1. Current Issues Affecting Fixed Wireless: An Update on FWCC Activities National Spectrum Management Association Cheng-yi Liu 703-812-0478 | liu@fhhlaw.com Fletcher, Heald & Hildreth, PLC May 19, 2015 Current Issues Affecting Fixed Wireless: An Update on FWCC Activities National Spectrum Management Association Cheng-yi Liu 703-812-0478 | liu@fhhlaw.com Fletcher, Heald & Hildreth, PLC May 19, 2015

2. Fixed Wireless Communications Coalition (FWCC)  Formed in 1998  Provides a voice for the Fixed Service community  Hundreds of filings at the FCC (over 230 per ECFS)  initiated numerous rulemaking proceedings  Success due to dedicated and diverse membership  Members include:  equipment manufacturers, engineering firms, licensees of microwave systems and their associations, communications service providers and their associations, railroads, public utilities, petroleum and pipeline entities, public safety agencies, cable TV providers, backhaul providers, communications carriers, and telecommunications attorneys and engineers 1

3. FWCC Objectives (excerpt)  To participate in regulatory proceedings that impact the Fixed Service through spectrum allocation, technical or service rules, or otherwise  To initiate regulatory actions as needed to maintain and improve the environment for the Fixed Service  To defend the Fixed Service against interference from other services both licensed and unlicensed (visit www.fwcc.us for full list)www.fwcc.us 2

4. FWCC Objectives  In other words, we strive to ensure that:  fixed services have access to necessary spectrum  that the regulatory environment under which we operate is workable and keeps pace with technological developments  that fixed services can coexist harmoniously—and interference free—among other spectrum users. 3

5. Access to Spectrum  Spectrum policy motivation:  MORE BANDWIDTH FOR MOBILE BROADBAND  Meow!  Effect on fixed service:  Corresponding need for more wireless backhaul  Mobile services compete for spectrum access  Example:  2014 Notice of Inquiry – 5G mobile services in 24+ GHz bands  Many bands currently used by fixed service  FWCC seeking other spectrum opportunities 4

6. Access to Spectrum  42 – 43.5 GHz  2012 FWCC Petition for Rulemaking  Already allocated for Fixed Service  Suitable for urban backhaul  7125 – 8500 MHz  Currently only for Federal users  Under 10 GHz, mitigates rain fade  Can alleviate congestion in Lower/Upper 6 GHz  Needs NTIA consent, automated coordination system 5

7. The Regulatory Environment  Laws and regulations often lag technology  FWCC active in advocating for change  Congress, Communications Act re-write  FCC proceedings  Ensure rule changes do not create negative implications 6

8. The Regulatory Environment  Relaxation of antenna standards  Smaller can be better  FCC modified 6, 18, & 23 GHz standards in 2012  FWCC provided input  FCC also sought comment on standards for other bands  FWCC requested rulemaking for 70/80 GHz antennas  Smaller antennas facilitate dense urban deployment  Lower costs  Visually inoffensive  Can be installed in more places 7

9. The Regulatory Environment  5.8 GHz unlicensed  Useful for quick deployment of long links (unlimited antenna gain with no power penalty)  Easy transition to licensed 6 GHz operation  2013 FCC proposal to consolidate two rule sections  Resulted in possible elimination of unlimited antenna gain  FWCC and other successfully opposed  Currently, ongoing efforts to address OOBE issue  Stricter OOBE negates benefits of unlimited antenna gain  Government concerned with protecting TDWR installations 8

10. Coexistence With Other Spectrum Users  Prevent interference concerns  Promote efficient use of spectrum  Frequency coordination process generally works well  Coordination among fixed service users  Coordination with Government users  Coordination with other services (e.g., satellite) 9

11. Coexistence With Other Spectrum Users  Occasional disputes between fixed service users  2014 dispute centered around  Expedited coordination requests  Growth channel holding periods  FWCC sought clarification for uncertainty  2015 FCC Public Notice  Reiterated coordination requires cooperation from both sides  Sought further comment on whether: –Fixed time limits are needed for growth channels –Other rule changes needed to address growth channels 10

12. Coexistence With Other Spectrum Users  2010 FWCC Petition for Rulemaking re 23 GHz band  23 GHz shared with Federal users  Requires NTIA coordination  FWCC requested automated coordination system  Alleviates lengthy NTIA coordination process  If implemented, would better facilitate conditional authorization  FWCC also requested eligibility for conditional authorization across the entire band  Currently, only limited frequency pairs eligible  Heavy usage on eligible frequencies  Rest of band underutilized 11

13. Coexistence With Other Spectrum Users  Fixed Satellite Service Earth Stations  Coordinated/licensed for “full band, full arc”  Effectively blocks many fixed service links  Problems if earth station not built or not in right place  FWCC requested earth station audit in 2010  Also requested in 2008, 2004, and 2002  So far, without resolution  FWCC working with NSMA WG3  Conducting studies to further illustrate the issue 12

14. Coexistence With Other Spectrum Users  Fixed Service Sharing with TV BAS & CARS at 7 & 13 GHz  FCC authorized in 2011  NSMA working on coordination guidelines  Issue of missing receive-end data in ULS  Likely due to manual porting of Form 313 data  Past efforts to encourage ULS corrections unsuccessful  FWCC working with NSMA to seek FCC assistance 13

15. 14 Thank you! (most FWCC filings available at www.fwcc.us)www.fwcc.us Cheng Liu 703-812-0478 | liu@fhhlaw.com