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Rogers.Com O 416.935.7009 M 416.371.6708 Howard Slawner 350 Bloor Street East, 6th Floor Toronto, ON M4W 0A1 [email protected] o 416.935.7009 m 416.371.6708 August 10, 2018 Via email: [email protected] Aline Chevrier Senior Director, Spectrum Licensing and Auction Operations Innovation, Science and Economic Development Canada 235 Queen Street, 6th floor Ottawa, Ontario K1A 0H5 Re: Canada Gazette Notice No. SLPB-004-18: Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band Please find the reply comments of Rogers Communications Canada Inc. (Rogers) in response to Canada Gazette, Part I, June 16, 2018, Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (SLPB-004-18). Rogers thanks the Department for the opportunity to provide input on this important issue. Yours very truly, Howard Slawner Vice President – Regulatory Telecom HS/pg Attach. Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band SLPB‐004‐18 Reply Comments of Rogers Communications Canada Inc. August 10, 2018 Rogers Communications Consultation on Revisions to the 3500 MHz Band to August 10, 2018 Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (SLPB-004-18) Table of Contents Page Executive Summary 2 Introduction 4 Rogers’ Reply Comments of Other Parties Q1 Timelines for 5G ecosystems for 3500 MHz & 3800 MHz bands 4 Q2 Changes to Canadian Table of Frequency Allocations 6 Q3 Flexible Use in 3450–3475 MHz band 7 Q4 Spectrum Sharing in 3400–3450 MHz band 8 Q5 ISED proposals for existing Spectrum Licensees 10 Q6 Alternative proposals for existing Spectrum Licensees 16 Q7 Revised Band Plan in 3450–3650 MHz frequency range 20 Q8 Measures to limit Interference with proposed TDD band plan 21 Q9 Aligning issuance of Flexible Use Licences between Incumbents 22 and Future Licensing Process Q10 Importance of Price Discovery in Licensing Process 24 Q11 Protection and Notification provisions for Incumbent Licensees 25 Q12 Alternative Transition plans, or variations to Times proposed 26 Q13 Intermittent Interference, including cross-border, within 3450– 27 3650 MHz band Q14 Optimizing use of 3650–3700 MHz band 28 Q15 Importance of 3700–4200 MHz band to future FSS operations 31 Q16 Registration of Unlicensed Operators in 3700–4200 MHz band 33 to assist in Frequency Management Q17 Optimizing usage of 3700–4200 MHz band between Current 34 Services and Developing Technologies to provide New Services Q18 Challenges and Considerations related to Coexistence of Mobile 36 and/or Fixed Wireless Access in 3700–4200 MHz band Page 1 of 38 Rogers Communications Consultation on Revisions to the 3500 MHz Band to August 10, 2018 Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (SLPB-004-18) Executive Summary E1. The consultation record shows that stakeholders see the 3500 MHz and 3800 MHz spectrum bands as a critical input for satisfying the growth in terrestrial demand for advanced connectivity services in Canada. It is also clear that these stakeholders see the spectrum in the broader 3300-4200 MHz range as a key global pioneer band for enabling the deployment of 5th generation (5G) wireless technology, both mobile and fixed wireless. This spectrum will support the deployment of advanced next-generation wireless technologies by terrestrial facilities-based operators, with the arrival of 5G technology having the potential to revolutionize how we work, study and play. Rogers continues to invest heavily in advanced wireless telecommunications networks across Canada and requires access to both our current and additional spectrum. The Department should take all necessary steps to accelerate the release of 3500 MHz and 3800 MHz spectrum – and other 5G bands – while ensuring incumbent 3500 MHz licensees, who have met all their licence conditions, are able to retain their spectrum in line with past decisions. E2. No alternative proposal is superior to Innovation, Science and Economic Development Canada taking steps to make 300 MHz of exclusively, licensed spectrum available through this consultation. An initial 300 MHz will provide multiple network operators access to the big blocks of spectrum necessary to deliver the benefits of 5G to Canadian consumers and business. Only by providing facilities- based operators with sufficient amounts of the spectrum they need to power their networks will all Canadians truly benefit from the innovative consumer and industrial services that 5G can deliver. Making 300 MHz of spectrum immediately available is, thus, critical for the continuation of existing services, competition in the wireless market, and availability of new 5G services for Canadians. E3. The Department should also move quickly to release additional spectrum in future extensions of the band, expanding the band up to 4200 MHz. Satellite operators provide no evidence of demand for C-band services outside of the Far North and remote areas of Canada. The Department should immediately transition satellite operations out of at least 3700-3750 MHz. It should further initiate clearing satellite operations from the entire 3700-4200 MHz range as soon as practical for the southern parts of Canada, and everywhere that alternatives to satellite services in this band are widely and economically available. E4. Incumbent 3500 MHz licensees that have fully met their licence conditions should retain two-thirds of their spectrum based on the Department’s own 2500 MHz precedent and in recognition of incumbents having invested hundreds of millions of dollars in the face of ongoing and significant technology uncertainty. A two-thirds Page 2 of 38 Rogers Communications Consultation on Revisions to the 3500 MHz Band to August 10, 2018 Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (SLPB-004-18) retention of 3500 MHz licences is both justified and good policy, and it is the best option for delivering 5G services to all Canadians. Clawing back unjustified amounts of deployed spectrum to simply auction it back to providers will reduce the capital available for new network deployments, investments that ensure all Canadians can benefit from 5G services. E5. In order to achieve the large, contiguous bandwidth necessary that network operators require to ensure Canadians to fully benefit from all the innovations and performance that 5G networks can deliver, new blocks auctioned in the future extension bands should automatically be assigned contiguously to the spectrum available through auction and to incumbent licensees through this consultation. The Department should include a spectrum contiguity provision in its new 3500 MHz policy and a condition of licence for the new 3500 MHz and 3800 MHz flexible use licences, requiring spectrum block exchanges whenever the band is extended. E6. The Department must seize the opportunity of the 3500 MHz consultation to foster both innovation and competition in Canada. Increasing the amount of spectrum immediately available to facilities-based operators through this consultation to 300 MHz, moving to rapidly expand the band upwards to as high as 4200 MHz, and implementing provisions to ensure spectrum contiguity for new and incumbent licensees will help protect and promote wireless competition in Canada. These policy actions will also allow incumbent licensees to retain two-thirds of their spectrum, respecting both the Department’s own precedent and incumbents’ investments in the band. Page 3 of 38 Rogers Communications Consultation on Revisions to the 3500 MHz Band to August 10, 2018 Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (SLPB-004-18) Introduction 1. Rogers Communications Canada Inc. (Rogers) welcomes the opportunity to reply to comments filed by other parties in response to SLPB-004-18: Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band1 (the Consultation), posted on Innovation, Science and Economic Development Canada’s (ISED or the Department) website on July 16, 2018. 2. Rogers stated its position on all of the issues raised in the Consultation in its comments of July 12, 2018. This reply is limited to comments on proposals made by other parties. Failure to address any specific issue raised by other parties should not be taken by the Department as Rogers’ acquiescence with the position. Rogers’ Reply to Comments of Other Parties Q1: ISED is seeking comments on its assessment of the timelines identified for the development of an equipment ecosystem for 5G technologies in the 3500 MHz and 3800 MHz bands, and whether the timelines will be the same in both bands. 3. There is wide agreement with ISED’s assessment of the timelines for the development of an equipment ecosystem for 5G in the 3500 MHz and 3800 MHz bands. There is also wide agreement that band n78 (3300-3800 MHz) equipment will be available before widespread availability of the band n77 ecosystem (3300- 4200 MHz).2 With a robust equipment ecosystem rapidly developing, the Department must make all efforts to accelerate the regulatory timelines for all the priority 1 spectrum bands, including the 3500 MHz band and the millimetre wave (mmWave) bands. 4. Rogers agrees with Telus that the Department should aim to release a technical, licensing, and policy framework for the 3500 MHz band in mid-2019 and hold the 1 ISED, SLPB‐004‐18: Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band (Consultation); http://www.ic.gc.ca/eic/site/smt‐ gst.nsf/eng/sf11401.html. 2 Bell Comments, para 19; Telus Comments, para 16; Shaw Comments, para 38; Quebecor Comments, para 12; Cogeco Comments, para 25; SaskTel Comments, para 42‐43; ABC Communications, para 16; Seaside Wireless, pg 3; Ericsson Comments, pg 7; Huawei Comments, pg 2; Nokia Comments, pg 7; BCBA Comments, para 10.
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