FCC 15-47 Spectrum Sharing in the 3.5GHz Band Comments Approval April 2009 doc.: IEEE 802.19-09/xxxxr0 July 2015 FCC 15-47 Spectrum Sharing in the 3.5GHz Band Comments Approval Date: 2015-07-13 Authors: Rich Kennedy, MediaTek Rich Kennedy, Research In Motion

April 2009 doc.: IEEE 802.19-09/xxxxr0 July 2015 Abstract This presentation is intended to explain the Comments for FCC 15-47, previously approved by the Regulatory SC and the 802.11WG, the process we should use to have it submitted to the FCC, and why we should use this process in future regulatory responses. Rich Kennedy, MediaTek Rich Kennedy, Research In Motion

Summary The 3.5 GHz Band Today and the Report & Order July 2015 Summary The 3.5 GHz Band Today and the Report & Order The FCC 15-47 Comments reflect what is important to IEEE 802.11 Why did the 802 EC not approve our May document What the current EC rules allow Modification of the May document Approval and submittal Rich Kennedy, MediaTek

The 3.5 GHz Band Today 3550-3650 MHz 3650-3700 MHz Exclusion zones July 2015 The 3.5 GHz Band Today 3550-3650 MHz Federal radars Fixed Satellite Services (FSS) 3650-3700 MHz FSS WiMAX including utility networks IEEE 802.11y Exclusion zones Naval radars Rich Kennedy, MediaTek

July 2015 The 3.5 GHz Band Rich Kennedy, MediaTek

July 2015 Footnote US349: The band 3650-3700 MHz is also allocated to the Federal radiolocation service on a non-interference basis for use by ship stations located at least 44 nautical miles in off-shore ocean areas on the condition that harmful interference is not caused to non-Federal operations. Rich Kennedy, MediaTek

Federal Exclusion Zones July 2015 Federal Exclusion Zones Rich Kennedy, MediaTek

FSS Protection Zones in 3650-3700 MHz July 2015 FSS Protection Zones in 3650-3700 MHz Rich Kennedy, MediaTek

FCC 15-47 Report & Order Final rules for operation in this band July 2015 FCC 15-47 Report & Order Final rules for operation in this band Three level spectrum sharing Spectrum Access System (SAS) database control Licensed incumbents Part 96: Priority Access Licenses (PALs) and General Authorized Access (GAA) Changes from FCC 12-148 NPRM 3-year PAL non renewable term vs 1-year renewable 5 times Federal exclusion zones reduced by 77% No 5-year limit on grandfathered FSS Addition of Environmental Sensing Capability (ESC) New categories: Category A CBSDs for lower-power (e.g., small cell) Category B CBSDs, authorized for higher-power, directional, higher-gain use No reservation for Contained Access Facilities (“CAFs”). Rich Kennedy, MediaTek

The Tiers First Tier - Incumbents July 2015 The Tiers First Tier - Incumbents Federal users Fixed Satellite Services (FSS) Second Tier – Priority Licenses (PALs) Must not interfere with Tier 1 10 MHz channels in the 3550-3650 MHz band [none in 3650-3700 MHz] On a census-tract basis, for three-year terms, no option to renew Dynamically assigned via Spectrum Access System (SAS) A maximum of 70 MHz in any census tract Licensees may hold a maximum of four licenses in any area, i.e. 40 MHz Third Tier – General Authorized Access Must not interfere with Tiers 1 and 2 License-by-rule framework May access PA spectrum when it is not in “use” Rich Kennedy, MediaTek

Maximum Conducted Output Power July 2015 TX Power Limits  Device Geographic Area Maximum Conducted Output Power (dBm/10 megahertz)** Maximum EIRP (dBm/10 megahertz) Maximum 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 Rich Kennedy, MediaTek

Comments Approved in May July 2015 Comments Approved in May IEEE 802.11 will not develop a standard, and the industry will not develop silicon with the current restrictions Coastal exclusion zones prevent use in some major metropolitan areas; timing of proposed further reductions is unclear FSS protection zones eliminate other population centers Similar restrictions prevented hindered 802.11y development Unclear spectrum availability slowing 802.11af development The FCC should understand that Wi-Fi’s success is based on low-cost silicon, enabled by spectrum certainty Rich Kennedy, MediaTek

Why the EC Rejected the May Comments July 2015 Why the EC Rejected the May Comments Two members asked to make wording changes which would have softened what needs to be a strong message Although the document claimed to represent IEEE 802, it was actually narrowly representative of 802.11 There was concern that the 802.11 message was not aligned with what 802.22 would like to see in the response 802.22 did not develop a response of their own The 802.18 Chair abstained because he objected to 802.11/15 sending it directly to the EC, and not through his group Rich Kennedy, MediaTek

How We Will Submit it to the FCC July 2015 How We Will Submit it to the FCC What the 802 EC allows Working Group documents can be submitted to government agencies under their WG name and the WG Chair’s signature Sponsor subgroup communications shall be identified in the first paragraph as the view of only the Sponsor subgroup and shall be issued by the Sponsor subgroup(s) Chair(s) and shall include the Sponsor Chair in the distribution. Such statements shall not bear the IEEE, the IEEE-SA, or IEEE 802 LMSC logos This effort Adrian has submitted the updated document to the EC for 5-review in the expectation that the WG will approve the updated document. TBC – no motion to block was made, and we can proceed with the motion on the updated document. TBC – or a motion to block was made, and failed, and we can proceed. TBC – A motion to block succeed. TBC … Approve the updated document in the 802.11 Opening Plenary Edit options when outcome of opening EC known Rich Kennedy, MediaTek

What I Changed in the May Document July 2015 What I Changed in the May Document Changed all references to IEEE 802 to IEEE 802.11 Added a sentence to the conclusion IEEE 802.11 will continue to monitor progress towards resolving the exclusion zone and FSS protection limitations, and will re-evaluate our position as conditions dictate. This will prevent some of the potential blocking votes Rich Kennedy, MediaTek

July 2015 Motion Approve transmission of document 11-15/683r4 (https://mentor.ieee.org/802.11/dcn/15/11-15-0683-04-0reg-comments-in-fcc-15-47.docx) to the FCC in response to FCC docket 15-47, granting the 802.11 WG chair editorial license Moved by: Seconded by: Discussion? Vote: The motion is approved / not approved Rich Kennedy, MediaTek