Andrew Clegg NSMA Spectrum Management 2015 May 19th, 2015

Andrew Clegg NSMA Spectrum Management 2015 May 19th, 2015
3.6 GHz Overview Andrew Clegg NSMA Spectrum Management 2015 May 19th, 2015

Background

U.S. Authorizes Three-Tier Access in 3550-3700 MHz Band
Citizens Broadband Radio Service (CBRS) rules adopted April 17th, 2015 Innovative access methodology allows shared small-cell commercial access to spectrum with ongoing encumbrances by government and non-government incumbents Enacts three-tier spectrum sharing architecture under Spectrum Access System (SAS) control, as recommended by President’s Council of Advisors on Science and Technology (PCAST Report) Technology agnostic (LTE, Wi-Fi, other…)

Three-Tier Access in U.S. 3550-3700 MHz Band
Primary Federal Incumbents Incumbents (Tier 1) (protected from Tiers 2 & 3) Tier 2 & 3 initial and ongoing authorization to transmit must be granted by a Spectrum Access System (SAS) Grandfathered FSS Rx-Only Earth Stations Wireless Broadband Service ( MHz) Tier 2 (protected from Tier 3) Priority Access License Tier 3 (no protections) General Authorized Access

The 3.6 GHz Ecosystem

Allocations, Allotments, & Assignments
Band is governed by new Part 96, Citizens Broadband Radio Service (CBRS) Adds primary Fixed/Mobile (except aeronautical mobile) allocations in MHz Up to 70 MHz in MHz is allotted to Priority Access Licenses (Tier 2) General Authorized Access (GAA, Tier 3) will have access to 80 MHz or more in MHz, including unused PAL spectrum (definition of “unused” is left to 2nd FNPRM) Licenses/assignments are by census tract PAL licensee may aggregate up to four PALs per census tract No explicit limit on GAA spectrum aggregation All Tier 2 & Tier 3 activity is licensed

Allocation Table Changes
Allocation Changes Adds primary FIXED and MOBILE (except aeronautical mobile) allocations to Removes non-Fed secondary Radiolocation allocation in Adds Part 96 service rules to Removes Part 90 service rules from Old Footnote Changes Adds new US105 to (grandfathered non-Fed radiolocation) Adds new US107 to (new FSS earth stations are secondary) Mods US109 (CBRS must protect Fed radar sites at Pax River, Pensacola, and Pascagoula) Adds new US433 to (protects Fed ground radars; no protection between fixed/mobile and Fed aeronautical radar) New

Priority Access License (PAL)
Protected from GAA interference; must protect incumbents Auctioned when mutually-exclusive applications are filed License area = census tract ~74,000 census tracts in U.S., each with ~4,000 pops Three-year license term, no automatic renewal Example use cases Capacity/offload networks for established wireless service providers QoS-managed enterprise networks Utility networks Backhaul Wireless Internet Service Providers (after 5-year sunset on Part MHz operations)

General Authorized Access (GAA)
No interference protections; must protect incumbents and PALs No a priori bandwidth limit May utilize unused PAL spectrum (“unused” to be defined) Licensed by rule Example use cases Personal hot spots Small business hot spots Campus hot spots PAL offload during periods of incumbent activity interrupting PAL spectrum Unprotected capacity/offload for established wireless providers Wireless Internet Service Providers Backhaul

Category A CBSD (96.41 & 96.43) Category A corresponds to access points/femtocells/etc. 10 dB lower maximum EIRP than category B Same conducted power for Cat A and Cat B in non-rural areas, so Cat A is limited to 10 dB lower antenna gain Not allowed to utilize antennas higher than 6 m HAAT outdoors Otherwise considered Category B In MHz, may respect exclusion zones or operate pursuant to an approved ESC, but once any Category A device operates via ESC, all must (if the rule is being interpreted correctly) [96.15(a)(3)(i)]

Category B CBSD (96.41 & 96.45) Corresponds to point-to-point/point-to-multipoint type architecture Outdoor only Must be professionally installed Allowed higher EIRP in non-rural areas Non-rural conducted limits are the same, so Category B is allowed 10 dB higher antenna gain in non-rural areas compared to Category A Allowed 6 dB more conducted emission and 17 dB more EIRP than Category A in rural areas May only be authorized in MHz after an ESC is approved and commercially deployed Must provide additional information to SAS: antenna gain, beamwidth, azimuth, downtilt, and height above ground to SAS

End User Devices End User Device. A device authorized and controlled by an authorized CBSD. These devices may not be used as intermediate service links or to provide service over the frequencies listed in section to other End User Devices or CBSDs.

Environmental Sensing Capability (ESC)
Dedicated listening devices whose principal purpose is to detect incumbent radar activity Previously called “Dedicated Listening Devices” (DLDs)

Incumbent Users (96.3) The following are considered incumbent users:
A primary federal user FSS operator Grandfathered Wireless Broadband Licensee authorized to operate on a primary basis

Spectrum Access System (SAS)
One (or more) nationwide systems that asserts positive control over CBSDs in order to enforce interference management between CBSDs and incumbents, and between Tier 3 (GAA) and Tier 2 (PAL) SAS is the key enabler of the 3.6 GHz spectrum sharing ecosystem Accepts assignment requests from Tier 2 and Tier 3 devices Fulfills assignment requests based upon interference management calculations from Tiers 2 & 3 to incumbents, and between Tier 3 and Tier 2 Monitors incumbent activity and reconfigures Tiers 2 & 3 accordingly

SAS functionality Details of SAS functional requirements are TBD
FCC will hold series of workshops, similar to TVWS Different from TVWS, SAS will be more dynamic, and different SASs may give different answers, depending on capabilities Multistakeholder group established within the Wireless Innovation Forum, involving 30-some different entities, DoD, NTIA, and others, to help work out the details

CBSD Registration Data that must be Supplied to the SAS
Geographic location Antenna height above ground (in meters) CBSD class Requested status (PAL/GAA) FCC ID Call sign User contact information Air interface technology Unique manufacturer’s serial number Sensing capabilities (if supported) Indoor or outdoor (for Cat A) Additional information required for Category B registration Antenna gain Antenna beamwidth Antenna pointing azimuth Antenna downtilt

Technical Rules

Power Limits Device Geographic Area Max Conducted Power (dBm/10 MHz)
Max EIRP (dBm/10 MHz) Max Conducted PSD (dBm/MHz) End User Device All n/a 23 Category A CBSD 24 30 14 Category B CBSD Non-Rural 40 Rural 47 20

Out-of-Band Emission Limits
Limits between MHz are relative to channel edge Hard limit below 3530 Hard limit above 3720

Geolocation & Reporting
All CBSDs must be able to determine their position to ±50 m horizontal and ±3 m vertical accuracy Location of professionally-installed CBSDs may be determined to the quoted accuracy and reported to the SAS When moved, coordinates must be updated Non-professionally installed CBSDs must report its new position within 60 s when moved more than 50/3 m.

Operability All CBSDs must be capable of two-way operation on any authorized frequency assigned by a SAS Wireless Broadband Licensees, during their grandfathered period, are exempt from the requirement

General Technical Requirements
Digital modulation CBSDs and End User Devices must support and utilize transmit power control If requested, a CBSD must report to a SAS regarding received signal strength measurements on its occupied frequency and on adjacent frequencies, received packet error rates or other common metrics for itself and its End User Devices A CBSD must report which of the SAS-provided available channels or frequencies it will utilize [963.9(e)]

Receiver Performance Requirement (?)
PAL radios must accept adjacent and in-band blocking interference as high as -40 dBm in 10 MHz from other PALS and GAA [96.41(f)]

PAL/PAL and GAA/PAL Protection Limits
Signal strength at any PAL boundary from adjacent PAL or GAA may not exceed -80 dBm in 10 MHz 0 dBi gain antenna Antenna height 1.5 m AGL Affected PAL may agree to higher signal strength level at boundary

Incumbents & Band Configuration

Band Overview Incumbent Federal Radiolocation (Occasional activity, primarily in coastal areas) Incumbent FSS Rx-Only Earth Stations Priority Access License (Up to 7 10-MHz channels) General Authorized Access (At least 8 10-MHz channels) Incumbent Wireless Broadband Service 3550 3600 3650 3700 ← 3GPP LTE Band 42 3GPP LTE Band 43 →

Military Radar

Original Military Radar/Wireless Protection Zones

Federal Incumbent Exclusion Zones, 3550-3650 MHz

Federal Incumbent Exclusion Zones, 3650-3700 MHz

Exclusion Zones vs ESC 3550-3650 A No
Segment CBSD Category One or more ESC Approved? Restriction A No May be authorized by an approved SAS in geographic areas outside of exclusion zones Yes Once an ESC is approved and used by at least one SAS, Category A CBSDs may only be authorized consistent with information on federal frequency use provided to the SAS by an approved ESC B No operation allowed May only be authorized consistent with information on the presence of a signal from a federal system provided to the SAS by an approved ESC A or B May be authorized outside of 80 km exclusion zones around Pax River, Pensacola, and Pascagoula sites CBSDs may only be authorized consistent with information on the presence of a signal from a federal system provided to the SAS by an approved ESC

Fixed-satellite service earth stations

In-Band Incumbent FSS Rx-Only Earth Stations 3600-3700 MHz
150 km zones shown for illustration (presently used for coordination with Wireless Broadband Service in MHz) Coordination zones for Part 96 CBSDs to-be-determined

In-Band FSS Protection Summary
Segment FSS License Date Construction Date Protection Status Reference MHz Authorized prior to, or as the result of an application filed prior to, the effective date of the Order Within 12 months of initial authorization Primary (CBRS must protect) US107 Licensed after the effective date of the Order Any Secondary (CBRS need not protect) MHz Authorized prior to, or as the result of an application filed prior to, December 1, 2000 NG169 Authorized after December 1, 2000 Replace effective date

Adjacent Band FSS Rx-Only Earth Stations 3700-4200 MHz
25 km zones shown for illustration Coordination zones for Part 96 CBSDs to-be-determined

Wireless Broadband Service (Part 90) – WISPs, UTEs, etc.

Part 90 Wireless Broadband Services
Various licensees currently operate in MHz under Part 90 Wireless Broadband Services Wireless Internet Service Providers (WISPs) Utilities Approximately 45,800 registered sites Non-exclusive nationwide licenses License term 10 years Operation/protection requires registration of individual base/fixed stations ULS shows 2047 active licenses as of release date of R&O, each with multiple registered sites Current rules are under Part 90 subpart Z ( )

Wireless Broadband Service incumbents in 3650-3700 MHz
5 km zones shown for illustration Coordination zones for Part 96 CBSDs to-be-determined

Part 90 Wireless Broadband Services Status
Part 90 operations in MHz will be migrated to Part 96 No new Part 90 licenses issued after April 17, 2015, except: Licenses that expire between April 17, 2015, and April 17,2020, can be renewed for a term ending not later than April 17, 2020 Licenses that were issued after January 8, 2013, will be afforded protection from CBRS until April 17, 2020, regardless of expiration date Licenses that were issued on or before January 8, 2013, will be protected from CBRS until the expiration of their license term Latest date should be January 8, 2023 Number of active licenses originally granted on or before January 8, 2013 that will expire after April 17, 2020 = 804 (~39% of total) Grandfathered stations have to protect Fed and Radar consistent with the same rules as CBRS [96.21(a)]

Wireless Broadband Services Base/Fixed Grandfathered Protections
License Date Base/Fixed Registration Date Constructed, In-Service, and Fully Compliant Protections Granted from CBRS On or before January 8, 2013 On or before April 17, 2015 As of April 17, 2016 Protected as described in until end of license term (could be as late as January 8, 2023) After January 8, 2013 Protected as described in until April 17, 2020 Any After April 17, 2015 Protected within licensee’s Grandfathered Wireless Protection Zone as defined in 96.3 & 96.21

Wireless Broadband Services Mobile/Portable/Subscriber Unit Grandfathered Protections
Associated License Date Protections Granted from CBRS within Licensee’s Grandfathered Wireless Protection Zone* Licensed as of April 17, 2015, originally licensed on or before January 8, 2013 Until expiration of license (could be as late as January 8, 2023) Licensed as of April 17, 2015, originally licensed after January 8, 2013 Until April 17, 2020

Part 90 Radiolocation Licenses Grandfathered Status
License Grant Date Operating Status Licensed or applied for prior to effective date of Report & Order May continue to operate in MHz band on secondary basis for life of equipment Applied for on or after the effective date of the Report & Order Not allowed in MHz Note: Radiolocation was already secondary in MHz. They may continue to operate, and new ones licensed, in the MHz segment on a secondary basis. There are only three non-fed radiolocation licenses in the U.S. in the MHz band as of the release date of the Order.

3500-3700 MHz Band Evolution Previous New
3550 3600 3650 3700 FEDERAL RADIOLOCATION Offshore & 3 LAND SITES Radiolocation BROADBAND FSS RX-ONLY (GRANDFATHERED) Previous FEDERAL RADIOLOCATION Offshore & 3 LAND SITES Radiolocation GRANDF. BROADBAND FSS RX-ONLY (GRANDFATHERED) Grandf. Radiolocation, life of equipment fss rx-only (new) CBRS New FEDERAL RADIOLOCATION Offshore & 3 LAND SITES Radiolocation FSS RX-ONLY (GRANDFATHERED) fss rx-only (new) CBRS After 2023 (and after life of radiolocation equipment) Color Key: Federal Part 25 Part 90 Part 96 CAPS denotes primary or protected; Non-caps is secondary or not protected

2nd Further Notice of Proposed Rulemaking

General Report and Order & Second Further Notice of Proposed Rulemaking FCC 15-47 GN Docket Affects MHz Adopted April 17, 2015, released April 21, 2015 Published in Federal Register on <TBD>, 2015 (“Effective Date”) (~mid-to-late May) Comment deadline 30 days after effective date (probably around mid-to-late June) Reply comment deadline 60 days after effective date (probably around mid-to-late July) Insert dates when Order is published in FR. Also update “effective date” on other slides.

Secondary markets for PAL licenses Definition of “use” of PAL spectrum FSS protection criteria

Thanks & Questions?

Spectrum Access System Purposes and Functionality
(a) To enact and enforce all policies and procedures developed by the SAS Administrator pursuant to section (b) To determine and provide to CBSDs the permissible channels or frequencies at their location. (c) To determine and provide to CBSDs the maximum permissible transmission power level at their location. (d) To register and authenticate the identification information and location of CBSDs. (e) To retain information on, and enforce, Exclusion Zones and Protection Zones in accordance with sections and

Spectrum Access System Purposes and Functionality (cont’d)
(g) To ensure that CBSDs operate in geographic areas and within the maximum power levels required to protect federal Incumbent Users from harmful interference, consistent with the requirements of sections and (h) To ensure that CBSDs protect non-federal Incumbent Users from harmful interference, consistent with the requirements of section and (i) To protect Priority Access Licensees from interference caused by other PALs and from General Authorized Access Users consistent with section (j) To facilitate coordination between GAA users operating Category B CBSDs, consistent with section

Spectrum Access System Purposes and Functionality (cont’d)
(k) To resolve conflicting uses of the band while maintaining, as much as possible, a stable radio frequency environment. (l) To ensure secure and reliable transmission of information between the SAS and CBSDs. (m) To protect Grandfathered Wireless Broadband Licensees consistent with section , , and (n) To implement the terms of current and future international agreements as they relate to the Citizens Broadband Radio Service.

Designated SAS Administrators must:
(a) Maintain a regularly updated database that contains the information described in section (b) Establish a process for acquiring and storing in the database necessary and appropriate information from the Commission's databases, including PAL assignments, and synchronizing the database with the current Commission databases at least once a day to include newly licensed facilities or any changes to licensed facilities. (c) Establish and follow protocols and procedures to ensure compliance with the rules set forth in this part, including the SAS functions set forth in section 96.53, et seq. (d) Establish and follow protocols and procedures sufficient to ensure that all communications and interactions between the SAS, ESC, and CBSDs are accurate and secure and that unauthorized parties cannot access or alter the SAS or the information transmitted from the SAS to CBSDs.

Designated SAS Administrators must: (cont’d)
(e) Provide service for a five-year term. This term may be renewed at the Commission's discretion. (f) Respond in a timely manner to verify, correct or remove, as appropriate, data in the event that the Commission or a party brings a claim of inaccuracies in the SAS to its attention. This requirement applies only to information that the Commission requires to be stored in the SAS. (g) Securely transfer the information in the SAS, along with the IP addresses and URLs used to access the system, and a list of registered CBSDs, to another approved entity in the event it does not continue as the SAS Administrator at the end of its term. It may charge a reasonable price for such conveyance.

(h) Cooperate to develop a standardized process for coordinating operations with other SASs, avoiding any conflicting assignments, maximizing shared use of available frequencies, ensuring continuity of service to all registered CBSDs, and providing the data collected pursuant to section (i) Coordinate with other SAS Administrators including, to the extent possible, sharing information, facilitating non-interfering use by CBSDs connected to other SASs, maximizing available General Authorized Access frequencies by assigning PALs to similar channels in the same geographic regions, and other functions necessary to ensure that available spectrum is used efficiently consistent with this part. (j) Provide a means to make non-federal non-proprietary information available to the public in a reasonably accessible fashion in conformity with these rules.

(k) Ensure that the SAS shall be available at all times to immediately respond to requests from authorized Commission personnel for any and all information stored or retained by the SAS. (l) Establish and follow protocols to respond to instructions from the President of the United States, or another designated Federal government entity, issued pursuant to 47 U.S.C. 606. (m) Establish and follow protocols to comply with enforcement instructions from the Commission.

(n) Ensure that the SAS: (1) operates without any connectivity to any military or other sensitive federal database or system, except as otherwise required by this part; and (2) does not store, retain, transmit, or disclose operational information on the movement or position of any federal system or any information that reveals other operational information of any federal system that is not required by this part to effectively operate the SAS.

Incumbent Users that Receive Protection (Tier 1)
Federal primary Current and future radar FSS rx-only earth stations FSS earth stations in MHZ licensed/applied for prior to effective date of order FSS earth stations in MHz licensed/applied for prior to Dec 1, 2000 No new primary FSS will be authorized FSS must register yearly with details of configuration (pointing, gain, beam pattern, etc.) Part 90 Wireless Broadband Service stations in MHz Stations (WISPs, UTEs, etc.) will migrate to CBRS under Part 96 Protected until April 17, 2020 (generally) or as late as January 8, 2023 No new licenses after April 17, 2015 except renewals good until April 17, 2020

Incumbent Protection DLD is now Environmental Sensing Capability (ESC)
In MHz: SAS can authorize Cat A when using ESC, or, alternatively, in the absence of an ESC, can authorize Cat A outside of new NTIA exclusion zones Once one ESC has been approved, all Cat A devices can only be authorized by virtue of an ESC (still parsing the language on this…) Cat B can only be authorized using ESC In MHz: Can authorize Cat A or Cat B outside of 80 km exclusion zones surrounding three land sites until one or more ESCs are operational SAS must reconfigure CBSDs within 60 s of alert from ESC

Certifications and Approvals
Commission will designate one or more SAS Administrators to provide a nationwide service ESCs may operate only after receiving approval from FCC All equipment in band must be certified

Power Limits Device Geographic Area Max Conducted Power (dBm/10 MHz)
Max EIRP (dBm/10 MHz) Max Conducted PSD (dBm/MHz) End User Device All n/a 23 Category A CBSD 24 30 14 Category B CBSD Non-Rural 40 Rural 47 20

CBRS Power Limits

Notable Impacts to SAS & ESC Design
Clearance timescale from ESC alert to CBSD reconfig is 60 s SAS must protect tens of thousands of WISPs in the MHz band SAS Administrator must facilitate coordination among Category B GAA licensees FSS sites will inform SAS (via FCC) of technical information relevant to improved interference analysis into FSS (antenna gain, pattern, az/el, etc.) Unclarity surrounding impact on Category A authorizations once any ESC is approved SAS registration data must be publicly accessible (but obfuscated) SAS must validate user information and location SAS will have to monitor Cat A registration parameters (particularly height above average terrain) and determine whether device must be reclassified at Cat B

General Allocation Changes & Grandfathered Protections

Effects of Allocation Changes
New FSS earth stations will be secondary FSS earth stations authorized prior to effective data and constructed within 12 months of authorization are protected from CBRS Transitions MHz Part 90 operations under Part 96 Covers WISPs, UTEs, etc., in MHz ( ) Transition completed by January 8th, 2023 CBRS does not need to protect federal airborne radars in (no fed airborne radar in ), but receives no protection from fed airborne radar Non-fed radiolocation in licensed or applied for prior to effective data may continue to operate for life of equipment; no new authorizations will be made

ESC & CBSD Authorizations (3550-3650 MHz)
96.15(a)(3) For Category A CBSDs, Exclusion Zones shall be maintained along the Coastline, as shown at [NTIA Web page]. Exclusion Zones shall also be maintained around federal radiolocation sites as set forth at [same Web page].... Exclusion Zones shall be maintained and enforced until one or more ESCs are approved and used by at least one SAS… Thereafter, Exclusion Zones shall be converted to Protection Zones. (i) Category A CBSDs may be authorized by an approved SAS in geographic areas outside of Exclusion Zones before an ESC is approved (ii) Once an ESC is approved and used by at least one SAS, Category A CBSDs may only be authorized consistent with information on federal frequency use provided to the SAS by an approved ESC. (iii) Category B CBSDs may only be authorized consistent with information on the presence of a signal from a federal system provided to the SAS by an approved ESC.

ESC Deployment and Category A & B Authorizations (3650-3700 MHz)
(2) Exclusion Zones shall be maintained for an 80 km radius around the federal radiolocation sites listed in 47 CFR and 47 CFR 2.106, US 109. These Exclusion Zones shall be maintained and enforced until one or more ESCs are approved and used by at least one SAS, in accordance with section Thereafter, Exclusion Zones shall be converted to Protection Zones. (3) CBSDs may only be authorized within these Protection Zones consistent with information on the presence of a signal from a federal system provided to the SAS by an approved ESC, in accordance with section

Grandfathered Wireless Protection Zones
Incumbent protection zones surrounding base stations in the Wireless Broadband Service (WISPs, UTEs, etc.) in ULS shows 2047 active licenses as of release date of R&O, with a total of ~25,000 registered sites 96.21(a)(1) Incumbent User protections for a Grandfathered Wireless Broadband Licensee shall only apply with its Grandfathered Wireless Protection Zone. 96.3 Grandfathered Wireless Protection Zone. A geographic area and frequency range in which Grandfathered Wireless Broadband Licensees will receive protection from Citizens Broadband Radio Service transmissions and defined using methodology determined by the Wireless Telecommunications Bureau and Office of Engineering and Technology.

Auction Rules 96.29 Competitive Bidding Procedures
(c) When there are two or more accepted applications for PALs in a given License Area for a specific auction, the Commission will make available for assignment one less PAL than the total number of PALs in the License Area for which all applicants have applied, up to a maximum of seven.

60 s CBSD Reconfiguration upon ESC Alert
In MHz [96.15(a)(4)]: Within 60 seconds after the ESC communicates that it has detected a signal from a federal system in a given area, the SAS must either confirm suspension of the CBSD’s operation or its relocation to another frequency, if available. In MHz [96.15(a)(6)(b)(4)]: Within 60 seconds after the ESC communicates that it has detected a signal from a federal system in a given area, the SAS must either confirm suspension of the CBSD’s operation or its relocation to another unoccupied frequency.

OOBE Limits 96.41(e) 3.5 GHz Emissions and Interference Limits:
(1) General protection levels. -13 dBm/MHz within 0-10 MHz outside channel edge; -25 dBm/MHz beyond 10 MHz (2) -40 dBm/MHz below 3530 and above 3720 MHz (3) Measurement procedure 1 MHz RBW, except in 1 MHz immediately outside of channel, can use RBW no less than 1% of emission bandwidth

Priority Access License (PAL)
Protected from GAA interference; must protect incumbents Auctioned when mutually-exclusive applications are filed License area = census tract ~74,000 census tracts in U.S., each with ~4,000 pops Three-year license term, no automatic renewal Example use cases Capacity/offload networks for established wireless service providers QoS-managed enterprise networks Utility networks Backhaul Wireless Internet Service Providers (after 5-year sunset on Part MHz operations)

No interference protections; must protect incumbents and PALs No a priori bandwidth limit May utilize unused PAL spectrum (“unused” to be defined) Example use cases Personal hot spots Small business hot spots Campus hot spots PAL offload during periods of incumbent activity interrupting PAL spectrum Unprotected capacity/offload for established wireless providers Wireless Internet Service Providers Backhaul

Issues for Multistakeholder Group Raised in R&O

License Area Edge Power Limit
Aggregate received signal level at a PAL license boundary at or below an rms level of -80 dBm integrated over 10 MHz “We recognize that ensuring compliance with this limit at the boundary is likely challenging on a real-time basis and there are legitimate questions relative to how to develop appropriate predictive models. We also recognize that the use of an aggregate metric could be challenging in a multi-user environment. We encourage any multi-stakeholder group formed to address technical issues raised by this proceeding to consider how this limit should be applied. As an initial matter, we will apply the limit through measurements at the license area boundary at times of peak activity.” (¶195)

Deliverable: Methodology for predicting aggregate signal strength from CBSDs and End User Devices (EUDs) at the boundary of a PAL license area. Relevant Information (¶195) Assumes a measurement antenna at 1.5 m AGL, assumed to be 0 dBi gain Aggregate signal level must be at or below an average (rms) of -80 dBm per 10 MHz Does not apply to adjacent license areas held by the same licensee Initially, the limit applies to measurements at times of peak activity This limit apparently applies to outbound PAL signals, and inbound PAL and GAA signals (GAA has no associated “license area”)

96.21(d) Received Signal Strength Limits (1) For both Priority Access and GAA users, CBSD transmissions must be managed such that the aggregate received signal strength, measured at any location on the Service Area boundary of any cochannel PAL, shall not exceed an average (rms) power level of -80 dBm in any direction when integrated over a 10 megahertz reference bandwidth, with the measurement antenna placed at a height of 1.5 meters above ground level, unless the affected PAL licensees agree to an alternative limit and communicate that to the SAS. (2) These limits shall not apply for co-channel operations at the boundary between geographically adjacent PALs held by the same Priority Access Licensee.

CBSD Professional Installer Accreditation
“Given the importance of accurate reporting by professional installers, we strongly encourage the SAS and user community, through multi-stakeholder fora or industry associations, to develop programs for accrediting professional installers who receive training in the relevant Part 96 rules and associated technical best practices.” (¶222)

CBSD Professional Installer Certification
Notes from April 30 discussion: May tie to certification and trade-off in SAS requirements Could define what information is required from the installer May not be good for the Forum to get into the business of certifying guys with tool belts Trust criteria for inputs to SAS Want to minimize the amount of data from the installer Proposed Deliverable List of information required from the installer Could simply flesh out Category B data requirements a bit more (antenna pattern, azimuth, downtilt, etc.) Deliverable may be needed to avoid delay in certification process WG4 (or joint 1/4) issue?

CBSD SAS Registration Requirements
“We encourage multi-stakeholder groups to consider the issues raised by the registration rules described in this section, including acceptable contact intervals between CBSDs and SASs, and to suggest appropriate operational parameters.” (¶234)

“Issues” refers to issues raised by commenters and not specifically addressed in the rules? (¶231) Data verification Update interval (heartbeat) Data retention time Storage of actual operational information Confidentiality of sensitive information, including detailed operational parameters of mobile networks Deliverable Recommendations/requirements addressing above Confidentiality should be addressed by WG2

96.39(c) Registration with SAS: A CBSD must register with and be authorized by an SAS prior to its initial service transmission. The CBSD must provide the SAS upon its registration with its geographic location, antenna height above ground level (in meters), CBSD class (Category A/Category B), requested authorization status (Priority Access or General Authorized Access), FCC identification number, call sign, user contact information, air interface technology, unique manufacturer’s serial number, sensing capabilities (if supported), and additional information on its deployment profile required by sections and If any of this information changes, the CBSD shall update the SAS within 60 seconds of such change, except as otherwise set forth in this section. All information provided by the CBSD to the SAS must be true, complete, correct, and made in good faith.

96.43 – Additional Requirements for Category A CBSDs (a) Category A CBSDs shall not be deployed or operated outdoors with antennas exceeding 6 meters height above average terrain. CBSDs deployed or operated outdoors with antennas exceeding 6 meters height above average terrain will be classified as, and subject to, the operational requirements of Category B CBSDs. (b) When registering with an SAS, Category A CBSDs must transmit all information required under section This transmission shall also indicate whether the device will be operated indoors or outdoors. (c) Any CBSD operated at higher power than specified for Category A CBSDs in section will be classified as, and subject to, the operational requirements of a Category B CBSD.

Additional Requirements for Category B CBSDs (a) Category B CBSDs must be professionally installed. (b) In the MHz band, Category B CBSDs must be authorized consistent with information received from an ESC, as described in section (c) Category B CBSDs are limited to outdoor operations. (d) When registering with an SAS, Category B CBSDs must transmit all information required under section plus the following additional information: antenna gain, beamwidth, azimuth, downtilt angle, and antenna height above ground level.

Spectrum Access System Purposes and Functionality … (d) To register and authenticate the identification information and locations of CBSDs. ...

Interference Reporting
“We require that CBSDs be able to measure and report on their local interference levels and issues as set forth in the proposed rules. We encourage industry to develop detailed metrics regarding issues like received signal strength, packet error rate, and technology specific parameters of signal and interference metrics. These metrics could be developed by an industry multistakeholder group.” (¶237)

Interference Reporting (paragraphs 235-237)
Background. It was suggested in the FNPRM that, to help an SAS tune or update its predictive propagation models and detect realistic interference issues once CBSDs are deployed, the CBSDs should be able to provide signal strength and interference level measurements. This capability is already widely used to facilitate interference and radio resource management within cellular networks. It could be used in the 3.5 GHz Band to help promote coexistence between different users. The record generally supports the proposal to incorporate interference reporting into CBSDs. However, some commenters contend that the details of such measurement/reporting should be specified by industry forums. Discussion. We require that CBSDs be able to measure and report on their local interference levels and issues as set forth in the proposed rules. We encourage industry to develop detailed metrics regarding issues like received signal strength, packet error rate, and technology specific parameters of signal and interference metrics. These metrics could be developed by an industry multistakeholder group. Such guidance could be incorporated in the SAS Approval process described in section IIIH)(3)(b) or incorporated independently by authorized SAS Administrators, subject to Commission review. This requirement is separate from sensing requirements associated with ESC, discussed in section III(I).

Interference Reporting
Could be another SAS approval criterion so this should be addressed expeditiously Deliverable Document describing “detailed metrics regarding issues like received signal strength, packet error rate, and technology specific parameters of signal and interference metrics.”

FSS Protections “...[W]e agree ... that a multi-stakeholder process could provide insight into the technical factors and interference limits between coexisting services in the 3.5 GHz Band.” (¶289)

FSS Protections Order quotes widely disparate claims from commenting parties regarding FSS protection (both in-band and adjacent band) Commission adopted rules for FSS earth stations to register operational parameters on a yearly basis, but the rules are otherwise silent on protection criteria, leaving that to the 2nd FNPRM and a multistakeholder group Deliverable(s) Recommendation document on FSS protection WinnForum regulatory filing in response to 2nd FNPRM Deadline will likely be ~mid-to-late June for comments, ~mid-to-late July for reply comments

Data Security “Data security is fundamental to the successful implementation of the Citizens Broadband Radio Service….We are mindful, however, of the limitations inherent in mandating any particular security technology or protocol through regulation. We encourage the industry to develop best practices for end-to-end security that can be validated in the equipment and SAS certification processes.” (¶240)

Data Security To be addressed by WG2 and WG3

SAS Requirements “We continue to believe that a “light touch” regulatory approach is appropriate for this band and that the rules should include only the high-level requirements necessary to ensure the effective development and operation of fully functional SASs. We agree with commenters that support collaborative, industry-wide efforts to create standards and best practices governing SAS operations. The Commission will assist these efforts through the SAS Administrator approval process, as set forth in III(H)(3)(b). We also believe that an active multi-stakeholder group could help develop industry consensus around the best methods of meeting the SAS requirements.” (¶319)

SAS Requirements Commission has laid out high-level functional requirements for SASs (96.53) Otherwise it is allowing “SAS Administrators, individual licensees, and the rest of the industry to work together to implement procedures to meet the Commission’s regulations.” Deliverable This is a broad-brush endeavor that matches the general goals and deliverables of the SSC, including the WG1 requirements document

Band Plan “...[W]hile we decline to subdivide the MHz band, nothing in the rules we adopt should be read to preclude industry agreement on a common bandplan, so long as the bandplan complies with the rules…. If industry stakeholders do not develop such a convention, the Commission may revisit this issue in the future.” (¶59)

Band Plan Considerations
Analysis and metrics related to disruption to PAL/GAA operations due to incumbent operation Improving stability and availability of spectrum access by PAL licensees under various incumbent scenarios Reducing susceptibility of OOBE interference to/from PALs due to existing Wireless Broadband Service activity in Consideration of temporary interstitial channel assignments to improve spectrum access during incumbent activity Consistency with 3GPP band 42 & 43 channel raster Considerations of relative priority of PAL and GAA channels during disruptions

Band Plan Deliverable Recommended band plan for 3550-3650 MHz band
Recommendations related to dynamic band reconfiguration during incumbent activity

Congestion Metric [I]t might be possible that instead of the bright-line urban/rural distinction implemented in these initial rules, industry stakeholders (perhaps working through a multi-stakeholder forum) could agree on a “congestion metric” and associated methodology for SAS to reduce CBSD power levels in high-demand areas. (¶214)

Congestion Metric Commission could allow increased power limits for Cat B non-rural CBSDs, either by rule change or by waiver Subject to advancements in technology, such as advanced SAS coordination capabilities or use of contention-based protocols in CBSDs (or both) Deliverable Document deriving concept of “congestion metric” to allow for dynamic (in time and space) power limits for Category B CBSDs

PAL Channel Reconfiguration Upon Single Incumbent Disruption
1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 10

36 Different Ways 2-7 PALs Can Be Held By Up To 7 Licensees
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Licensee 1 Licensee 2 Licensee 3 Licensee 4 Licensee 5 Licensee 6 Licensee 7 Total No. of PALs 1 2 3 4 5 6 7 Color corresponds to PAL license count:

Priority Access License
Licensed use authorized in MHz Will be auctioned License area will be census tracts as defined in the 2010 census FCC may update license area definitions subsequent to future censuses Each PAL is a 10 MHz channel in one license area PAL licensee may aggregate up to four PALS in one license area PAL license term is 3 years Automatically expire at end and cannot be renewed, but licensee can re-apply Initial auction of licenses will allow aggregation of consecutive 3-year licenses; subsequent auctions will be three-years only

Priority Access License (cont’d)
If only one PAL application in a license area is submitted, no PALS will be assigned and spectrum will remain solely GAA [(96.29(d)] No more than seven PALs shall be assigned in any given license area at a time Leaves at least 80 MHz for GAA in each census tract Unused Priority Access frequencies may be used for GAA Definition of “unused” addressed in 2nd FNPRM PAL information will be maintained by the FCC and publicly accessible [96.23(c)]

GAA may operate in MHz MHz portion is encumbered by Part 90 Wireless Broadband Service, which is granted protection rights out as long as 2023 GAA may utilize unused PAL frequencies Definition of “unused” left for 2nd FNPRM No expectation of interference protection from other GAA No explicit language restricting aggregation of GAA spectrum GAA is licensed by rule (not unlicensed)

General Topic Areas Addressed in 2nd FNPRM
Defining “use” of PAL frequencies Implementing Secondary Markets in Priority Access Licenses Optimizing Protections for FSS In-band protection of FSS in the MHz band Out-of-band protection of C-band FSS earth stations

A Bit More Detail

353 313 138 Total = 804

Part 96 – Citizens Broadband Radio Service Rules Highlights

Incumbent Protections

Federal Incumbent Protection: ESCs, Exclusion Zones
For CBSD operations in MHz: Category A CBSDs must protect by using ESC or exclusion zones [96.15(a)(3)] Once an ESC is approved and used by at least one SAS, Category A CBSDs may only be authorized consistent with information on federal frequency use provided to the SAS by an approved ESC [96.15(a)(3)(ii)] Category B CBSDs must rely on an ESC Within 60 seconds of ESC notification to SAS, the SAS must either confirm suspension or relocation of CBSD operations

For CBSDs operating in MHz (cont’d): FCC can add or modify exclusion zones or protection zones to protect current and future federal incumbents Non-emergency reclamation orders will be coordinated between federal incumbent users and the FCC. The order, with an expiration date and time, will be communicated to the SAS [96.15(a)(6)]

For CBSDs operating in MHz: CBSDs and End User Devices must not cause harmful interference to, and must accept interference from, federal incumbent users operating in the MHz band Until ESCs are approved, exclusion zones must be maintained for an 80 km radius surrounding federal radiolocation sites at: Pax River, MD Pensacola, FL Pascagoula, MS SAS must reconfigure CBSDs within 60 seconds upon receiving an alert from an ESC Pasc was taken out of US109 and , but was put back in US109 in the Order.

Federal Incumbent Protections: General
CBSDs operating in MHz must [96.15(a)(1)]: Not cause harmful interference to federal incumbents operating in or below this band Must accept interference from federal incumbents operating in or below this band Grandfathered Wireless Broadband Services must protect Fed and FSS consistent with rules governing CBRS [96.21(a)]

Federal Incumbent Protection: Kill Switch
Non-emergency reclamation orders will be coordinated between federal incumbent users and the FCC. The order, with an expiration date and time, will be communicated to the SAS [96.15(a)(6)]

FSS Protection: 3600-3650 and 3700-4200 MHz (96.17)
SAS required to enforce protections of FSS earth stations in and MHz Sites listed at fcc.gov/cbrs-protected-fss-sites FSS earth stations requesting protection must register annually by December 1st or when making changes Registration info will be made available to approved SASs Info must include coordinates, antenna gain, az/el antenna gain pattern, antenna pointing azimuth, antenna elevation angle CBSDs may operate within interference zone of FSS earth station upon mutual agreement Terms must be provided to a SAS provider and communicated with other SASs

FSS Protection: 3650-3700 MHz [96.21(c)]
CBRS and Grandfathered Wireless Broadband Licensees must protect authorized grandfathered FSS earth stations consistent with existing rules in Part 90, subpart Z, until the last Grandfathered Wireless Broadband license expires within a given protection zone. “...base and fixed stations may not be located within 150 km of any grandfathered satellite earth station operating in the 3650–3700 MHz band” [ (a)(1)] Effectively no CBRS within 150 km of grandfathered sites, unless under an agreement with the FSS operator, and until the last Wireless Broadband License expires in that protection zone.

SAS Purpose and Functionality
96.53 spells out long list of SAS functional requirements, most of which are consistent with expectations, with the exception of 96.53(d) adds a requirement to authenticate the identification information and location of CBSDs (probably as a direct result of the NAB TVWS emergency petition) 96.53(j) requires facilitation of coordination among Category B GAA CBSDs 96.53(m) requires protection of Grandfathered Wireless Broadband Licensees

SAS Information Gathering and Retention (96.55)
List of required information and retention is generally as expected, with the exception of: 96.55(a)(3) requires CBSD registration information to be available to the general public, but obfuscated Records pertaining to other than fed spectrum use must be maintained for at least 60 months Retention of ESC data will be addressed in the ESC approval process Every CBSD registrant must acknowledge the risk of possible interference from federal users and SAS must keep records of this acknowledgment

Scratchpad, Backup & Interesting Issues

3550-3700 MHz Band Estimated Timeline
Anticipated activities prior to operations in the band: Completion of follow-up rulemaking Hardware availability Establishment of requirements to achieve approval of Environmental Sensor Capability (ESC) to detect and avoid incumbent government radar Establishment of requirements for SAS certification Public trials of SAS Proof of ESC ability to protect incumbent radar Approval and certification of SAS and ESC Estimated timeline for first deployments: ~18 months (late 2016)

End-to-End CBRS Architecture (FCC)
Proxy/ Network Manager User CBSD 1 FCC Databases (Commercial Users/Licenses) User CBSD 2 SAS1 CBSD 3 CBSD 4 User ESC (Federal Incumbent Use) CBSD Citizens Broadband radio Service Device ESC Environmental Sensing Capability (dedicated device to detect incumbent radar activity) SAS Spectrum Access System SAS2

ESC-related Developments
Once an ESC is approved, all Category A devices, apparently under all SASs, must rely on ESC Implies ESC operator will share ESC alerts with competing SASs Low-budget SASs have no incentive to deploy their own ESC network 60 s time limit from ESC alert to CBSD reconfiguration Much shorter than 11 minute interval (including 10 min heartbeat) in proposed rules May require push technology

Clarifications/Questions
Where is the definition of Grandfathered Wireless Protection Zone? cf (a)(1) Note: Definitions section says it will be defined by WTB and OET. OOBE levels in 96.41(e)(1) are specified in PSD (dBm/MHz), but 96.41(e)(3) specifies different measurement bandwidths for different frequency offsets (1% of emission BW in first MHz, 1 MHz otherwise). This is conflicting, but we know what they meant. There is a requirement for protection of OOBE C-band FSS (96.16(b)), but there is no definition of what that protection zone looks like.

Interesting If only one PAL application in a license area is submitted, no PALS will be assigned and spectrum will remain solely GAA [(96.29(d)] Grandfathered Wireless Broadband must now use same incumbent protection methodology as CBRS? Language in 96.21(a) is confusing. What does 96.23(c) mean? PAL radios must accept adjacent and in-band blocking interference as high as -40 dBm in 10 MHz from other PALS and GAA [96.41(f)] SAS must authenticate identification information and location of CBSDs

Interesting (cont’d) 96.55(a)(3) requires CBSD registration information to be available to the general public, but obfuscated

Andrew Clegg NSMA Spectrum Management 2015 May 19th, 2015

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Andrew Clegg NSMA Spectrum Management 2015 May 19th, 2015

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