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Before the DEPARTMENT of ENERGY Washington, DC 20585 In Before the DEPARTMENT OF ENERGY Washington, DC 20585 In the Matter of National Broadband Plan (NBP) RFI: Communications Requirements COMMENTS OF QUALCOMM INCORPORATED Dean R. Brenner Vice President, Government Affairs John W. Kuzin Senior Director, Regulatory 1730 Pennsylvania Avenue, NW Suite 850 Washington, DC 20006 (202) 263-0020 Dated: July 12, 2010 SUMMARY Qualcomm is pleased to provide these detailed comments to the Department of Energy (“DOE” or “Department”) on how current and future wireless broadband communications capabilities can support the energy management needs of electric utilities, businesses, and consumers, which include requirements for the evolving and growing Smart Grid. The DOE should be applauded for timely following-up on the recommendations in the Federal Communications Commission’s National Broadband Plan (“NBP”) that focus on how broadband communications systems can achieve the critically important U.S. goals of energy independence and enhanced energy efficiency. See FCC NBP at 247. In this regard, Qualcomm explains how commercial wireless technologies can be used to satisfy the varied and increasing communications needs of electric utilities. Qualcomm looks forward to continuing a dialogue with the DOE and its industry partners on these important issues as Smart Grid technologies are further integrated into our electrical networks. For more than two decades, Qualcomm has enabled the introduction of countless wireless technologies and products that are used by many utilities to support the smart delivery and consumption of energy. Qualcomm believes that these technologies also will enable the swift, broad, and cost-effective implementation of the Smart Grid. Indeed, as the DOE appreciates, Smart Grid communications must benefit businesses, consumers, and utilities alike by transporting the information required to wisely manage energy use. Commercial cellular technologies, which currently provide mobile broadband service to approximately 98% of all Americans, must play a key role in the continued development of the Smart Grid to fully realize the goals of the FCC’s NBP – which are appropriately echoed in the DOE’s RFI – namely (i) improved reliability and power quality; (ii) reduction in peak demand and in transmission congestion costs; (iii) increased energy efficiency; (iv) greater environmental benefits through increased asset utilization; (v) increased security; (vi) greater ability to accommodate more renewable energy, and (vii) increased durability and ease of repair in response to attacks and natural disasters. See 75 Fed. Reg 26206, 26207. Qualcomm explains in these Comments the vital role that existing commercial cellular technologies, and the enhancements to these technologies that are being rapidly developed and deployed, can play in supporting the communications requirements of the Smart Grid. Many key Smart Grid applications can take full advantage today of the enormous sunk and ongoing investments in commercial cellular technology: from automated meter reading to demand response (i.e., the ability of the customer to alter energy usage through remote control of customer equipment based on, for example, time of use and critical peak pricing) to remote connects and disconnects of electric power to remote fault detection and isolation to net metering (i.e., the means of monitoring energy from a customer’s solar panel system or wind farm back to the utility grid). To launch the Smart Grid broadly and rapidly, it will be far more cost-effective to take advantage of the substantial economies of scale and other benefits of cellular technology already in heavy use throughout America. There is no other available broadband communications technology that can meet the unique combination of requirements for the Smart Grid, including reliability, security, full coverage, and global harmonization and interoperability, other than today’s cellular technology. Cellular technology offers highly attractive economies of scale as the underlying equipment is available from a wide array of vendors at very low costs. Cellular technology can be used to meet the broadband needs of Smart Grid applications in two ways. First, existing commercial cellular networks can be used, thereby taking advantage -ii- of the massive investments the wireless carriers have made and will continue to make. These virtually ubiquitous networks deliver high speed, low latency mobile broadband service where the overwhelming majority of Americans live, work, and travel, and these networks are constantly being expanded and upgraded. Second, if a particular utility determines that, notwithstanding the tremendous past, present, and future network investments by commercial cellular carriers, those networks will not meet their own requirements for reliability, coverage, performance, and security, they can acquire spectrum rights and build their own cellular wireless networks. In fact, commercial cellular carriers are expanding their coverage every day. Also, to reach areas that would be unduly expensive to cover with terrestrial mobile broadband, Qualcomm has developed satellite-based mobile broadband technology, which will be integrated into the same wireless chipsets that support terrestrial mobile broadband. Mass-market, hybrid satellite-terrestrial devices using these chipsets will enable access to mobile broadband anywhere within the U.S. This satellite-based mobile broadband technology can be used to fill coverage holes in terrestrial mobile broadband networks. The result will be truly ubiquitous high speed wireless broadband coverage across the U.S., which may be necessary to cover the countless devices that are expected to access the Smart Grid, including those that will support the increased need for renewable energy and storage. Beyond developing technology for universal mobile broadband coverage, Qualcomm is working to enable the use of mobile broadband for the Smart Grid in other ways. For example, several companies produce 3G-based modules using chips supplied by Qualcomm CDMA Technologies (“QCT”), the world’s largest supplier of chips for wireless devices. These modules are very small in size and are embedded in computers, into dongles attached to -iii- computers and other consumer devices, and a variety of machines and equipment to provide high speed wireless broadband connectivity for Smart Grid applications, among other uses. In addition, QCT’s Gobi module provides multi-mode mobile broadband connectivity so it can be used on any commercial 3G mobile broadband network. In this way, Gobi would permit a utility to use multiple 3G network technologies for Smart Grid applications and allow the provider to choose the most cost-effective 3G network in any given area. Gobi is particularly well-suited for several highly prevalent Smart Grid applications: (i) automated meter reading, particularly at the “concentrator” level, where the data aggregated from hundreds of homes are collected and transmitted to the utility; (ii) demand response systems, and (iii) remote fault detection and isolation. Another QCT module, known as inGeo, uses Assisted GPS and wireless connectivity to report position location data from a very small, extremely low-power device. inGeo also allows for the simple integration of sensors that, for example, can measure pressure and temperature and report those readings back to a utility’s network control center in near real time. This capability is perfect for remote monitoring, sensing, and control systems that support Smart Grid reliability improvements and limit the need for expensive site visits to remote sites. Qualcomm hopes that the DOE will find this submission helpful as it reviews the current and projected communications requirements for sustaining and modernizing our power grid. As summarized above and as detailed herein, cellular technology should continue to serve an essential role in supporting the communications needs of our nation’s 21st century power grid. -iv- TABLE OF CONTENTS SUMMARY ..................................................................................................................................... i I. Cellular Communications Technology And Networks Are Essential To The Successful Deployment Of The Smart Grid ........................................................................2 A. Overview of Qualcomm’s Role In The Development Of Cellular Technology ......2 B. Cellular Technology Is Continually Being Upgraded to Deliver Faster Data Rates, Lower Latency, and Greater Capacity .....................................................................6 1. Faster Data Rates ........................................................................................ 6 2. Wider Coverage .......................................................................................... 7 3. Lower Latency ............................................................................................ 8 4. Expanded Capacity/Improved Performance ............................................... 8 5. Support for Full Mobility ............................................................................ 9 6. Security & Reliability ................................................................................. 9 C. Mobile Broadband Chipsets & Modules for Smart Grid Applications..................10 1. Gobi Solution for the Widest Possible Connectivity ................................ 10 2. inGeo Solution for Wireless Monitoring & Tracking ............................... 11 D. Cellular Technology Is Being
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