Verizon Communications, Inc., has detailed for the FCC proposed technical rules to protect earth station operations once the C-band is repurposed to free up a portion for 5G terrestrial use.
In an ex parte filing in GN docket 18-122 posted today that reports on a meeting with FCC staffers, Verizon said, “First, we urged the Commission to adopt technical rules consistent with those governing 3GPP Band n77. Adopting technical rules that are consistent with the worldwide 5G NR Band n77 gives access to a worldwide ecosystem of network equipment and will permit rapid deployment. Any technical rules that are not consistent will require the ratification by 3GPP of new, U.S.-only bands, which will require the creating of an all-new and U.S.-only ecosystem. Such a result will significantly delay the deployment of 5G NR networks in C-Band and block U.S. networks from global economies of scale.
“The end-user device emission masks are particularly critical,” Verizon added. “Adopting masks that are more stringent than those ratified by 3GPP has the added detriment of requiring significant transmit power reduction in the end-user device, drastically reducing the achievable coverage radius, and geometrically increasing the deployment density required to provide 5G NR services. Comments in the record stating that spectral and physical distance from the MBX [terrestrial mid-band flexible use]-FSS [fixed satellite service] band edge permits a ‘hands-off’ approach to a subset of MBX licensees is based upon a suggested spectral mask that is significantly more stringent than that ratified by 3GPP for Band n77. Such a mask would result in catastrophic damage to the utility of C-band. Even the C-Band Alliance has come to agree that such stringent spectral masks are not necessary for FSS protection.”
“Second, Verizon urged the Commission to adopt PFSD as a compliance safe-harbor,” the filing said. “A recent addition to the record recommends that power flux spectral density (or PFSD; units of dBW/m2/MHz) should be adopted as a measurement proxy for the CBA’s proposed blocking (MBX in-band/FSS out-of-band) and interference (MBX out-of-band/FSS in-band) PSD thresholds. Verizon agrees that the simplification afforded by a safe-harbor PFSD measurement has value.”
“Finally, Verizon discussed TT&C [telemetry, tracking and control] Gateway filters,” according to the filing. “Narrowband filters for TT&C gateways will require additional filter design and testing work. In addition, it will not materially relax the co-ordination requirements on the MBX operations, as OOBE requirements into the narrow-band channel would have to be met. We also support full use of the band for no more than four TT&C gateways.”
In another filing that reported on meetings at the FCC, Comcast Corp. suggested that the “CBA’s proposed technical rules are important to address interference, and the FCC should adopt them – but these rules are insufficient on their own.” The company urged the Commission to (1) “[e]ncourage interested stakeholders to convene a broad-based group to develop a comprehensive framework for addressing interference prevention, detection, mitigation, and enforcement;” and (2) “[c]ondition commencement of MBX operations on joint approval (Wireless Telecommunications Bureau, International Bureau, and Office of Engineering and Technology) of this multi-stakeholder group’s consensus recommendations and path for implementation.”
Comcast added, “If there is no consensus, the FCC itself should take follow-on actions to address incumbent protections.”
Comcast also said that the “CBA has redoubled efforts to provide Comcast/NBCUniversal with firm, detailed commitments that demonstrate it can coordinate a clearing and repack of video services that ensures Americans continue to receive unimpaired video content from Comcast/NBCUniversal.”
But it said that the Commission “should set forth an enforceable mechanism to ensure CBA and its member companies fulfill their on-the-record commitments and those made directly to their customers, which, if met, would maintain the video quality Comcast/NBCUniversal and its customers require.”
Comcast added that the “CBA must be engaged, incentivized, and compensated to participate in ensuring a smooth transition and unimpaired video operations during and after the transition.”
“The FCC should make clear that it will not propose to reallocate any additional C-Band spectrum beyond 300 megahertz,” Comcast also stressed. “The remaining 200 megahertz will be critical to continuing and future innovative video operations.”
In another submission, The Boeing Co. said that the FCC should “exercise caution in ensuring that repurposing a significant portion of the 3.7-4.2 GHz band does not jeopardize the commercial viability or ongoing reliability of the C-band satellite operators. The Commission must ensure that the satellite operators are compensated adequately for their relocation expenses, their ongoing increased costs of doing business, and as acknowledgement and incentive for their voluntary offer to surrender the major portion of their spectrum resources to advance the development of next-generation 5G networks in the United States. The Commission should also permit the C-band satellite operators, through their C-Band Alliance, to administer the reconfiguration of the 3.7-4.2 GHz band in the most expeditious and efficient manner possible. The absence of such a coordinated transition approach, including adequate compensation for their voluntary efforts, would reflect negatively on existing and future spectrum licensees who will need to cooperate with the Commission in the future conversion of other frequency bands to accommodate new wireless technologies that will be needed in subsequent decades to support the continued growth and economic success of this country.” —Paul Kirby, [email protected]
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