all Tier 4 SAs, including rural residences in “suggested Urban Tier 4” SAs - Allowing more urban communities in the “suggested Rural Tier 4” SAs to enjoy Mobile services - Efficient spectrum usage from technical point of view, since the interference between mobile and fixed services in adjacent Tier 4 Service Areas does not exist
Comments on DGSO-003-14 4 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
Comments for Paragraph 29-30 and Question 2:
29. Based on deployment data submitted by licensees, as well as the amount of spectrum available in rural areas, the demand for spectrum on a localized basis in rural tiers is not expected to exceed supply. As much of the interest in FWA is in deploying fixed broadband Internet services in smaller communities, making spectrum available for licensing in small, localized user-defined areas on an FCFS basis is likely to meet FWA demands in the rural tiers.
30. Moreover, issuing spectrum licences on a more granular level, such as using grid-cells19 rather than for an entire Tier 4 service area, means that licences can be obtained for the desired operating area rather than having to seek a single licence for an entire Tier 4 area. It is anticipated that this approach would permit services to be delivered to a greater number of communities. This approach also allows for more efficient use of the spectrum and helps to manage the demand, depending on the amount of spectrum available following the renewal process, more than one licence can be issued in a given spectrum block in a given tier area.
CCI Wireless does not support the use of grid-cell licensing. CCI Wireless recommends that Tier 4 licensing to be used for FWA in 3500 MHz band.
Further Comments The inherent TDD interference of a TD-LTE system makes the Frequency Coordination of a grid-cell licensing practically impossible. The TD-LTE system requires all the Base Transmitter Stations (BTS) to be time synchronized and use the same parameters, such as sub-frame ratio and channel bandwidth, in order for uplink and downlink frames not to collide. The lack of timing synchronization and parameters coordination between BTSs forces the distance between adjacent BTSs (using the same channel) in the order of 80-100 Km. This essentially means that one BTS will be required for approximately every 31,400 Km2 of the same channel making the spectrum use of a grid-cell licensing system very inefficient.
FWA deployment is a capital-intensive venture and future investments into this space will be seriously jeopardized if the long term viability of the business plan is not examined and validated. Annual grid- cell licensing on a FCFS basis does not guarantee long term business plan viability and hence investment in rural FWA. No Mobile operator can raise capital for network deployment with grid-cell FCFS licensing. This will also be the case for FWA operators, if grid-cell FCFS licensing is adopted.
Comments on DGSO-003-14 5 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
Comments on other Questions
CCI Wireless has no comments.
CCI Wireless has no comments.
CCI Wireless does not recommend grid-cell licensing, as captured in Annex B. Grid-cell licensing introduces severe interference challenges and does not provide efficient use of spectrum. This defeats the original stated objective of grid-cell licensing to serve more rural communities.
CCI Wireless suggests Tier 4 licensing for FWA in all SAs. CCI Wireless also suggests the term of the license to be 10 years.
CCI Wireless has no comments.
CCI Wireless does not support the proposal for urban/rural geographic distinctions between fixed/mobile services within Canada. CCI Wireless is proposing that Industry Canada adopt a national Band Plan with provision of both Fixed and Mobile services for all Tier 4 SAs.
Comments on DGSO-003-14 6 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
Further Comments CCI Wireless believes that the separation of Canada into Urban and Rural Service Areas for licensing of 3500 MHz spectrum is nearly impossible (please see CCI Wireless’ answer to Question 1). There are many Rural Communities in “suggested Urban Tier 4” SAs and many Urban Communities in “suggested Rural Tier 4” SAs. CCI Wireless is proposing that Industry Canada adopt a national Band Plan with provision of both Fixed and Mobile services for all Tier 4 SAs. This will have the benefits of: - Providing high-speed Internet to all Rural Canadians, as opposed to only 50% of Rural Canadians - Providing Mobile services to all of the Urban communities, as opposed to only selected Urban communities - Providing the coexistence of FWA and Mobile services from the interference and technical point of view - Maintaining the efficiency of spectrum reuse high, from the technical point of view
Our analysis shows that classifying the Tier 4 SAs to Urban vs. Rural and dedicating the complete spectrum to Mobile vs. Fixed services is much less spectrally efficient, compared to splitting the spectrum between mobile and fixed services with a national Band Plan.
Paragraph 59 suggests that the FWA operators need to return the spectrum in-use to Industry Canada in “suggested Urban Tier 4” SAs. Our analysis, based on Statistics Canada data, shows that returning spectrum in “suggested Urban Tier 4” SAs will deny robust Broadband to 50% of Rural Canadians.
CCI Wireless strongly urges Industry Canada to ensure the continuation of high-speed Internet availability via licensed FWA for Rural Canada. As the business case for rural broadband is not as strong as of the urban market, any disruption in any segment of this market will impact all of the rural Broadband market. Having said that, we are very much in favor of Industry Canada clawing back the unused spectrum.
To that end (as suggested in our answer to Question 1) CCI Wireless suggests FWA services to continue to be operational in specific portion of the 3400 MHz to 3700 MHz band permanently, however, can be relocated within this band. CCI Wireless suggests the relocation (not return of the spectrum to Industry Canada) of FWA services within 3400 MHz to 3700 MHz band adopt option 2 in Paragraph 62 of the Consultation Paper.
Comments on DGSO-003-14 7 CCI Wireless 7640 – 8th Street NE Calgary, AB T2E 8X4
Via e-mail: [email protected]
8 October 2014
Senior Director Spectrum Development and Operations Industry Canada 300 Slater St. (JETN 15th) Ottawa ON K1A 0H5
Dear Sir or Madam:
Re Canada Gazette, Part I, Vol. 148, No. 36 - 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
I. Introduction
1. Ciel Satellite Limited Partnership (“Ciel”) is pleased to offer the following comments in connection with Industry Canada’s Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) (the “Consultation”).
2. Ciel is a licensed Canadian satellite operator. Ciel is majority-owned by SES S.A. (“SES”), a global satellite operator with a fleet of more than 50 geostationary satellites which collectively reaches 99% of the world’s population. Ciel has operated the Ciel- 2 BSS satellite at the Canadian 129°W geostationary orbital position since 2008 and currently provides broadcasting-satellite services throughout the North American market. Ciel also holds approvals in principle from Industry Canada to develop several additional Canadian frequency assignments.
Ciel Satellite LP Suite 410, 116 Lisgar Street, Ottawa, Ontario, Canada K2P 2K1 tel. (613) 233-4400 www.cielsatellite.ca
DGSO-003-14 8 October 2014 Page 2
3. The matters raised in the Consultation are of great concern to both Ciel and SES due to the impact the decisions made in this Consultation may have on the future integrity of the Fixed-Satellite Service (FSS) in Canada, in particular the FSS in the band 3700-4200 MHz (Standard C-band space-to-earth). The comments herein specifically address Question 7 in the Consultation: the Department’s proposal to fundamentally reallocate the 3500 MHz band to include mobile services and make related changes to the Canadian Table of Frequency Allocations as described in Section 8 of the Consultation.
4. Ciel objects to the reallocation proposal. This reallocation should not be considered without first completing all of the necessary consultations and technical studies to ensure that the introduction of mobile services in the 3500 MHz band will not cause harmful interference to existing services operating in the Standard C-band. Before taking the steps described in the Consultation, Industry Canada must first satisfy itself that the impact of the proposal has been fully evaluated and understood, and that appropriate interference protection measures are possible and can be put in place to protect existing services in the Standard C-band. Simply put, the Department’s allocation proposal is premature.
II. Specific Comments
5. The Standard C-band was allocated to and has been in continuous use by the Canadian satellite industry since the first satellite networks were deployed more than 40 years ago. The Standard C-band today is not only a fundamental element of the Canadian broadcast distribution infrastructure, but also supports the expansion of much-needed broadband services to rural and remote communities, as well as critical national security and safety-of-life data services. Canadian satellite operators have built robust Standard C-band networks to support these important services in urban, rural and less densely-populated areas of the country.
6. Industry Canada itself has consistently recognized the importance of Standard C- band for Canadians. In the March 2013 Industry Canada Commercial Mobile DGSO-003-14 8 October 2014 Page 3
Spectrum Outlook (the “Outlook”), which is cited in the Consultation, the Department describes the extent of C-band usage in Canada: 1
... The 3700-3800 MHz band is heavily used by the FSS for the delivery of broadband services as well as feeder links for television broadcasts. It forms part of the larger pairing of 3700-4200 MHz (used for downlink) and 5925-6425 MHz (used for uplink), commonly referred to as the C-Band. The licences held by the top five users of the C- Band account for 65.9 percent of all frequency assignments (approximately 2,350) in this band. Additionally, there are three Canadian and 53 foreign satellites licensed to operate in the C-Band. Industry Canada currently requires that operators provide public benefit satellite capacity in the C-Band as part of their conditions of licence. A large number of remote northern communities depend on this satellite capacity in order to meet their communications needs ...
... FSS receiver earth stations operate above 3700 MHz for weather monitoring, national defence and security, TV distribution to TV broadcast stations and cable systems and services in the North.
The foregoing demonstrates that the services provided by satellite operators using Standard C-band spectrum are, without question, fundamental to the existing and future communications infrastructure of Canada.
7. In the same document, Industry Canada also identified the serious issues that could be encountered in introducing mobile services in a band adjacent to the Standard C- band:2
[FSS receiver earth stations operating above 3700 MHz] are susceptible to interference from transmitters operating below 3700 MHz. Therefore, a minimum separation distance is required between any WBS base station or FWA station and the FSS receiver earth stations. Furthermore, in order to protect terrestrial services (including the fixed and mobile services), FSS satellite transmitters operating in the 3700-4200 MHz band are subject to some power flux density limits, specified in Article 21 of the International Radio Regulations. Sharing between mobile base stations or subscriber terminals and FSS earth stations would be very difficult [emphases added]
This view is consistent with technical studies which have demonstrated that out-of band interference into the Standard C-band from mobile service transmitters in the
1 http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09446.html at 4.2.6 2 ibid DGSO-003-14 8 October 2014 Page 4
3500 MHz band is a serious problem.3 However, Industry Canada has proposed to move forward with the fundamental reallocation described in the Consultation in spite of this clear recognition of the work that would need to be done to ensure that appropriate interference protection measures are available and could be effective in protecting existing services. Ciel believes that proceeding in this manner would be ill-advised at this time.
8. The Consultation also references the 2007 Spectrum Policy Framework for Canada (SPFC) which describes the underlying principles that should guide the Minister of Industry in exercising his authority. One of the basic principles noted in the SPFC is that spectrum policy and management should support the efficient functioning of markets by:4
ensuring that appropriate interference protection measures are in place; and
reallocating spectrum where appropriate, while taking into account the impact on existing services [emphasis added]
Neither of these basic principles would be met if the proposal described in the Consultation is implemented without first conducting the necessary consultations – the Minister will not have ensured that appropriate interference protection measures are in place, because none have been identified, nor, therefore, will he have fully taken into account the impact of the reallocation on existing services.
9. Industry Canada notes at paragraph 53 of the Consultation that:
If the Department implements the proposed fundamental reallocation, it will initiate a further consultation on a 3500 MHz band technical and licensing framework to authorize commercial mobile services in urban tiers.
3 For example, 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. 4 DGTP-001-07 at p. 9 DGSO-003-14 8 October 2014 Page 5
With respect, the Department has got the process completely backwards. The consultation referred to needs to take place before any allocation can be made. To do otherwise is to pre-suppose that such an allocation is even possible without seriously interfering with existing critical services. As the Department itself has pointed out:
(a) the Standard C-band is susceptible to interference from transmitters operating below 3700 MHz;
(b) The Minister must take into account the impact of a reallocation on existing services and must ensure that appropriate interference protection measures are in place;
It makes no sense to undertake a fundamental reallocation of spectrum before understanding the technical framework that may be required to support such a step, or if such a step is even possible, given the spectrum management principles espoused by the Department.
10. Canadian telecommunications services rely on C-band earth stations in all regions of the country. The operation of mobile services in the 3500 MHz band has the real potential to cause interference to those earth stations. The Department must carefully consider the technical means by which FSS C-band earth stations can be protected, before changing the allocations in the Canadian Table of Frequency Allocations, not afterwards. To do otherwise would be completely inconsistent with stated Department policy.
All of which is respectfully submitted.
Sincerely,
Scott Gibson Vice President & General Counsel Ciel Satellite Limited Partnership
October 8, 2014
[email protected] Senior Director Spectrum Development and Operations Industry Canada 300 Slater Street (JETN, 15th) Ottawa, Ontario K1A 0H5
Dear Sir/Madam:
Re: Canada Gazette, Part I, 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 – Eastlink’s comments
Please find attached the comments of Bragg Communications Inc., carrying on business as Eastlink (“Eastlink”), in response to Canada 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 (Part I, September 6, 2014).
We appreciate the opportunity to provide our views to the Department.
Sincerely,
Denise Heckbert Manager, Wireless Regulatory, Eastlink
Tel: (902) 406-4066 Email: [email protected] 6080 Young Street Halifax NS B3K 5M3
Box 8660, Station A, Halifax, Nova Scotia B3K 5M3 T (902) 431-9979 F (902) 446-9979 E [email protected]
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INDUSTRY CANADA CONSULTATION ON POLICY CHANGES IN THE 3500 MHz BAND (3475-3650 MHz) AND A NEW LICENSING PROCESS IN RURAL AREAS CANADA GAZETTE, PART I, SEPTEMBER 6, 2014 (DGSO-003-14)
COMMENTS OF BRAGG COMMUNICATIONS INC., OPERATING AS EASTLINK
8 OCTOBER 2014
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1. Bragg Communications Inc., carrying on business as Eastlink (“Eastlink”), appreciates the opportunity to provide comments on the issues raised under 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”).
2. Under the Consultation, Industry Canada (the “Department”) seeks comments on its proposed revisions to the Tier 4 licensing areas, and regarding its proposed allocation of 3500 MHz spectrum in Tier 4 areas. Eastlink herein provides our comments.
Incumbents dominate high capacity spectrum
3. Eastlink addresses the Department’s specific questions below, but we submit at the outset that a population of 30,000 is too large a threshold to distinguish a Tier 4 area as “rural.” While such a threshold may make sense in more populated parts of Canada, such as southern Ontario and Quebec, Eastlink notes that in our existing serving area in Nova Scotia and Prince Edward Island there are just three towns with more than 30,000 people; Halifax, Charlottetown, and Sydney. Under the Department’s proposal, Eastlink would be prevented from purchasing much needed high-capacity spectrum throughout much of our licensed areas in Atlantic Canada and Ontario. This could deteriorate wireless competition in these areas and limit affected rural consumers’ access to advanced wireless data services.
4. For example, our fourth largest serving area is Truro, Nova Scotia, with a population of roughly 14,000 people. We are providing advanced mobile wireless data services in Truro and will require additional mobile wireless spectrum to sustain and improve our services over the long-term. Wireless incumbents hold the vast majority of high capacity spectrum in Canada, including the 3500 MHz spectrum subject to this consultation, the AWS spectrum auctioned in 2008, and the 2500 MHz spectrum. At the same time, wireless data is becoming increasingly important to Canadian consumers, who are among the heaviest data users in the world. It is critical that Eastlink has access to the high-capacity spectrum needed to support the wireless data services our customers demand if we are to compete sustainably in the retail wireless market.
Box 8660, Station A, Halifax, Nova Scotia B3K 5M3 T (902) 431-9979 F (902) 446-9979 E [email protected]
5. We support the Department’s decision under DGSO-004-13 Decisions Concerning the Renewal of 2300 MHz and 3500 MHz Licences (the “Renewal Decision”) to recover spectrum where the licence holder had not met the conditions of licence so that it may be reallocated. The Renewal Decision was an important step toward ensuring that Canadians have access to this 3500 MHz spectrum and the advanced mobile data services the spectrum will soon support.
6. Eastlink further supports the Department’s proposal to reallocate this 3500 MHz spectrum band to mobile wireless services but we submit this reallocation should not be limited to “urban” areas, as defined in the Consultation. Eastlink notes that Tier 4 areas that are small compared to those of southern Ontario, but that nevertheless require access to advanced wireless data services, should not be disadvantaged with respect to the quality of their mobile wireless services.
7. We further note that many of these less-populated Tier 4 areas are unlikely to see Fixed Wireless Access services (“FWA Services”) develop. For example, Summerside, Bridgewater/Kentville, Truro and Antigonish/New Glasgow, among others, were all proposed to be designated “rural” under the Consultation. Each of these areas has an incumbent broadband service provider and at least one competitive broadband service provider (i.e., Bell Aliant and Eastlink, respectively), such that it is extremely unlikely that a FWA service provider would establish a network in these areas. As a result, if licences in these areas are designated “rural” and set aside for FWA services, the spectrum would most likely go unused.
8. As a result, we submit that the Department should reallocate the entire spectrum band in all Tier 4 areas to mobile wireless services as a first priority: the Department could allow FWA services to be offered in licence areas where, following an auction of all available licences, no mobile wireless service provider had acquired 3500 MHz spectrum licences in that particular licence area.
9. Eastlink submits that sustainable mobile wireless competitive alternatives for Canadians should be the first priority, and that FWA should only be made available where mobile wireless operators choose not to acquire further spectrum. This would ensure that, where mobile wireless service providers need the spectrum to meet Canadians’ growing demand for mobile wireless data services, the very limited spectrum is used efficiently, but would
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also ensure that, in very rural areas, FWA service providers could use the spectrum to provide broadband service.
Department questions
10. Eastlink has commented below on certain of the Department’s proposals; a failure to comment on others should not be construed as agreement where such agreement would be contrary to our business interests or our positions outlined herein.
Question #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 Statistic Canada’s 2011 definition for population centres, as outlined in Annex A.
11. Eastlink submits that the Departments’ population threshold of 30,000 people has inappropriately grouped some regionally urban areas in with truly rural areas where FWA services may make sense. For example, New Glasgow, Truro, Summerside, and Bridgewater are key areas among Eastlink’s wireless serving area. We have business and consumer wireless subscribers in these regions and we will require additional high-capacity spectrum, like the 3500 MHz band, in order to meet their increasing wireless data needs.
12. While these regions are small compared to other urban centres in southern Ontario and Quebec, the populations in these regions are large enough that there are already two fibre- based broadband service providers competing, making it unlikely that FWA services would be needed or viable in the area.
13. As a result, Eastlink submits that there should be a single classification of Tier 4 licence area.
14. In the event that the Department adopts its proposed distinction between urban and rural Tier 4 areas, the distinction should be relied on only solely as described herein, to prioritize allocation for mobile wireless but to allow it to become available for FWA if not auctioned off, thus avoiding inadvertently leaving valuable spectrum unused that could be more appropriately allocated to mobile wireless use.
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Question #2 and #3. 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. 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.
15. In order to preserve the mobile wireless competition supported by recent spectrum policy frameworks, it is critical that new entrants have access to additional spectrum throughout our serving area, including areas with fewer than 30,000 people. Eastlink submits that all 3500 MHz spectrum should be allocated to mobile wireless use and should be auctioned according to a mobile wireless licensing and policy framework to be determined at a future date. Eastlink submits this is reasonable as primarily-rural wireless service providers, like Eastlink, with limited high-capacity spectrum compared to the incumbents, require additional spectrum to provide competitive wireless data speeds sustainably. Any licences auctioned pursuant to the future mobile wireless licensing framework would be subject to the licence terms and conditions determined as part of that framework.
16. This will ensure that the spectrum is put to its best use as mobile wireless data speeds are increasingly important for Canadians, and most Canadians already have access to at least two competing broadband service providers such that FWA services are unnecessary.
17. In Tier 4 areas where no mobile wireless service provider bidder purchases a spectrum licence for this 3500 MHz band, the Department could make that licence available to FWA service providers. At that time, Eastlink would support a first-come first-served approach to licensing of FWA spectrum within that particular Tier 4 area, and would support annual spectrum licences on a per-grid cell basis.
Questions #7 and #8. 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. 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.
18. Eastlink supports the Department’s proposal to reallocate the 3500 MHz spectrum band to mobile wireless services. We reiterate that this reallocation should also apply to rural tiers.
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Eastlink will require additional high-capacity spectrum in Truro, Nova Scotia, for example, to continue providing competitive mobile wireless data services. It is very unlikely that a FWA service provider would use this spectrum to serve Truro considering the existing broadband competition provided by Eastlink’s High Speed Internet service and Bell Aliant’s FibreOp. As a result, limiting “rural” Tier 4 spectrum licences to FWA services would mean that the 3500 MHz spectrum in Truro would go unused. Eastlink submits that the same is true of many Tier 4 areas.
19. As noted above, Eastlink submits that the Department should allow mobile wireless services in all Tier 4 areas of the 3500 MHz spectrum band and should make such spectrum available via a mobile wireless licensing and policy framework to be established at a future date, as proposed in the Consultation. Only in the event that no mobile wireless service provider purchases licences in a particular Tier 4 area should the Department designate that Tier 4 area for FWA services, such FWA licences to be awarded pursuant to the licensing framework proposed in the Consultation.
Conclusion
20. The vast majority of high capacity wireless spectrum suitable and/or soon to be suitable for mobile wireless services is concentrated in the hands of the three incumbent wireless service providers. Eastlink submits that this 3500 MHz spectrum should be made available first to mobile wireless service providers, particularly to new entrant service providers who are committed to deploying this spectrum so that we may continue to provide competitive mobile wireless data services over the long-term. Such a decision would be consistent with recent decisions and actions by the Department and would help ensure that all Canadians – including those in rural areas – benefit from the competition first supported in the 2008 AWS auction.
**END OF DOCUMENT**
7
Consultation on
Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas
COMMENTS OF GTI
The Global TD-LTE Initiative (GTI) is pleased to be able to respond to Industry Canada’s consultation “Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas”. This response has been prepared by the
Spectrum Working Group of GTI1.
GTI (Global TD-LTE Initiative) is an open platform in 2011, advocating cooperation among global operators and vendors to energize the creation of a world-class and a growth-focused business environment. GTI aims to build a robust ecosystem of converged TD-LTE/LTE FDD, and speed up its commercialization. With 3 years’ development, GTI has become one of the most important cooperation platforms with 112 operator members and 90 vendors.
Accordingly we welcome the initiative by the Industry Canada to review planning arrangements in the 3.5 GHz band, which would maximize future flexibility for a review of planning issues. GTI hereby submits its comments in response to the Industry Canada’s consultation on the transitioning of 3.5GHz licensing and the future opportunities presented by this important global mobile broadband frequency band.
General view on the 3.5GHz bands
1 Individual members of GTI may respond separately and their views may be different to those in this document. We think it is very wise for IC to consider the 3.5GHz band for mobile and fixed wireless access system deploying in rural and urban area. As the latest advanced mobile network technology, Long-Term Evolution (LTE) will contribute to maximize the social and economic value of spectrum, especially in the case of wide area deployment.
1. Progress of 3.5GHz band
3.5GHz is being increasingly recognized as the most probable global harmonized TDD band and will play a key role in meeting the explosive mobile data demands. Regional band planning or re-farming considerations for this band have made significant progress in the world in recent years.
1.1 Progress in Region 1
In Europe, there has been a transition from a framework designed for BWA/rural access to a new framework designed for IMT-Advanced purposes. The initial BWA framework (reflected in EC decision 2008/411/EC) assumed paired spectrum allocations could be used either as TDD or FDD, together with a proper block-edge-mask. This was fine as rural deployment usually exhibit few inter-operator coexistence issues, and ensuring flexibility was more important in this context. However, for IMT-Advanced purposes, those assumptions were no longer true, i.e. sites are often shared among operators, and FDD/TDD or unsynchronized TDD/TDD coexistence issues were expected. Besides, the flexible arrangement did not provide enough guidance to the industry to know where to invest (which is illustrated by WiMAX failure to properly address the mobile market in this frequency band). Yet, most countries and operators recognized the 3.4-3.8 GHz bands as the main suitable contiguous block of spectrum to enable IMT-Advanced data rates, and it was desirable to get a new proper harmonized regulatory framework to help those deployments happen.
The new ECC decision (11)08 removes flexibility and mandates a homogeneous band plan within a country to avoid TDD/FDD coexistence issues. For the 3.6-3.8 GHz subband, TDD is the only duplexing mode allowed (corresponding to 3GPP band 43). One of the main reasons has been related to coexistence with satellites in this upper band (in FDD, voiding one duplex for coexistence would also mean losing the other corresponding duplex). For the 3.4-3.6 GHz subband, two band plans are defined (TDD i.e. 3GPP band 42, and FDD i.e. 3GPP band 22. See fig.1 and fig.2). There has been intense debates related to which band plan should be preferred — if any — as both duplexing schemes have pros and cons. The European Commission decided to mandate ECC to define a preferred band plan, which has been finally defined as TDD. The main reasons were to enable economies of scale with other parts of the world, and ease terminal implementation (while B22 was technically more challenging due to its very small duplex gap).
There has been some additional work • on new block edge masks, assuming HetNet deployments (macro/micro/pico/femtocells), in FDD, TDD-synchronized and TDD-unsynchronized modes. This is reflected in ECC report 203
• on synchronization for TDD networks, assessing technical and non-technical topics in a multi-operator context with HetNets and indoor cells (i.e. without GNSS). This work is reflected in the ECC report 206 [finished but formal approval pending at the time of this writing].
All this work is reflected in CEPT report 49 (November 2013), in ECC decision(11)06 (march 2014), and in the new EC decision 2014/276/EU (may 2014, updates previous EC decision 2008/411/EC).
3400 MHz 3600 MHz 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5
Figure 1 Preferred Frequency arrangement for the 3400-3600 MHZ band based on TDD
3400 MHz 3600 MHz
Uplink Duplex Gap Downlink 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5
3410 MHz 3490 MHz 3510 MHz 3590 MHz
Figure 2 Alternative Frequency arrangement for the 3400-3600MHz band based on FDD
1.2 Progress in Region 3
Regulators in Region 3 have also speed up the planning of this band and it is expected to finish the planning soon in some representative countries, e.g. in Japan and China
In China, co-existence study and field test have been carried out to evaluate the compatibility between TD-LTE and fixed satellite services. It is thought that current sharing study between TD-LTE and satellite is enough. It is feasible for TD-LTE to operate and coexist with satellite within band 42. Co-existence issue in very limited cases will be handled by the approach of geographic separation. It is anticipated that the planning for this band will be speed up in 2014.
In Japan, introduction of LTE-Advanced systems to 3400-3600MHz band was studied during 2012-2013. The technical requirements such as the coexistence with the incumbent systems (satellite, and microwave links) were concluded. And it is announced that Japan will launch LTE-A TDD in 3.5GHz commercial service around 2016.
In South Korea although some of the capacity in the 3.5-3.7GHz range is used for fixed satellite services, the government plans to release at least 160MHz of capacity at 3.5GHz for mobile broadband services by 2018 as part of its Mobile Gwanggaeto Plan. Both TDD (200MHz) and FDD (2x80MHz) options in 3400-3600MHz are considered to meet the capacity target.
1.3 Progress in North America
North America envisions 3.5 GHz as an “innovation band,” Three-Tier Spectrum Access is proposed by FCC that the band be structured according to a three-tiered shared access system enforced by a Spectrum Access System (SAS) and the use of geo-location based technology.
The first tier, Incumbent Access, would include authorized federal users. These incumbents would be afforded protection from all other users in the 3.5 GHz Band.
The second tier, Priority Access (PA), would include critical use facilities, such as hospitals, utilities, government facilities, and public safety as well as non-critical entities such as operators that would be afforded a quality-assured access the 3.5 GHz Band. TD-LTE would be a good candidate for this tier.
The third tier, General Authorized Access (GAA), would be authorized to use the 3.5 GHz Band opportunistically. GAA users would be required to accept interference from Incumbent and Priority Access tier users but have to avoid causing any harmful interference to Priority Access Licensees and Incumbent Access tier users.
2. TD-LTE at 3.5GHz Band
2.1 Standardization Progress at 3.5GHz
In terms of standard on 3.5GHz (3400-3600 MHz), 3GPP specifies two arrangements: unpaired TDD mode (Band 42) and paired FDD mode (Band 22). It has become clear in recent years that TD-LTE at 3.5GHz has a highest possibility to be the dominant IMT technology deployed around the world.
Figure 3 Two 3GPP specified arrangements on 3.5GHz
Besides, TD-LTE at 3600-3800 MHz is the sole technology allocation in the 3GPP: Band43. In the middle or short term, it is expected that C-Band (3800-4200 MHz) will be assigned for IMT use and the technology mode will also be likely to be TD-LTE.
Thus, TD-LTE at 3.5GHz is the widest 3GPP band, giving a total of 400MHz ultra wide bandwidth (even extend to 800MHz). This would enable operators to take the unique advantage of building super speed networks, which is highly desirable among global mobile operators when building a perfect heterogeneous MBB network.
2.2 Vibrant Ecosystem around TD-LTE at 3.5GHz
Availability of chipsets and devices
Chipsets that support TD-LTE at 3.5GHz are now available. Chipset vendors that are known to have 3.5GHz capability for their TD-LTE chipsets include Huawei/Hisilicon, Sequans and Altair Semiconductor. Other important chipset providers such as Qualcomm and Intel will have 3.5GHz TD-LTE chipsets ready in 2014/2015.
Availability of devices that can support TD-LTE remains growing. The earliest devices available to operators are indoor and outdoor CPE to support fixed wireless broadband applications. In late 2013, multimode MiFi (GSM/UMTS/TD-LTE) has come into market serving many significant markets. Furthermore, during MWC 2014, Huawei showcased the world’s first 3.5GHz TD-LTE smart phone, which was expected to Go-To-Market in 2015.
According to GSA statistics, there are 24 devices in the market in mid-July 2014. Details for some selected devices are presented in the following table.
Vendor Device type Device name Frequency bands supported
FIC Mobile tablet Elija TF9300 TDD 3500 b42, 43
DA-235 TD-LTE and TDD 2300 b40,TDD 2600 b38,TDD Greenpacket Router WiMAX CPE 2600 b41,TDD 3500 b42, 43
B2268A Cat 4 TDD 1900 b39,TDD 2300 b40,TDD Huawei Router device 2600 b38,TDD 3500 b42, 43
TDD 3500 b42, 43, LTE FDD E5776s-420 Cat 4 Huawei MiFi 2600MHz personal hotspot UMTS 850/900/2100MHz
Mitrastar Router Outdoor CPE band TDD 3500 b42, 43 Vendor Device type Device name Frequency bands supported
Corporation 42/43
WNTD-4243 TDD 2300 b40,TDD 2600 b38,TDD Netcomm Router Outdoor TD-LTE 2600 b41,TDD 3500 b42, 43 Router
Availability of network equipment
The status of the network equipment market is similar to the status of the device market: improving. A number of vendors of radio network equipment are making available eNodeB base station equipment to support TD-LTE at 3.5GHz, including Huawei, ZTE, NSN, Datang Mobile, Airspan, Accelleran, etc. Existing products are currently mostly macrocells and microcells, but pico/femtocells are expected in a very short timeframe as chipset vendors such as Qualcomm/Broadcom also have small cells reference-designs that are nearly ready to work on 3.5 GHz.
2.3 Operator commitments to invest in TD-LTE at 3.5GHz
Many global operators have signalled their clear desires to use in the 3.5GHz band.
Operator commitments to TD-LTE at 3.5GHz are growing steadily. At the end of June 2014, there were five live commercial TD-LTE networks at 3.5GHz: UK Broadband in UK, PLDT in Philippines, Menatelecom in Bahrain, ABC Communications in Canada, and Neo-Sky in Spain. In addition to these live commercial networks, a number of other operators have announced plans to launch services using TD-LTE in bands 42 and 43. These include players from all parts of the world.
Operator Country Details Xplornet Communications Canada Trials from WiMAX migration to TD-LTE Azqtel Azerbaijan Targeting service launch Q3 2014 VipNet Côte d'Ivoire Targeting commercial launch in 2H 2014 ITC Saudi Arabia In deployment, in deployment Combined WiMAX / LTE network in Dedicado Uruguay deployment Commercial launch is planned in 2014 b•lite Telecom Belgium beginning in the city of Aalst Operator Country Details Imagine Group Ireland Currently conducting trials of LTE Milmex Poland Plans to launch 3.5 GHz TD-LTE in 2014 Has a licence with 42 to 70 MHz of 3.5 GHz DBD Germany spectrum nationwide and plans to deploy TD-LTE. Plans to introduce TD-LTE system in band 42 Bolloré Telecom France (3.5 GHz), and launch mobile services using MM-MB devices
Except for the operators mentioned above, leading operators from Japan promise to make a great contribution to 3.5GHz TD-LTE. It is said that Japan government will allocate 3.5GHz band in this year. This will drive forward the ecosystem around 3.5GHz TD-LTE more quickly. The following table (cite SoftBankMobile’s presentation) illustrates the potential operators’ plan in Japan.
Note: eAccess（named Ymobile）is one company of SoftBankMobile.
2.4 TD-LTE at 3.5GHz: Now and for the Future
The aforementioned information means that the ecosystem around 3.5GHz TD-LTE is available and mature. As such, ever-increasing operators have a heightened interest in this large block of spectrum that has been available or may become available worldwide.
In contrast, the LTE FDD industry, has not yet announced any plans for the development of 3.5GHz networks or devices. Global harmonization of the 3.5GHz spectrum band is critical to supporting a single ecosystem, particularly for chipsets and devices. Based on current situation, TD-LTE at 3.5GHz is the preferred choice for Canada, and it gives a bright future to address the rapid growing data needs. One thing to note though: inter-operator synchronization is desirable to avoid interferences, and as mentioned in the ECC report 216, there are situations where inter-operator synchronization agreements may be difficult to reach as it reduces operator flexibility. Yet it is desirable to have certainty that inter-operator synchronization is implemented. China has avoided the issue by making inter-operator mandatory (instead of optional, pending inter-operator agreements) in 2.6GHz. This option may be worth to explore to ensure TDD success in an urban environment with multiple operators.
Feedback for the consultation questions
With regards to the consultation questions of the technical issues for the 3.5GHz award, we would like to explain the views and comments on several aspects as below.
1. Classification criterion Question1. 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.
GTI would not recommend the proposal of geographic distinction between rural and urban as this will be considerably challenging to control interference between operators without freq and configuration synchronization.
GTI would also highly recommend a proper Bandplan be developed as a result of this consultation. One extending from 3400-3600, in 5 or 10MHz channels and as TDD would align Canada with other band plans worldwide.
Considering this classification’s usage, traffic and spectrum demand is better than population. The area with smaller population may have high traffic leading to larger spectrum demand and vice versa.
2. Comments on FWA in rural Question2. 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.
GTI would suggest not using a FCFS process for interference reasons.
Question3. 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). GTI believes Gridcell licensing would increase the likelihood of interference issues.
Question4. 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.
GTI has no comment
Question5. 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.
GTI has no comment
Question6. Industry Canada invites comments on the conditions of licence in Annex B.
Considering there is a continued demand for FWA in rural areas, it seems reasonable to keep FWA licenses legalization within a period of time to allow these fixed operators to implement and transition to TDD-LTE. With a new TDD based bandplan, TDD unpaired blocks may be more suitable for current and future spectrum licenses.
TD-LTE could coexist with existing licensing arrangements in Canada by properly choosing DL/UL configuration which cannot be met by the 1:1 DL/UL spectrum allocation of FDD. Since not requiring FDD’s paired spectrum with fixed duplex distance, TDD is easier to create “holes” or “exception areas” in the band to protect incumbent satellite users. In conclusion, TDD provides efficient spectrum usage and flexibly allows networks to coexist with FSS and Amateur stations as necessary.
For those reasons, TDD may allow more flexible accommodation of current use of the frequency bands by other services.
3. Comments on mobile services in urban Question7. 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.
GTI believes IMT-A is forcing a convergence of fixed and mobile through the deployment of TDD LTE networks worldwide, including Canada. The same core and RAN technology is being used for both fixed and mobile networks. GTI again recommends IC issue a proper bandplan to harmonize internationally. It is not recommended that Canada follow the US proposed plan for the reasons described earlier.
Question8. 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).
GTI believes a proper bandplan be established and allocated for TDD services. The distinction of urban/rural or mobile./fixed is diminishing worldwide. Incumbent spectrum holders utilizing their spectrum and planning or deploying TD-LTE networks should be transitioned into this bandplan.
Question9. Industry Canada invites comments on its two proposed options for displacement.
GTI believes there is no need for displacement in urban areas if current FWA operators are already deploying TDD-LTE based networks.
GTI agree with IC that there is increasingly demanded extended coverage, faster data transmission rates and more advanced data-intensive mobile applications. With the adoption of more sophisticated mobile devices and data traffic on mobile networks that is expected to continue to grow into the foreseeable future, additional spectrum is required to meet the demand for mobile services. Considering the global TD-LTE ecosystem, 3.5GHz band is a global harmonized TDD frequency band.
TD-LTE could coexist with existing licensing arrangements in Canada by properly choosing DL/UL configuration which cannot be met by the 1:1 DL/UL spectrum allocation of FDD. Since not requiring FDD’s paired spectrum with fixed duplex distance, TDD is easier to create “holes” in the band to protect incumbent satellite users. In conclusion, TDD provides efficient spectrum usage and flexibly allows networks to coexist with FSS and Amateur stations as necessary.
For those reasons, TDD may allow more flexible accommodation of current use of the frequency bands by other services.
As for the Q9, option 2 may be preferred and GTI also suggest that existing licensees in urban tier would not be required to be protected from mobile service. As mentioned above, TD-LTE can be easily co-existence with existing licensees.
If you have a question, comment or suggestions regarding our submission, please send your feedback to my attention.
Yours truly,
GTI Secretariat
E-mail: admin@lte-tdd.org, [email protected]
Website: www.lte-tdd.org
Mr. Peter Hill Director General Spectrum Management Operations Branch 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 Mr. Hill:
Hispasat S.A. 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”). Hispasat provides its comments specifically to Question 7 and its proposal to reallocate the 3500 MHz band (3475-3650 MHz) to include mobile services and its consequential changes to the Canadian Table of Frequency Allocations.
According to the studies conducted in ITU1, the Fixed Satellite Service (FSS) in the 3700-4200MHz range is subject to harmful interference from the Mobile Service in adjacent band if a minimum separation distance in the range of several kilometers is not guaranteed. However, this consultation does not include any technical proposal to protect existing and planned FSS earth stations in the 3700-4200 MHz band from the Mobile Service in the 3475- 3650 MHz band. Hispasat has concerns on how this sharing could be achieved, especially considering the difficulty to guarantee the implementation of an exclusion area around each FSS earth station in Canada or in a neighboring country. Furthermore, in case this band is reallocated to the Mobile Service, a technical framework to mitigate any interference caused into the other services should be deployed.
Hispasat would like to point out that this alleged increasing demand for mobile services could be satisfied by alternative methods, such as deployment of more spectrally efficient technology, WiFi offloading or simply considering the unused spectrum currently allocated to mobile services. In comparison with assigning more spectrum for mobile services, these methods would not affect other services currently in use.
1 ITU‐R CPM15.02. Director of the Radiocommunication Bureau, Draft CPM Report, Section 1/1.1/4.1.8.2 http://www.itu.int/md/R12‐CPM15.02‐C‐0001/en Sincerely yours,
Vicente Rubio Carretón Regulatory Affairs, Manager HISPASAT, S.A. Paseo de la Castellana 39, 28046 Madrid, Spain
Jonathan L. Holmes Executive Director [email protected]
8 October 2014 Via email Senior Director Spectrum Licensing and Auction Operations Industry Canada 300 Slater Street (JETN, 15th) Ottawa, Ontario K1A 0H5
Dear Sir/Madam:
Subject: Canada Gazette Notice No. DGSO-003-14 - 6 September 2014 - Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas
1. The Independent Telecommunications Providers Association (“the ITPA”) has obtained a copy of Gazette Notice No. DGSO-003-14, published on 6 September 2014 (“the Consultation Document”). Pursuant to the procedures established in section 10, the ITPA hereby submits its comments. The list of the 20 companies represented by the ITPA is found in the Appendix to this submission and a map of these companies’ rural incumbent serving territories can be found at www.itpa.ca. A number of ITPA members currently use 3500 MHz spectrum to provide fixed wireless services to rural Canadians and would be directly impacted by the changes proposed by Industry Canada in the Consultation Document.
2. The ITPA’s silence on any of the questions posed by the Consultation Document should not be taken as agreement with Industry Canada’s proposal on that issue where such agreement is not in the best of interests of ITPA members.
29 Peevers Cres., Newmarket, Ontario, L3Y 7T5, Tel: 519.595.3975, Fax: 519.595.3976 www.itpa.ca 3. The ITPA is on the record in past Industry Canada consultations1 advocating for much smaller Tier sizes to enable small service providers to acquire valuable wireless spectrum and, as a result, enhance competitive market forces in the wireless market. Industry Canada’s Tier 4, the smallest Tier size currently in use, presents the single biggest obstacle to market entry for small service providers in the mobile wireless market. As will be described further below, continued use of Tier 4 in the 3500 MHz Band to the exclusion of all other options for smaller service areas, when combined with the proposals in the Consultation Document, will once again hinder the efforts of small service providers to offer competitive wireless services to rural Canadians.
Urban Tier 4 Areas – 3500 MHz 4. While Rural Tier 4 areas will continue to be devoted to primarily fixed-wireless services, Industry Canada is proposing to open up the Tier 4 areas it has re-classified as Urban Tiers to mobile services. Mobile services would pre-empt existing fixed wireless services across the entirety of each of these new Urban Tiers. The distinguishing feature of each new Urban Tier is the presence of a population centre of 30,000 or more.
5. Industry Canada’s stated intent in proposing these changes to the 3500 MHz Band is to facilitate the expansion of mobile services in urban areas:
13. Comments received from stakeholders for the Consultation on Renewal Process for 2300 MHz and 2500 MHz Licences indicated that there is strong demand for both fixed wireless broadband services in rural areas, and mobile broadband services in urban areas. ... 21. ...the 3500 MHz spectrum is well suited to meet the increasing demand for mobile spectrum in urban areas to address congestion... and 22. In the Renewal Decision, the Department indicated that it anticipated that demand for mobile services would be very high in large urban areas. In addition, there may be limited demand for mobile services in rural areas and, therefore, these licensees would likely continue to provide fixed services. (emphases added)
1 See most recently the ITPA’s comments, dated 4 September 2014, on Consultation on the Technical, Policy and Licensing Framework for Advanced Wireless Services in the Bands 1775-1780 MHz and 2155-2180 MHz (AWS-3).
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6. While the ITPA has no objection to facilitating additional mobile expansion in urban areas, Industry Canada’s proposal to designate entire Tier 4 areas as Urban uses too broad a brush. It cannot be lost on Industry Canada that the vast majority of the geographic territory of most of the newly designated Urban Tiers is, in fact, rural. Its proposal would eliminate any opportunity for services providers to offer, or continue to offer, fixed wireless services in these rural areas. Tier 4-088 - Stratford2 is a perfect example of this problem. The city of Stratford is the largest population centre in that Tier and it barely meets the minimum requirement. All of the remaining territory in the Tier consists of rural farmland or small villages/hamlets. Other than the few reasons provided in the Consultation Document, it is unclear as to why Industry Canada is proposing the 30,000 cut-off. The ITPA submits that if Industry Canada implements its proposal, it should consider using much larger population centres as the cut-off.
7. More importantly, Industry Canada’s proposal would require those service providers that are already serving rural customers using this spectrum to needlessly terminate service to those customers and force rural Canadians migrate to less satisfactory and more expensive Internet access services such as satellite or even dial-up. Such a result would only serve to widen the rural/urban digital divide, not close it. The ITPA notes that the first pillar of the federal government’s recently released Digital Canada 150 strategy is “Connecting Canadians” which has as one of its goals “providing rural and remote communities with fast, more reliable online services.”3 It is unclear to the ITPA why the same department of the federal government would plan for a significant roll out of rural broadband services via the Digital Canada 150 strategy on the one hand and on the other hand force service providers to potentially cut services to similarly situated rural customers who are currently using this spectrum for their broadband connections. ITPA members service hundreds of fixed wireless customers via the 3500 MHz Band. These customers’ existing services have been put in jeopardy by Industry Canada’s proposal.
8. While the ITPA applauds the recognition by Industry Canada that urban and rural areas of the country deserve different treatment, its approach of designating an entire Tier as Urban completely ignores the reality on the ground. Tier 4 areas are large geographic areas. As an
2 http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf05827.html 3 https://www.ic.gc.ca/eic/site/028.nsf/eng/h_00569.html
Page 3 of 6 alternative, the ITPA to proposes that Industry Canada adopt an approach that would use the existing hexadecimal grid-cells - the smallest geographic area currently used for wireless allocation - to designate the truly urban portions of existing Tier 4 areas as being eligible for mobile traffic leaving the remaining large swathes of Tier 4 areas open to continued use for fixed wireless service. One or more adjoining grid-cells in a Tier 4 area - the truly densely populated urban area - would, as required, be designated as eligible for mobile service. This approach would facilitate the growth of mobile services as contemplated in Consultation Document and the need to relieve congestion in large population areas while establishing more realistic dividing lines between rural and urban areas.
Options for displacement 9. In section 9.2 Industry Canada requests feedback on its two options for displacement. The ITPA does not support the proposal to classify entire Tier 4 service areas as Urban. However, in the event that Industry Canada forges ahead with its proposal it is the view of the ITPA that Industry Canada should use Option 2. This option is the most efficient and proportionate approach to displacement given that it would be used only after a bona fide need for commercial mobile frequency is demonstrated.4 This would provide the maximum flexibility for those service providers offering service and would only require service providers to cut off service to existing customers in the event of demonstrated need by a mobile service provider.
One-year license terms 10. Industry Canada’s proposal to employ one year license terms for all licences in the 3500 MHz band is too short a term, will be unduly onerous for small licensees and could ultimately create a drag on investment in rural infrastructure. Wireless network equipment will typically last for at least five years before having to be replaced/up-graded. Service providers need a return on their investment in this equipment over at least the same period of time in order to justify the risk taken in making the initial investment. If the regime established by Industry Canada as a result of this consultation creates uncertainty as to whether an adequate return on investment will be realised, small service providers will not make these investments in the first place and equipment manufacturers will scale back on the production of this equipment, creating a downward spiral that will only serve to reduce investment in infrastructure in rural Canada.
4 Mobile service providers should be required to demonstrate that they have used all suitable, available spectrum to address growth and congestion issues in urban areas prior to being granted additional 3500 MHz spectrum.
Page 4 of 6 Failure to ensure adequate capital recovery time will also serve to drive up costs to consumers as providers use price increases to reflect the higher risk associated with licence renewal uncertainty. 11. Finally, small service providers typically do not have internal staff dedicated to regulatory/government compliance regimes. Having to reapply each year represents a significant and disproportionate administrative burden for small companies. 12. For all of these reasons, the ITPA submits that Industry Canada should establish a licence term of at least 5 years.
Yours truly,
Jonathan Holmes
Page 5 of 6 Appendix
Member of the Independent Telecommunications Providers Association (ITPA) Brooke Telecom Co-operative Limited Bruce Telecom City West Cable & Telephone Corp. Cochrane Telecom Services Execulink Telecom Inc. Gosfield North Communications Co-operative Limited Hay Communications Co-operative Limited Huron Telecommunications Co-operative Limited The Lansdowne Rural Telephone Company Limited Mornington Communications Co-operative Limited Nexicom Telecommunications Inc. Nexicom Telephones Inc. North Frontenac Telephone Corporation Limited North Renfrew Telephone Company Limited Ontera Quadro Communications Co-operative Inc. Roxborough Telephone Company Limited Tuckersmith Communications Co-operative Limited WTC Communications Wightman Telecom Limited
*** End of Document ***
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October 8th, 2014. Sent via email: [email protected]
Senior Director Spectrum Development and Operations Industry Canada 300 Slater Street Ottawa ON K1A 0C8
Re: Canada Gazette, Part I, August 19, 2014. Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14)
Pursuant to the procedures outlined in the above noted document, the attached Comments are being filed on behalf of Bell Canada (“Bell”), Inukshuk Wireless Partnership (“Inukshuk”), and Rogers Communications Partnership (“Rogers”).
Yours very truly,
Barry Chapman Don Falle Ken Engelhart Bell Canada Inukshuk Wireless Partnership Rogers Communications Partnership Attach.
Comments of Bell Canada Inukshuk Wireless Partnership Rogers Communications Partnership
Canada Gazette, Part I, August 19, 2014. Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14)
October 8th, 2014
Executive Summary
E1. The 3500 MHz band represents valuable commercial mobile spectrum because of the relatively wide blocks that are possible and the faster broadband speeds that this will enable. Through effective management by Industry Canada this band has the potential to bring high- capacity fixed and mobile wireless Internet access services to Canadian consumers and businesses. Inukshuk Wireless Partnership (IWP) holds spectrum in this band and has successfully deployed services in accordance with its existing conditions of licence. As Industry Canada considers making amendments to the licensing of this band, IWP would like to stress the opportunity that exists in maximising the use and value of this band through making the right policy decisions for Canada.
E2. While IWP welcomes Industry Canada’s initiative with regard to making changes to the 3500 MHz band, before all else, IWP recommends that Industry Canada establish a new band plan. This would align Canada with international developments regarding the future use of the 3500 MHz band and with a rapidly emerging ecosystem.
E3. IWP notes that Industry Canada has often followed the United States when developing new band plans. However, due to the on-going uncertainty in the U.S with regards to its policies for the 3500 MHz band, IWP urges Industry Canada to not follow the U.S. with respect to this band.
E4. Industry Canada’s leadership in managing the 2500 MHz/2600 MHz band should be replicated for the 3500 MHz band. IWP recommends that the Stakeholder Proposal Development process used for the 2500 MHz/2600 MHz band should be used to establish a new band plan and licensing policy for the 3500 MHz. This would facilitate interaction between stakeholders so that all relevant parties have the opportunity to provide input into the development of a new band plan.
E5. Further, the policy that allowed flexible use of the spectrum in the 2500 MHz/2600 MHz band which led to the rapid deployment of services should also be enacted for the 3500 MHz band.
E6. IWP does not believe there is any value in differentiating between a mobile or fixed allocation for the 3500 MHz band. Instead, the policy should allow for the flexible use of this band, consistent with the licensing of other mobile bands. With that in mind IWP supports the proposal to add a mobile allocation to the 3500 MHz band so that mobile services can be provided by licensees. However, IWP does not believe that adding a mobile allocation represents a fundamental reallocation and, therefore, there is no need for the displacement of existing licensees.
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E7. To acknowledge the significant investments in networks by some of the existing licence holders, IWP strongly urges Industry Canada to allow those who have met their conditions of licence to transition to a new mobile licence for two-thirds of the amount of spectrum that they currently hold. This will allow the same licensees to seamlessly transition their customers from fixed services to mobile services and will avoid interrupting the wireless broadband services that these Canadians rely on every day.
E8. In its proposal, Industry Canada suggests classifying Tier 4 service areas as either urban or rural whereby mobile services would be permitted only in urban areas and rural areas will be limited to fixed services. Splitting the use of the band in this manner will reduce the benefits that will arise for Canadians and doing so would complicate the technical issues stemming from frequency coordination. The technology that is being developed for this band can and should be used in both urban and rural areas. Splitting the use of the band would deny rural Canadians the benefits of the mobile broadband services that can be provided in this band.
E9. IWP is opposed to grid-cell licencing. Our real world experience in deploying in the 3500 MHz band has shown that the potential for interference is high and this will only be exacerbated with grid-cell licencing. It will likely create a number of complications that would adversely impact the quality of services provided to rural customers.
E10. Further, the proposed licence term of one year term is too short. It will not provide sufficient time for any licensee to achieve their business objectives. This will discourage licensees from investing in areas where this new form of licensing will be required.
E11. With respect to the rural tiers as proposed by Industry Canada, any new licensed spectrum in these areas will have the same designation as the existing licences. These new licences will be designated as FWA and licensed for fixed services. If Industry Canada proceeds with its proposal, the rural licences should be renewed for a ten year period, not one year, as suggested by Industry Canada.
E12. Since the Time-Division Long-Term Evolution (TD-LTE) technology that has already been deployed in the band is frequency agile, these systems do not need to be displaced and can simply be re-tuned. Should Industry Canada want to create other classes of licences in the band, IWP can move its existing deployments to another part of the band. This would be far more reasonable than the proposed displacement policy. However in the event that Industry Canada elects to proceed with its proposal, IWP supports the displacement of existing licensees in urban tiers only if, and as required, after commercial mobile licences are issued. Licensees should have one year to transition once notified.
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Introduction
1. Inukshuk Wireless Partnership (IWP) welcomes the opportunity to respond 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) (‘the consultation paper’). IWP supports the Spectrum Policy Framework for Canada’s objective of maximizing the economic and social benefits that Canadians derive from the use of radio frequency spectrum. Further, IWP agrees that ‘spectrum policy and management should support the efficient functioning of markets by permitting the flexible use of spectrum and making it available for use in a timely matter’.1 The comments offered below are made within the context of these objectives.
2. Since 2005, IWP has been a pioneer in the utilization of high frequency spectrum in Canada. We have deployed a wireless broadband network nationally, including in many rural areas using 2500 MHz spectrum. Accordingly, IWP has significant operating experience in a wide variety of regions across different applications.
3. The 3500 MHz band represents valuable spectrum for Canadian society and the economy. Due to the large amount of spectrum available, it is perfectly suited to support the growth of rural broadband and small cell deployment, including in dense urban areas.
4. IWP has long been a forerunner in deploying new technologies in the 3500 MHz band. We are currently deploying a state-of the art Time-Division Long-Term Evolution (TD-LTE) system which, when completed, will be one of the largest 3500 MHz TD-LTE networks in the world, covering both urban and rural areas. In deploying this new network and based on the ‘Implementation of Spectrum Usage’ Condition of Licence (COL) set forth in Appendix A of DGRB-007-09, Licensing Framework for the Auction of Residual Spectrum Licences in the 2300 MHz and 3500 MHz Bands , IWP has fully satisfied this COL for all 3500 MHz licences. We have filed status updates in confidence with Industry Canada that demonstrate our compliance.
5. IWP supports the utilization of the 3500 MHz band, especially in rural areas of Canada through the sub-licensing of IWP’s 3500 MHz spectrum. This is something that Industry Canada has encouraged. Today, some of the largest rural deployments in Canada have been accomplished through sub-licence agreements with IWP.
6. The 3500 MHz band brings several benefits to wireless operators including its capability to support wide bandwidth channels and its international use. Deployment has already started
1 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 2.
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in China and many European countries. Historically, Canada has often followed the U.S. in the development of various band plans. However, IWP cautions Industry Canada from doing that for the 3500 MHz band, since it is our understanding that the U.S. experience with this band has been fraught with complications.
7. One of the cornerstones of Digital Canada 150, the Government’s digital action plan, is connecting Canadian businesses and citizens.2 The Government has placed a great deal of emphasis on creating a digital policy that connects Canadians through high-speed Internet access and the latest wireless technologies. The 3500 MHz band is an important part of the spectrum required to deliver the Government’s digital objectives to enhance productivity for both residential and business consumers.
8. Critical to ensuring the effective use of this band is the ability to take advantage of the development of a global technological ecosystem, which is based on industry standards for both network equipment and terminal devices. While it is in its infancy, this ecosystem is beginning to emerge at 3500 MHz. The Third Generation Partnership Project (3GPP) has also defined bands 42 and 43 covering the range 3400-3800 MHz.
9. IWP would like to continue to develop services in the 3500 MHz band to bring mobile high- speed Internet access to Canadians.
Relevant Precedent
10. The evolution of technology plays a critical role in the efficient development of spectrum use. In many ways the development of the 3500 MHz band mirrors the evolution of the 2500 MHz/2600 MHz band in Canada. In the mid-2000s, only fixed wireless equipment was available and there was a lack of a global ecosystem for equipment at 2500 MHz/ 2600 MHz.
11. The Canadian 2500 MHz/2600 MHz band was designated for Multipoint Communications Systems (MCS) and Multipoint Distribution Services (MDS). The Canadian band plan followed the U.S. band plan with 6 MHz wide RF channels—a legacy of its original use for interactive television (ITV). The band then began to evolve with the introduction of proprietary pre-WiMAX and WiMAX (802.16e) technology and other technologies. Globally, there was a lack of a critical mass of WiMAX operators and this left a stranded standard
2 Digital Canada 150. https://www.ic.gc.ca/eic/site/028.nsf/eng/h_00569.html
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without a technology roadmap. There was also a lack of equipment (both network base stations and terminals) capable of supporting mobile or fixed services.
12. The 2500 MHz/2600 MHz band was and remains a global band. 3GPP based operators and the International Telecommunication Union (ITU) designated it as an International Mobile Telecommunications (IMT) band and defined a band plan that allowed vendors to develop equipment and terminals to operate within that band plan.
13. In the mid-2000s Canada was at a crossroads. Previously Canada had followed U.S. band plans, almost without exception. However, the Canadian Industry realized that this might not be the best approach for the 2500 MHz/2600 MHz band. The Industry urged the Department to consider adopting the ITU band plan and this led to a Stakeholder Proposal Development (SPD) process. This put stakeholders in a series of face to face meetings with Industry Canada, where options and their rationale for the long term development of a band plan, and the various advantages and disadvantages of different band plans, were presented and discussed The process resulted in the following: o Key industry input to the development of a long term Canadian band plan. o A shortened timeline for consultations. o A successful result where the final band plan was based upon a globally defined international band plan and agreed to by all stakeholders.
14. Industry Canada reassigned the band from MCS to Broadband Radio Service (BRS) and then assigned flexible use BRS licences to existing operators following the return to Industry Canada of 33% of the original MCS/MDS spectrum that was licensed to individual licensees, such as IWP. The specific reference to the 2500 MHz displacement policy stated:
Should an existing MCS or MDS licensee, authorized to operate in the 2500 MHz band, wish to offer mobile services, they may apply to the Department for a new spectrum licence in the mobile service. The Department may issue a new spectrum licence which will include mobile service for approximately two-thirds of the originally authorized spectrum in the 2500 MHz band and one-third will be returned to the Department subject to the following: In order to implement mobile service, the Department will adopt a new band plan (see section 5), taking into account the needs of incumbents and other requirements. 3
3 Notice No. DGTP-002-06 — Policy Provisions for the Band 2500-2690 MHz to Facilitate Future Mobile Service http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf08551.html
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15. Similar to Industry Canada’s policy approach with the 2500 MHz/2600 MHz band, IWP submits that operators in the 3500 MHz band that satisfy the existing COLs should be eligible to transition to a flexible use licence for two-thirds of the amount of spectrum that the licensee originally held. This would recognize the significant investments of existing licensees in the band. It would also ensure continuity of services to consumers and businesses that are currently enjoying the benefits of high speed broadband Internet provided in the 3500 MHz band. Finally, it would be consistent with the fact that existing licensees have a high expectation of renewal where all licence conditions have been satisfied.
16. The 2500 MHz/2600 MHz BRS licences provide for the ‘flexible use’ of the spectrum, meaning that the licences can be used to provide mobile and fixed services. This approach has been extremely successful. There is also no geographic distinction between urban and rural licence areas, as Industry Canada has proposed for the 3500 MHz band. The 3500 MHz band should be licensed in the same manner. Creating an artificial distinction in the band based on use or geography will establish barriers which do not take into account the variety of applications that are developing using the very same underlying technology.
17. IWP and others have deployed technology in the 3500 MHz that is already compatible with mobile services. This was not the case in the 2500 MHz/2600 MHz band where the technology that was initially deployed was only compatible with fixed services. Some 3500 MHz band licensees such as IWP have already implemented LTE mobile technology. This mobility capability has been disabled by IWP to ensure compliance with the requirement that only fixed services may be implemented. However, it can easily be enabled to offer mobile services. The technology is also frequency agile, so in fact IWP does not have to be displaced, and our equipment would allow us to move to another part of the band.
18. Finally, Industry Canada’s forward looking approach to managing the 2500 MHz/2600 MHz spectrum band facilitated the upcoming 2500 MHz auction, which is scheduled for April 2015. Further, today there is a fully developed ecosystem of both network equipment and terminals available for use in the 2500 MHz/2600 MHz band in Canada.
19. The Department’s approach to managing the 2500 MHz/2600 MHz band has brought significant benefits to Canadian society and the economy and stands as an example of a highly successful Industry Canada policy. IWP would urge the Department to incorporate aspects of the 2500 MHz/2600 MHz policy into the policy that is being developed for 3500 MHz. The SPD process was effective and collaborative. It could easily be replicated for the band planning for 3500 MHz. The provision for the flexible use of spectrum in the 2500
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MHz/2600 MHz band has led to a flourishing ecosystem and the rapid deployment of services in the band. It would be a logical choice for the 3500 MHz band due to the large bandwidth that is available to support data services and the growing technical ecosystem. Further, the ability to transition to a new licence for two-thirds of the amount of spectrum would create minimal disruption to IWP’s existing customers and sub-licensees who undoubtedly would like to continue to enjoy the high speed Internet access that IWP delivers to its customers.
20. For the reasons stated, IWP strongly recommends that Industry Canada develop a similar policy for the 3500 MHz band.
Current Situation at 3500 MHz
21. In many ways the 3500 MHz band is now in the same position as 2500 MHz/2600 MHz was in the mid-2000s. In summary: o 3500 MHz spectrum is used globally for mobile and fixed services. There is a significant variety of technology and many operators in the band. o In Canada, the band has largely been used to provide fixed wireless services for Internet access and even some legacy systems providing plain old telephone service ‘POTS’ access in remote areas. o Within Canada there are many different technology standards deployed in the band ranging from proprietary to industry standards-based systems such as WiMAX and 3GPP TD-LTE. o This wide range of technology has greatly complicated both frequency coordination and the efficient use of spectrum. This has led to interference between different types of systems, which in some areas has constrained the efficient use of spectrum. This is described in more detail in Appendix 1. o Although both FDD and TDD systems were available at one time in the 3500 MHz band, the technical roadmap has largely evolved in favour of TDD based systems (both WiMAX and TD-LTE). o It has become apparent though that WiMAX systems are rapidly being abandoned globally in favour of TD-LTE. In fact, several major equipment vendors have announced end of life timelines for WiMAX equipment and upgrade paths from WiMAX to TD-LTE. o The most significant recent deployments in Canada have used industry standards- based technology employing 10 MHz or 20 MHz wide RF channels
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which results in an inefficient use within the current Canadian band plan which has 25 MHz allocations. o For those that have deployed TD-LTE, the mobile capability is already installed; it just needs to be enabled. o While there are a limited number of TD-LTE equipment vendors and devices currently available, this is rapidly changing. According to industry experts, devices are expected to support multiple frequencies, based on chipsets under development, and support both FDD and TD-LTE.4 o Being part of a global ecosystem can bring significant benefits to all consumers, businesses and Canadian operators in all regions.
22. The 3500 MHz band is ideal for delivering high-capacity fixed and mobile wireless Internet access services. However the band’s capabilities will be jeopardized if it is carved up into small channel sizes. Further, the band is perfectly suited to support traffic hot-spots due to its propagation characteristics and re-use capabilities. Finally, the band supports a wide range of voice, data and video applications for consumers, as well as business and M2M customers, something which cannot solely be provided with landline based services or other frequency bands.
The US & the 3500 MHz Band
23. In evaluating the current situation with the 3500 MHz band, IWP also examined developments in the U.S. to see if there were any valuable learning’s to inform the Canadian experience.
24. The Federal Communications Commission’s (FCC) proposal5 for the 3500 MHz band is structured in such a way that does not maximize the use of a finite and valuable resource. The FCC has proposed to make the 3500 MHz spectrum available based on a prioritization of access. It has defined three access tiers of service which are: “(1) Incumbent Access; (2) Priority Access; and (3) General Authorized Access (GAA). The Incumbent Access tier would consist solely of authorized Federal and grandfathered licensed FSS 3.5 GHz Band users. The Priority Access tier would consist of a portion of the 3.5 GHz Band designated for small cell use by certain critical, quality-of-service dependent users at specific, targeted locations. The GAA tier would be assigned for use
4 http://www.whitepapers.lightreading.com/pdf_whitepapers/approved/1383671986_hr_ltetdd.pdf 5 FCC. NOTICE OF PROPOSED RULEMAKING AND ORDER. FCC 12-148. December 12 2012.
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by the general public on an opportunistic, non-interfering basis within designated geographic areas.”6
25. The FCC has proposed that the 2nd access tier licences will be commercially available for a term of one year. It is likely this will lead to low commercial interest among the tier 2 market as no one will be prepared to invest for a one year term, since it is a high fixed cost business and will take several years to earn a return The tier 3 unlicensed access will be managed through a proposed ‘spectrum access system’(SAS). Due to the potential for interference, this is a very complex and untested way of managing spectrum, it will likely lead to significant technical issues and delays in implementation. Further, the FCC has proposed exclusion zones that run 100 miles inland from coastal areas and this would exclude more than 60% of the population.
26. Use of the 3500 MHz band in the U.S. is encumbered by factors that are not relevant in Canada or exist to a much lesser degree. Firstly, 3500 MHz is already widely used in Canada for a broad range of commercial applications in both urban and rural markets, while in the U.S. only the Wireless Broadband Services (WBS) band (3.65 -3.7 GHz) has commercial users.
27. Based on IWP’s operating experience at 3500 MHz, as explained in other parts of this paper, we have serious doubts that the proposed SASs will lead to an efficient environment that encourages the widespread use of the band. The SASs may be administered by third parties who may have insufficient experience in spectrum management.
28. Without having some degree of assurance of the amount of spectrum that will be available to a network operator who may opt for tier 3 access perspective operators cannot adequately plan and operate a network. Moreover the concept of allowing a database operated by a 3rd party to potentially control bandwidth access may lead to complications of security and operational integrity.
29. As noted in Appendix 1, interference can be a significant issue at 3500 MHz, especially under varying propagation conditions, as it can complicate real time frequency coordination issues. These frequencies also can behave like microwave systems and are subject to ‘ducting’7 at times.
6 FCC. NOTICE OF PROPOSED RULEMAKING AND ORDER. FCC 12-148. December 12 2012. Page 56. 7 Ducting is the transmission of signals over long distances under certain atmospheric conditions. It can be prevalent at microwave frequencies.
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30. Based on IWP’s industry knowledge we understand that in the WBS band many operators are not diligent in keeping their network information updated and accurate in the Industry Canada database and the lack of accurate information makes frequency coordination more difficult.
31. The details of the proposed U.S. band plan have been widely criticized by American industry.8 Based on the lack of a clear commercial market in the U.S for this spectrum, the uncertainty around the proposed ‘SAS’ and the extensive exclusion zones, and the fact that the situation in Canada is very different to the U.S., IWP urges Industry Canada not to follow the U.S. approach to the 3500 MHz band.
Mobile versus Fixed
32. The concept of mobile versus fixed allocation is largely irrelevant at 3500 MHz. Both are simply applications of the same underlying technology platform that has already been implemented in the 3500 MHz band in Canada. Distinguishing between the two does not promote the Government’s stated objective that ‘spectrum policy and management should support the efficient functioning of markets by permitting the flexible use of spectrum’.9
33. Because of its propagation characteristics, 3500 MHz spectrum will likely not be used to provide coverage to mobile devices being used in a vehicle moving at high speed since this can be done more effectively and reliably with lower frequency bands. However 3500 MHz spectrum would be effective for portable applications such as to serve traffic hot spots or to provide coverage to someone using a device while walking. It will also provide important capacity expansion for existing operators including providing a backhaul link for small cells. Based on developments in other countries there is no differentiation in the use of the band on the basis of urban and rural geography, and deployment will include both large cell and small cell (hot spot) coverage.
34. Moreover, in other frequency bands, such as 2500 MHz/2600 MHz, the licensing does not provide a distinction between fixed and mobile. Operators are free to serve their customers, whether they are fixed or mobile, as long as it is compatible with the technical rules. Indeed, today Canadian operators such as SaskTel and Rogers serve both fixed and mobile customers in the 2500 MHz/2600 MHz band, with LTE platforms.
8 http://www.fiercewireless.com/tech/story/att-google-and-others-pick-apart-fccs-35-ghz-spectrum-sharing- scheme/2014-07-17 and http://www.attpublicpolicy.com/fcc/spectrum-sharing-lets-walk-before-running/ 9 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 2.
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Band Plan
35. While, there is no specific question in this consultation regarding a new band plan, IWP believes that before adding a mobile allocation and displacing incumbents, Industry Canada should first establish a new band plan at 3500 MHz. Further, in its submission, the RABC urges ‘caution in major changes to licensing without first having a defined band plan’.10
36. One of the main benefits of 3500 MHz spectrum is that it facilitates large bandwidth channels, which is ideal to deliver faster broadband speeds. The demand for additional spectrum coupled with the availability of TD-LTE equipment is driving the need for a new band plan. As was the experience with the 2500 MHz band, this will allow for greater planning certainty for both large and small operators alike. Further it will provide certainty to investors who need the assurance that their investment risks can be amortized over a long term, not one year as is currently proposed by Industry Canada, and similar to the FCC’s proposal in the U.S.
37. Developments outside the U.S. indicate with great certainty that the band will be a TDD band. Based on this, the suggestion made by the Department in paragraph 41 is not realistic. The paragraph states that: ‘any new grid-cell spectrum licence will be authorized only for the amount of spectrum required for the intended operations (with a minimum of 5+5 MHz paired and 5 MHz unpaired)’.11 While the 5+5 MHz paired and 5 MHz unpaired bandwidth are proposed as a minimum, it is totally insufficient in light of TD-LTE technology which is ideally suited to larger bandwidths. The current band plan is not optimized to support the rapidly evolving ecosystems such as 3GPP based LTE systems which utilize 10 and 20 MHz channels rather than the current 25 MHz channel blocks that are used in the band. IWP also notes that many customer terminals may not support 15 MHz channel bandwidths. IWP urges the Department to revise the proposed channel sizes to better reflect the technical characteristics of the 3500 MHz band.
38. Further, re-farming the existing 3475-3650 MHz spectrum alone into 10 and 20 MHz channels would free up 40 MHz of spectrum which could be more efficiently utilized by TD- LTE.
39. The bandwidth that the Department may choose to make available for a FCFS allocation should also take into account the frequency re-use pattern that would need to be
10 RABC Response to Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 2. 11 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 9.
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employed, as it will likely require additional spectrum. Self-interference between sectors limits both coverage and performance in TDD systems.
40. IWP also recommends that Industry Canada extend the band to encompass the entire range of 3400-3700 MHz and adopt the 3GPP bands 42 and 43. The portion of the band from 3650-3700 MHz that is currently designated for WBS should be included in this new band plan. There should be no distinction in the services that are permitted in each section of the band. This band should be licenced on a flexible use basis so that licensees may offer fixed and mobile services to support their business plans. IWP notes that the additional spectrum will also enable the introduction of LTE Advanced (LTE-A) in the band where multiple radio frequency (RF) channels are bonded together (carrier aggregation) to support higher data rates which will enable a wide range of applications and higher speed services in both urban and rural markets.
41. Extending the range of the band from 3450 MHz down to 3400 MHz would allow Canadians to benefit from a developing regional, if not global, ecosystem. This is supported by the following three developments:
o Firstly, ITU-R Region 1 has already added a primary mobile allocation under some conditions down to 3400 MHz (accordingly, 3GPP has already established band 42 (3400-3600 MHz); o Secondly, in ITU-R Radio Regulations, mobile services are already allocated in 3400-3450 MHz on a secondary basis for both Regions 2 and 3; o Finally, footnote 5.433 urges that radiolocation systems in 3400-3600 MHz cease operation.12 In the event that such systems are still in operation, deployment of mobile services may be considered where radiolocation service is not deployed, using a footnote similar to C15 of the Canadian Table of Frequency Allocations. This gives priority to radiolocation service over mobile service.
42. In addition, there is significant and growing momentum to use 3400-3600 MHz Band 42 for TD-LTE globally. The main proponents of this are members of the ‘3.5 GHz Interest Group’ which is a sub-group of the Global-LTE Initiative. This group promotes TD-LTE spectrum bands 42 and 43. Members of the group include iSoftBank, KDDI, TELUS, GSMA, QUALCOMM, and Fujitsu Semiconductors. IWP notes that Industry Canada is listed as a member of this sub-group, so the Department will be well aware of the global efforts towards extending the range of this band.
12ITU-R Radio Regulations: ITU, Radio Regulations Articles, Edition of 2012.
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43. IWP notes that the RABC response to this consultation cites a recently approved Canadian position to allocate mobile service in this band. The position will be submitted at an upcoming CITEL meeting in preparation for WRC-15. The paper states that ‘Canada proposes a Mobile Service (MS) allocation in the range 3400-3500 MHz and an IMT identification in the range 3500-3700 MHz’.13 While no one can predict with certainty the final outcome of WRC-15, a high likelihood exists that the band will be globally harmonized for TD-LTE.
44. Below is one potential band plan that encompasses the range 3400-3700 MHz. We believe that any new band plan for Canada must encompass the entire range and reflect the technology evolution that is occurring in the 3500 MHz band in general. See Appendix 2 for more detail.
45. Although the U.S. has not set its final policy for the use of 3500 MHz spectrum, there is no reason to wait until this is completed before beginning to develop a Canadian band plan. For reasons stated elsewhere in this paper, the proposed U.S. plans for 3500 MHz should not be followed by Industry Canada.
RESPONSES TO THE CONSULTATION PAPER 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.
46. IWP supports Industry Canada’s objective of facilitating rural connectivity, which is one of the main purposes of this consultation. However, before proceeding with the re-
13 RABC Response to Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 4.
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classification of Tier 4 service areas as urban or rural; there is a need to introduce a new band plan for Canada in the 3500 MHz band.
47. In the event that the Department proceeds with its proposal, IWP does not support the proposed designation of urban versus rural. It is unnecessary from both a policy and technical viewpoint, and further complicates the technical issues stemming from frequency coordination.
48. From a policy perspective there is no clear public benefit to splitting the band into urban and rural. Rural Canadians will be denied the benefits associated with the implementation of mobile services in the 3500 MHz band and urban Canadians will be denied the benefits of fixed services in the band. The technology that is being developed for this band can be used in both geographic areas and such a designation would limit carriers from offering services outside their ‘urban’ or ‘rural’ footprint.
49. There are many rural areas which would be compromised by the definitions contained in Industry Canada’s proposals. There are many ‘effectively’ rural areas that are within the designated urban areas. Both existing and future operators would be limited in their ability to provide services to those ‘rural’ customers.
50. Many of the Tier 4 areas listed as ‘rural’ are essentially adjacent to urban Tier 4 areas. Rural operators generally try to maximize coverage and minimize the number of sites they deploy in order to economically serve rural areas. This means that they utilize sites that might have towers as high as 100 metres or more. This in turn means that the radio frequency coverage from a site can extend 30-40 km and sometimes much more depending on the specific design and geographic location. Under the existing proposal, for example, Napanee (4-071) is designated ‘rural’ in the Industry Canada list and is only 30- 40 km away from Kingston (4- 070) which has been designated as ‘urban’.14
51. With our extensive operating experience in the 3500 MHz band, IWP has encountered many substantial interference issues stemming from co-channel operation, especially with different operators and technologies. Under the proposal, the creation of interference would be contrary to the Department’s stated policy objective of maximising the economic and social benefits of spectrum as the band would not be put to the most efficient use.15 IWP has faced similar interference issues in other regions. This is further described in Appendix 1.
14 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) Appendix A. 15 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) page 2.
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52. Based on our understanding of the Industry Canada proposal, rural (fixed) operators would not be able to offer mobile services and urban (mobile) operators would not be able to offer fixed services. As noted, both utilize the same underlying technology platforms and essentially the only difference is the customer terminal type. In contrast, the 2500 MHz/2600 MHZ BRS licences permit the ‘flexible use’ of the spectrum (e.g. mobile or fixed) and there are no geographic distinctions based on urban and rural areas.
53. The 3500 MHz band should be licensed on the same basis as the 2500 MHz/2600 MHz band; such that licensees will be permitted to provide fixed and mobile services. The same kind of services will be implemented in both bands (fixed and mobile broadband), using the same underlying technology (LTE). There is no technical justification for imposing restrictions and limits on the 3500 MHz band licensees. Creating an artificial distinction will establish barriers which do not take into account the variety of applications that are currently offered and are being developed on the basis of the same basic underlying technology.
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.
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).
Question 2
54. IWP recommends that Industry Canada not issue any new licences for 3500 MHz spectrum until a new band plan is established. FCFS licences which are renewed on an annual basis, rather than for a longer term, may actually serve to deter operators from raising investment capital and deploying infrastructure especially in rural areas where the risks are inherently higher. A one year term is far too short to amortize such an investment, and does not provide enough time to deploy or make a return on an extensive commercial offering. See IWP’s response to Question 6 for further detail.
Question 3
55. IWP opposes the proposal to define licences on a per grid-cell basis. The origin of such a proposal is unclear, as there appears to be no evidence of broad support among existing and potential licensees to pursue such an approach.
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56. The current wording which reads “it is proposed that the new grid-cell licenses be authorized only for the amount of spectrum required for intended operations” is unclear. Industry Canada should clarify how the ‘amount of spectrum required’ will be determined and over what timeframe (e.g. the one year licence period). A one year term as suggested in Annex B is out of step with the concept of spectrum licensing, whereby licensees may gradually expand their services within an area over a period of time of no less than five years but more often 10 or 20 years. As a result, a one year term will likely not provide sufficient time for an operator to achieve their business objectives. Greater clarity is also needed regarding how different applicants will be evaluated, given that many might have different target market segments and applications. IWP provides further comments on the COLs in response to Question 6.
Grid-Cell versus Tier 4 licenses
57. The current 3500 MHz spectrum licences are based on Tier 4 geographic areas, which can vary greatly in their geographic extent. Some are very large while others near urban areas are much smaller. Tier 4 areas in theory allow operators to deploy more targeted areas which would result in more licences being awarded using the same frequency blocks. Interference between Tier 4 areas in these circumstances can be substantial. IWP has dealt with dozens of interference cases at 3500 MHz over the past few years. While some have been easy to resolve, many cannot be resolved without frequency separation, which requires at least one party having to use a different channel in the area in question. Examples of this are listed in Appendix 1.
58. Assigning new spectrum licences using grid-cells, while FCFS licences still exist, will create a number of complications that could adversely impact the quality of services provided to rural customers. They include the following:
o The complexity of TDD systems: These require a much more careful planning and coordination process as compared to FDD systems and the resources to undertake it. o Constant monitoring: If one operator makes a change to their system, it affects every other operator in the vicinity. o Varying technologies in the same band: Standards such as WiMAX and TD-LTE employ different system frame timing and different operators in a given band may have chosen different uplink/downlink ratios to meet their specific business needs. Modifying the time delay of the frame start to better align the downlink transmission and uplink reception of the two systems can reduce interference. However, aligning the uplink/downlink ratio is neither possible between many
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systems, nor practical for business and operational reasons. For example, if an operator decides to offer a symmetrical data service with the same uplink/downlink ratio, this changes the timing and they might not be able to synchronize with the other operator or operators. o Varying degrees of operator sophistication: Small operators may not have sufficient tools, resources or experience to complete the necessary coordination and interference mitigation processes.
59. Grid-cells are 25km X 25km in size, which is generally substantially smaller than most Tier 4 areas. There are quite a few grid-cell licences/systems that were issued as FCFS some time ago, with many employing legacy technology, including FDD systems with limited timing and frequency agility. As a result, frequency co-ordination issues are almost impossible to resolve on co-channel frequencies in many Tier 4 areas that also contain grid-cell operations.
60. SRSP 303.4 defines the frequency coordination process that relies on a distance of 60 km. Given that grid-cells are substantially less than 60 km in size this effectively means that new operators employing grid-cell licences may in fact have to reduce their radio transceiver power at the edge of their grid-cell in order to not interfere with other licensees, operating on the same frequency in either adjacent grid-cells or Tier 4 areas.
61. A possible, but not preferred, solution to this is the assignment of separate frequencies to grid-cells or the creation geographic ‘buffer’ zones, which may further reduce overall spectrum efficiency in the band. In many rural areas this is what effectively happens where systems are isolated from systems operating in other areas. The proposal would also mean that grid-cell operators would have to strictly adhere to the frequency coordination process. Some operators do not currently do this.
62. Based on the proposal for grid-cell licensing, it is unclear whether fixed licenses will only be available on a grid-cell basis or whether the existing Tier 4 licence will still apply. Should Industry Canada proceed with its proposal, operators need clarity before committing to invest in either new technology or new geographic coverage.
63. For the reasons stated above, IWP does not support grid-cell licensing and recommends the use of Tier 4 licensing. However, in the event that Industry Canada decides to proceed with the use of grid-cells, the following steps should be undertaken:
o Separate spectrum within the band should be designated for all new grid-cell licences. IWP notes that the portion 3400-3475 MHz is not currently heavily
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occupied in the band. There may have to be geographic exclusion zones to protect legacy systems.
o Prior to the actual issuance of a grid-cell licence, the operator must demonstrate to Industry Canada that a successful frequency coordination process has been agreed to with existing operators.
o In certain areas there may be a necessity to create geographic buffer zones between grid-cell licensees on the same frequency block to reduce interference issues. While this will be less of a problem in rural and remote areas it will be in more densely populated areas.
o Since grid-cell licences issued on an FCFS basis with low spectrum fees would essentially be a new class of licence they should not be afforded the same degree of protection as current Tier 4 licensees or future licences that have a flexible use designation. Accordingly, they should be subject to displacement if they cannot avoid interfering with existing licensees.
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.
64. IWP agrees with this proposal. Given that existing point to point operators have known since 200416 that they will be subject to displacement and that the proposed licence term is for one year, six months is the absolute maximum amount of time that should be allowed for a notification period.
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.
65. While IWP does not support displacement of existing licence holders, should Industry Canada proceed with its proposal IWP concurs only subject to our other comments.
16 http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10264.html#appendix3
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6. Industry Canada invites comments on the conditions of licence in Annex B.
66. IWP has concerns with many of the proposed COLs. Firstly; IWP has an issue with regard to the condition for displacement. If there is a mobile allocation added to the band, licensees in urban tiers would no longer have an expectation of renewal and would be subject to displacement. Further, as explained in paragraph 68, IWP submits that adding a mobile allocation is not a fundamental reallocation of the band. Current FWA licensees, including IWP, have invested significant capital in building out their networks to provide connectivity to customers who now depend on these services. These licences were issued ‘with a high expectation of renewal’ and IWP has fully satisfied its conditions of licence.
67. IWP does not support the proposal to re-classify the band into rural and urban areas. However, should the Department proceed on this basis; IWP would note that any new licences in the 111 rural tiers as proposed by the Department will have the same designation for fixed services as the existing licences in the same areas. The consultation paper clearly states that; ‘in rural tiers, the use of the spectrum will remain for fixed services only’.17 For licences in these rural areas, IWP submits that there should be a ten year renewal period since the new spectrum utilisation policy and licences in these areas will continue to be limited to fixed services. As noted above, the use of the 10 year term would promote greater investment in the band in these areas since it will provide licensees with a more reasonable timeframe over which to amortise their investments and earn a return.
68. In the proposed COL regarding ‘Implementation of Spectrum Usage’ (item 10) it states that service for an FCFS licence must be provided within six months of a licence issuance. IWP submits that this timeframe is not realistic, as there are factors beyond the licensee’s control, such as negotiating and securing tower access, installing backhaul capacity, securing financing etc. Even in the most efficient business environment launching and commercializing a service in a 12 month period is very rare.
17 Consultation on Policy Changes in the 3500 MHz Band (3475-3650 MHz) and a New Licensing Process in Rural Areas (DGSO-003-14) Page 11.
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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).
Question 7
69. Adding a mobile designation to the Canadian Table of Frequency Allocations ('the table') is not a fundamental reallocation and therefore there is no basis for displacement. IWP’s existing networks can easily handle mobile services. However, whilst it is not a fundamental reallocation, IWP agrees with the proposal to add a mobile allocation to the 3500 MHz band so that mobile services may be provided by licensees. Adding a mobile services allocation to the table will benefit Canadian society and the economy through the developing global ecosystem for technology to deliver high speed broadband Internet services. Further, existing licensees such as IWP have already implemented mobile technology. Should the proposed allocation be implemented, we can offer mobile services relatively quickly.
70. IWP supports the proposed modification to footnote C20, which provides priority of mobile service over fixed-satellite service in 3500-3650 MHz since this will ensure that fixed- satellite services will not impede the orderly development of fixed and mobile services within the band.
Question 8
71. Please refer to our response to Question 1.
9. Industry Canada invites comments on its two proposed options for displacement.
72. As explained above, IWP recommends that all operators that meet the existing COLs should be eligible to transition to a flexible use licence for two-thirds of the amount of spectrum that the licensee originally held, as was the case with the 2500 MHz/2600 MHz band. This would recognize the significant investments that have already been made in the band by existing licensees who meet the current terms and conditions of licence. It would also be
21
consistent with the fact that existing licensees have a high expectation of renewal where all licence conditions have been satisfied.
73. It is important to note that TD-LTE is frequency agile (as are some other technologies). IWP’s deployments in the 3500 MHz band do not have to be displaced and can be re-tuned. Should Industry Canada want to create other classes of licences in the 3500 MHz band, IWP can move our existing deployments to another part of the band, as our equipment allows us to.
74. Based on our technology being frequency agile, we urge the Department not to displace existing licensees in urban tiers. However should Industry Canada pursue its proposal, IWP favours option 2- ‘Displacement of existing licensees in urban tiers only if, and as required, after commercial mobile licences are issued. Licensees would have one year to transition once notified’. This is consistent with the policy approach taken by Industry Canada in other spectrum bands, for example, the PCS band. 18 It would allow consumers and business that rely on existing wireless broadband services to benefit from the continued operation of those services until such time as it is necessary for the services to be displaced.
CONCLUSION
75. IWP has deployed and continues to deploy, TD-LTE extensively across our licence areas at 3500 MHz. Our network covers a population of approximately 20 million across 140 Tier 4 areas, representing 83% of the Tiers. IWP has also strongly supported its sub-licensees in deploying in rural markets at 3500 MHz.
76. The 3500 MHz band represents a significant opportunity to facilitate connecting Canadian businesses and citizens to high speed wireless Internet services. A rare occasion exists to develop a new band plan for the 3500 MHz spectrum in a way that maximises the use of this valuable and finite resource.
77. IWP urges Industry Canada to carefully consider the comments and proposals made in this submission and we thank the Department for the opportunity to respond to this important issue.
18 Policy and Licensing Procedures for the Auction of Additional PCS Spectrum in the 2 GHz Frequency Range. June 2000. Appendix 2, Section 7.4https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/10.1e.pdf/$FILE/10.1e.pdf.
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Appendix 1
Interference issues at 3500 MHz
Interference at 3500 MHz can be a substantial issue. Most operators try to maximize coverage by minimizing the number of sites required. This can result in tower heights of 80-100 meters. Operators typically want to serve as many customers as possible and will run coverage out to the cell edge (typically -90 dbm to -100dbm received signal strength).
Operation with TDD systems becomes more complicated than traditional FDD systems when it comes to managing interference. Because most operation at 3500 MHz is TDD (transmitting and receiving on the same frequency), a base station is listening to and receiving from CPEs—the noise floor that the base station sees is important to ensure adequate performance. The design is generally uplink limited.
If an adjacent Tier less than 40 km away from the Tier edge of another operator’s site in an adjacent Tier is radiating on the same channel (co-channel), it can create substantial interference into the base station of the first site. The interference can be mutual.
There are many factors influencing the degree to which interference is a problem, including the amount of spectrum available to re-tune to and incompatible technologies.
IWP has seen interference as far away as 80-90 km on certain line of sight ‘LOS’ paths, and typically as far as 40 km. This means that in order to assure no degradations, distances must be beyond 80 km between base stations if they are co-channel. IWP understands that other operators may be recommending distances of up to 120 km.
Incompatible technologies might also require guard bands which further reduces spectrum efficiency. In paragraph 49 an example of Kingston to Napanee is cited. In fact this was a real case and the interference was significant and only solvable by utilizing separate spectrum on the sectors facing each other. In this case IWP had sufficient spectrum to solve the issue but it means that that a channel block is not being used resulting in spectrum inefficiencies.
A grid-cell based FCFS licensee in southwestern Ontario had a similar problem. It was further compounded by limited or no frequency agility in their equipment and it being FDD while IWP was using TDD. Again the only way to solve the issue was to utilize separate spectrum blocks.
23
Some interference mitigation between operators with TDD can be achieved by offsetting the timing of the sub-carriers but this requires careful analysis and is both complex and requires a fair degree of sophistication and experience. This is further complicated if the operator has deployed across multiple Tiers (i.e. a wide area).It may not be possible to have different timing on different sites.
Most operators who are covering wide areas want, to the maximum extent possible, to utilize the same frequency blocks across their coverage areas. This allows them to better manage their own self-interference without worrying about coordination with another operator or operators.
24
Appendix 2
IWP shows above one such potential band plan that encompasses the range 3400-3700 MHz. We believe that any new band plan for Canada must encompass the entire range and reflect the technology evolution that is occurring in the 3500 MHz band in general. It is for these reasons and because of interference management that IWP believes that channel block sizes should be based on 20 MHz rather than 10 MHz.
The band plan above also shows where the alignment with the potential U.S. band plan may occur, no matter which licensing regime they finally adopt. This requires 2- 10 MHz slots which we shown at the bottom of the band—i.e. 3400-3410 MHz and at the edge of band 42 3590-3600 MHz.
The portion of 3400-3475 MHz might require certain geographic exclusion zones to accommodate and protect radio location services but in general this portion of the band can be used in the majority of Canada with little issue.
While the ITU WRC-15 will not be completed until late 2015, IWP believes a discussion should commence now on the future band plan options. It is unclear if there is enough support globally for an FDD allocation (Band 22) at this time and in any case most equipment vendors would only proceed to provide FDD equipment if there was sufficient demand globally, not something that IWP would expect Canada to drive.
25
Chathem lnternet
www. craccess. com
September 29,2OL4
Senior Director Spectrum Development and Operations lndustry Canada 300 Slater Street (JETN, 15th) Ottawa, Ontario KlA OH5
RE: Canada Gazette, Part l, August 19,2OL4, Notice No. DGSO-003-14, Consultation on Policy Changes in the 3500 MHz Band (3475-3650) and a new licensing Process in RuralAreas
Chatham lnternet Access appreciates the opportunity to provide comments on the Policy Changes for 3500MHz Licences.
We are pleased to be able to offer our opinions regarding the renewal of spectrum licences and work with lndustry Canada to assist in developing the wireless service provider industry in Canada.
Sincerely,
Wally Romansky
President
162 Queen Street, P.O. Box775, Chatham, Ontario N7M 5L1 Phone: (519) 358-INET(463S). Fax: (519) 352-2095 Comments of Chatham Internet Access
About CHATHAM INTERNET ACCESS (CIACCESS)
L CIACCESS is one of the companies that is part of the MC Group of Companies. The companies in this group include:
¡ MC Business Solutions ¡ MicroAge ¡ Chatham lnternet Access (C|ACCESS) . Express Copies and Printing ¡ Standard Leasing Ltd.
The MC Group of Companies provide business products and services in the Municipality of Chatham- Kent as well as Lambton and Essex Counties. Together, the MC Group of Companies employs 70 persons and operates out of five offices.
2. CIACCESS was founded in 1995 with the goal of providing Business lnternet services to our current customers.
3. ln 2001, prior to DSL being available in our trading area, we rented space on the Municipality Water Towers and deployed wireless equipment to provide our business customers with High Speed lnternet Access. This was very successful and our customers appreciated the 10Mbps, Up and Down service that our wireless system provided.
4. ln2OO4, we participated in the 2300/3500MH2 auction acquiring blocks in Chatham-Kent (4089d), Wallaceburg (409ld), and Sarnia (a092w).
5. CIACCESS was awarded a grant under the BRAND program in2OO4, which helped launch our airNET service providing high speed lnternet service to the rural areas of Chatham-Kent, Wallaceburg, and Sarnia in 2004. This service was very well received in those areas and our customer base quickly expanded, enabling us to serve 98/o of the Municipality of Chatham-Kent and 50% of Lambton County.
6. ln 2009, CIACCESS was awarded a CONNECTING RURAL CANADIANS grant to assist in launching our WiMAX based wireless service - airNET MAX. airNET MAX is now available in all of Chatham-Kent and Southern Lambton County. Challenges
7. One of the challenges in our wireless business is keeping up with new technology and the speed demands that our customers require. ln order to increase speeds on our airNET MAX system, we require more spectrum. While we are adding sectors to increase speed, we have nearly exhausted the available spectrum in ourallotted 3.5GHz blocks. With each newsectorthatwe install, we must be very careful not to interfere with one of our other towers.
8. I have talked with and written letters to lndustry Canada numerous t¡mes to make them aware of this spectrum requirement issue. We have been hoping to acquire more spectrum, especially due to the fact that none ofthe other providers who bought spectrum in the 2004 auction have ever deployed a single base station in the 3.5GHz range in our Tiers during the first 9.5 years of their 10 year licence.
9. Starting in 2009 we contacted allspectrum holders who held unused spectrum in ourTiers ín regards to spectrum acquisition and we were not successful as not one would give their spectrum up.
10. While lndustry Canada allowed those spectrum holders to sit on spectrum, the result was that we were unable to either install more sectors or to turn up the radios to the highest speeds. Our customers in Chatham-Kent and Wallaceburg have been suffering with slower speeds because of CIACCESS's inability to acquire more spectrum.
CIACCESS Responses to lndustry Canada Questions
Question 7: lndustry Conada invites comments on its proposol to clossily Tier 4 seruice areas os either urban or rurol for the bond 3475-3650 MHz, using Stotitrcs Canodo's 2O77 definition þr populøtion centres, os outlined in Annex A.
We do not agree with the urban vs rural approach. We license 3.5 GHz spectrum for Tiers 4-089 and 4- 090 (Chatham and Wallaceburg). These areas are approximately the same size and have about the same percentage of rural residents.
The only difference is that the Chatham Tier includes the city of Chatham proper where the population exceeds 30,000 and would now be designated "urban". These City of Chatham residents have an abundance of lnternet opt¡ons available to them - DSL, Cable, Mobile Wireless, and Fixed Wireless. The rural population have two options - Fixed Wireless and Mobile Wireless. Most Fixed Wireless services are very economical while Mobile Wireless is very expensive for any user that uses over 5GB of data monthly. For this reason, mobile wireless has really been a last resort for most rural users.
We have spent the last 10 years investing millions of dollars in infrastructure to deliver an economical and quality service to these rural customers. This proposal has the potential to take it away from these customers because these rural customers live in a designated 'urban' tier. The proposals make no consideration that we see for these licence holders to keep their licences if a commercial wireless provider wants it in this 'urban' rural area. This would be catastrophic to our business and a hardship for all of the rural businesses and residences that we serve in the newly designated "urban" area.
The proposed Tier4 licensing process for 'urban' areas would be in contradiction with the stated goals of lndustry Canada's Digital Canada 150 Policy that all citizens - including those in low density areas, have at least 5Mbps broadband service.
As well, lndustry Canada has invested in rural lnternet services through the BRAND and CONNECTING RURAL CANADIANS initiatives. Now with re-allocation in designated "urban" rural areas you have the potential to render that investment useless.
For these reasons we disagree with the urban versus rural designations for small communities. All smaller communities have a rural component that require the same service levels as what is available in urban areas.
CIACCESS Responses to Industry Canada Questions
Question 2: lndustry Cønøda invites comments on its proposøl to moke available spectrum Iicences in tier oreos classìfted os rural, through a firct-come,lirct serued prccess.
We believe that the first lSPs who should have access to this spectrum are the EARLY DEPLOYERS. This seems to have been a group on companies who have been overlooked in this Consultation.
These EARLY DEPLOYERS are the companies who licensed the spectrum in 2004 (or later), ¡nvested a large amount of capital into towers and infrastructure in order to provide services to the rural customers in our Tiers.
There are many lSPs like us who have been limited as to how many base stations could be built and how many customers could be served. This is because the 50MHz of spectrum that we use has been exhausted due to its extensive deployment. Add to that the increased usage per subscriber and it has caused extensive congestion across our networks. We have an urgent need to add more spectrum and infrastructure in order to increase speeds and serve the area properly. ln our t¡ers we were the only service provider to deploy in the first 9.5 years of the licence. lnukshuk deployedasinglebasestationineachofthetiers. Thiswasrequiredinordertomeettheconditionof "use it or lose if'. They only did this at the last minute and only to minimally meet the condition of the licence.
The EARLY DEPLOYERS should have first access to spectrum in the 3.5GHz range in order to upgrade the systems to current standards. lf we were able to double the spectrum we have, we could essentially double the speeds across all of our network, bringing them up to current standards.
Once the EARLY DEPLOYERS are taken care of, then we agree with the rural areas using a first-come, first served process.
CIACCESS Responses to Industry Canada Questions
Question 3: lndustry Cønado invites comments on these licences being issued os onnuol spectrum licences, deftned on o grid+ell basis and outhorized only þr the amount ol spectrum required to operate (refer to Secfîon 7.3).
The grid-cell proposal can create cells that are much too small compared to the propagation distances of Fixed Wireless systems. ln smaller cities, coverage is provided by most rural systems just because they neighbor the rural area that is being covered. lt would be impossible to have an urban and rural provider trying to use the same spectrum in these smaller areas.
We recommend that Fixed Wireless Operators who have met their deployment requirements be offered a ten-year licence renewal for rural Tier- areas. This will help to foster additional ¡nvestment into infrastructure to meet the growing demands of the rural customers.
Annual renewals offer little guarantee of spectrum in the future and will stifle investments into infrastructure to serve the rural areas.
Question 4: Industry Conada invites comments on its proposol to modify the cu¡rent not¡licotîon period þr existing point-to-poÍnt, fixed støtions such thot those olfecting the implementation of new FWA systems in ru¡ol Tier 4 areas would now be allorded ø notificotion period of six months.
No comment. Question 5: lndustry Canodo invites comments on its proposal to hove the tronsition policy described in sedion 4 ol Annex B apply to all FWA systems (i.e. existing FCFS and the ouctioned FWA systems os listed in (v) and (vi) within ruml tierc.
lf Displacement means moving out of the 3.5GHz band that means that we would have to replace all base stations and customer radios. This is simply not acceptable - it is cost prohibitive and would devastate our business as75To of our revenue come from these customers.
Our demise would not be the only result. There would also be 2,000 customers who would have to change providers - with the majority having to go to cellular based, which are very expensive contracts. The idea of using lnternet for video services like Netflix or YouTube would be a thing of the past - simply cost proh¡b¡t¡ve. lf Displacement means moving into a different 3.5GHz band because of a new band plan that is acceptable. However it would take extensive work and co-ordination with other providers to ensure a seamless trans¡t¡on. The only other band that might work without an equipment change is 3400-3500.
This spectrum that you propose to transition is very heavily used spectrum by those who have deployed. We deliver a high-quality lnternet service to over 2,000 customers using that spectrum.
Once again, you need to accommodate all DEPLOYERS of this frequency, by letting them continue to use it per their licence agreement. The investment we have made in our tiers is very large - towers, base stations, fibre contracts, customer radios and other components of infrastructure.
We recommend that the total Fixed Wireless Spectrum capacity should not be reduced from the current 175MHz. This spectrum is required for Fixed Wireless operators to increase coverage and speeds and should be contained in one contiguous block.
Given that the Government has been making supporting statements about expanding rural broadband access, we are floored by the notion that you would propose someth¡ng that would cut off service to thousands of customers in our tiers alone, and hundreds of thousands across Canada. Your proposals have the potential to cause irreparable harm to the wireless provider industry in Canada.
Questìon 6: lndustry Conoda invites comments on the conditions ol licence in Annex B.
We agree with Annex B with two exceptions: Displacement to a different band: This simply is not an appropriate opt¡on. Rendering hundreds of millions of dollars of infrastructure unusable and cutting off lnternet service to hundreds of thousands of lnternet users makes absolutely no sense. lt would destroy businesses and put thousands of employees out of work.
This displacement cannot be an option in our Tiers. We would choose to close our doors rather than to re-investagainonanannual licenceschemeinanewband. Justthepossibilityofthisalonewillstopall investment into rural infrastructure at this time.
A one-year term is not feasible to foster investment into rural wireless systems. A ten-year term is the correct choice so that the wireless providers can plan and deploy rural wireless systems with a guarantee that it will not be displaced.
Question 7: lndustry Cønodo invites comments on its proposol to lundamentolly reollocate the 35ü) MHz band (3475-3650 MHz) to ìnclude mobìle seruices and its proposed changes to the Canadion Toble ol Frequency Allocotions as þund in Annex C.
We agree with the reallocation as long as current Fixed Wireless Providers can keep the spectrum they are currently using and have first access to additional spectrum to provide their customers services that are comparable to urban areas.
The deployment of mobile services should not come at the expense of rural users who need it for their essential lnternet service.
Most spectrum holders have been sitting on the sidelines-sitt¡ng on valuable spectrum-for ten years, keeping itoutof the handsof the more progressive ruralwireless providers'handsthat have launched using the best available equipment. We believe that the extensions that have been granted in the past have not served the rural Canadian population very well and those customers will once again be relegated to second rate service options if this re-allocat¡on takes place.
Question 8: lndustry Canodo invites comments on its geographìcally dilferentiøted poliry whe¡e mobile seruices will be allowed in urbon tierc, and fixed seruices will be ollowed in ¡u¡al tierc (refer to Sedion 6lor the definition of urbon and ru¡ol tierc.
ln general, we disagree with the urban versus rural designation approach. The urban Tiers in our area have a lot more rural land area than the urban area - approximately 98%. These rural users in urban designations have the exact same requirements as the rural users in rural designations and should have the same opportun¡ties for fixed wireless lnternet. Tier 4 areas are too large to be designated urban when in many Tiers there are as many or more rural residents than urban.
There is no reason to call the Chatham Tier "urban" when there are almost as many rural users who have very little choice when it comes to lnternet providers. By displacing our spectrum and giving the spectrum to mobile wireless, you are taking away service for thousands of users in the rural areas.
Question 9: lndustry Canodø invìtes comments on itstwo proposed optionsþr displacement.
DISPI.ACEMENT TO A NEW BAND IS NOT AN OPTION _ THIS IS NOT UNUSED SPECTRUM.
We believe that the obligation to the spectrum holder should be that the spectrum be used as it was originally intended - i.e. for Broadband Wireless Access for the rural communities. lf a spectrum holder was not able to deploy that access in a reasonable amount of time (and I believe that 10 years has been more than reasonable), that spectrum should be made available to the spectrum holders that need ¡t to expand or improve their current Broadband service offerings in the rural areas. lf no Fixed Wireless Operators want the spectrum, then and only then, should it be made available to the Mobile Wireless Providers.
We believe that the extens¡ons which have been granted in the past, have not served the rural Canadian population very well. Those rural customers will once again be neglected if any type of displacement to a new band comes into effect. lf you take away th¡s spectrum, you take away service for hundreds of thousands of rural Canadians and most likely bankrupt some wireless providers who have invested heavily in towers and wireless infrastructure. This would also jeopardize the employment of the workers in the Wireless Service Providers who are serving these rural areas. lndustry Canada should be looking at ways to nurture this rural wireless lndustry instead of proposing ideas that have the potential to put a lot of smaller providers out of business and hand that business over to larger mobile providers who are mostly interested in providing mobile service in the urban areas.
Conclusion
Over the last ten years, it has been apparent that many providers are reluctant to provide wireless broadband infrastructure to the rural areas. At the same time, many wireless lnternet providers have made investments in serving those areas. We believe your decisions should be based on the ability to give these rural lnternet users services that are similar to the services available in urban areas. Many licence holders have had 10 years to deploy those services, yet they have come up short. Your decision should first address the needs of the current providers who have already deployed. This seems to have been a group that have been largely ignored in this consultation. To many of us it seems that you place little value on our businesses and the services that we provide to a very large rural community in Canada. Yet these are the same providers who are investing in their communities and are able provide the services to their rural communities.
There will be tremendous financial hardships if there are displacements out of this band. As well, if current operators are not taken care of in this spectrum allocation process, the current infrastructure that is installed will continue to be congested, providing rural residents less speeds than their urban counterpa rts.
Chatham lnternet Access thanks lndustry Canada for allowing our opinions to be heard through this consultation process.
** End of Document ** Russ Friesen Vice President, Regulatory Vice-président des Affaires réglementaires MTS Allstream
8 October 2014 by Email
Mr. Peter Hill Director General Spectrum Management Operations Branch Industry Canada 300 Slater St. Ottawa, ON K1A 0C8 E-mail: [email protected]
Dear Mr. HIll:
Subject: 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 – MTS comments
1. Pursuant to the procedure set out in 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 (Notice DGSO-003-14), published 6 September 2014, MTS Inc. (MTS) provides the following comments.
2. In DGSO-003-14, Industry Canada (IC) has proposed a number of policy changes to the management of 3475-3650 MHz spectrum (the 3500 MHz band) in order to better address the changing demands for both fixed and mobile services. Specifically, IC has proposed a new classification of Tier 4 areas to differentiate between urban and rural areas, new licensing processes for fixed wireless access, allocation of some 3500 MHz spectrum to mobile services, and a transition policy.
3. MTS is supportive of the broad direction IC has proposed. Demand for mobile spectrum continues to grow. However, MTS understands and acknowledges that in rural areas, fixed wireless services using 3500 MHz spectrum is also important. MTS believes IC has struck an appropriate balance to enable both to coexist.
4. With regards to IC’s specific questions:
P.O. Box 6666, MP19C, 333 Main Street, Winnipeg, MB R3C 3V6 Tel: (613) 688-8789 Fax: (613) 688-8303 email: [email protected] Suite 1400, 45 O’Connor Street, Ottawa, Ontario K1P 1A4 Tel: (613) 688-8789 Fax: (613) 688-8303 email: [email protected] Mr. Peter Hill 8 October 2014 Page 2 of 6
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.
5. MTS supports IC’s proposal to classify Tier 4 service areas as urban and rural to meet the objectives of allocation towards mobile and fixed wireless services. However, MTS recommends consideration of expanded means to define Tier 4 areas for such services.
6. In DGSO-003-14, IC has essentially designated areas of high density demand as those that have the greatest need for spectrum for mobile services and thus proposed that 3500 MHz spectrum be made available for mobile services in larger urban centres. MTS suggests however, that major traffic routes, i.e. highways, are also key drivers of mobile services demand and geographic contiguity along these routes is also important.
7. The benefit of IC’s broad proposal is it allows flexibility to address this issue - it allows flexibility in the interaction between mobile and fixed wireless services. In DGSO-003-14 question 9, IC asks interested parties their suggestions on options on how the two could interact. Under Option 2, displacement of existing fixed wireless licensees may have to occur, but only if required.
8. If chosen, IC’s Option 2 could allow greater definition of designated Tier 4 areas for mobile services. Tier 4 areas could be designated where population may not live (i.e. urban centres) but where they travel.
9. For example, under the current proposed population definition, in Manitoba, only Winnipeg and Brandon would be designated as “urban” Tier 4 licence areas allowing the use of 3500 MHz spectrum for mobile services (Figure 1)
Mr. Peter Hill 8 October 2014 Page 3 of 6
Figure 1
10. MTS submits however, that three other Tier 4 areas (4-110, 4-113 and 4-115) will also have regions of significant demand (Figure 2). Traffic patterns and economic activity in these areas are denser and contiguity of service is beneficial.
Figure 2
Mr. Peter Hill 8 October 2014 Page 4 of 6
11. MTS recommends IC allow itself greater flexibility to receive applications to designate other Tier 4 areas for mobile services. In doing so, IC can enhance the availability and reliability of service.
12. In each designated area, whether it is specially designated or simply designated as “urban”, IC’s can continue to enable the co-existence of fixed wireless services. Mobile service development in these Tier 4 areas may be concentrated in urban and other high- density traffic areas. The remaining geography of the Tier 4 areas can maintain their fixed wireless services. Displacement need occur only as required.
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.
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).
13. MTS supports these proposals.
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.
14. MTS supports this 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.
15. MTS supports this proposal.
Mr. Peter Hill 8 October 2014 Page 5 of 6
6. Industry Canada invites comments on the conditions of licence in Annex B.
16. MTS has no objections to IC’s proposed conditions of license.
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).
17. MTS broadly supports IC’s proposals to align the 3500 MHz band to the 3GPP standard. As noted in response to Question 1, MTS recommends IC also allow itself greater flexibility to receive applications to designate other Tier 4 areas for mobile services. In doing so, IC can enhance the availability and reliability of service.
18. Using Option 2 in Question 9, IC can continue to enable the co-existence of mobile and fixed wireless services.
9. Industry Canada invites comments on its two proposed options for displacement.
19. MTS expresses its support for Option 2 - Displacement of existing licensees in urban tiers only if, and as required, after commercial mobile licences are issued. Licensees would have one year to transition once notified by the Department.
20. Manitoba has a greater proportion of rural population relative to many other provinces and fixed wireless services are important. Many urban designated Tier 4 areas will continue to have rural areas that will have lower demand for mobile wireless spectrum. Option 1 would needlessly reject some fixed wireless providers from using 3500 Mhz spectrum. This would not be efficient.
Mr. Peter Hill 8 October 2014 Page 6 of 6
21. Option 2 allows flexibility to displace fixed wireless providers only as required. While this may delay some implementation of mobile services, this can be managed. Option 2 also allows IC greater flexibility to designate other Tier 4 areas for mobile services.
Yours truly,
for Russ Friesen Vice President, Regulatory Affairs c.c.: Justin To, MTS Allstream, [email protected]
* * * End of Document * * *