Canada Gazette Notice No. SLPB : Consultation on the Spectrum Outlook 2018 to 2022 Canada Gazette, Part I October 21, 2017

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1 Howard Slawner 350 Bloor Street East, 6th Fl Toronto, Ontario M4W 0A1 o m Sent via ic.spectrumauctions-encheresduspectre.ic@canada.ca Director, Spectrum Regulatory Best Practices Innovation, Science Economic Development Canada 235 Queen Street Ottawa, ON K1A 0H5 Re: Canada Gazette Notice No. SLPB : Consultation on the Spectrum Outlook 2018 to 2022 Canada Gazette, Part I October 21, Rogers Communications Canada Inc. (Rogers) is pleased to provide Innovation, Science and Economic Development Canada (ISED or the Department) with the following reply comments in response to SLPB : Consultation on the Spectrum Outlook 2018 to 2022 (the Consultation), published in the Canada Gazette, Part I, October 21, Rogers thanks the Department for the opportunity to provide input on this important issue. Regards, Howard Slawner Vice President Regulatory Telecom HS/jt Attach.

2 Consultation on the Spectrum Outlook 2018 to 2022 SLPB Reply Comments of Rogers Communications Canada Inc.

3 Table of Contents Page Executive Summary 2 Introduction 3 Rogers Reply to Comments of Other Parties Q1 Potential Changes to Licensing Regime 5 Q2 Commercial Mobile Services Spectrum Demand 10 Q3 Developments to Address Commercial Mobile Spectrum 10 Demand Q4 Operational Measures to Address Mobile Spectrum Demand 10 Q5 Demand for Licence-Exempt Spectrum 13 Q6 Developments to Address Licence-Exempt Spectrum Demand 13 Q7 Priority of Licence-Exempt Spectrum Bands 14 Q8 Carrier-grade & Managed Wi-Fi Demand 14 Q9 Satellite Services Spectrum Demand 14 Q10 Demand of C-band, Ku-band, and Ka-band 15 Q11 Developments to Address Satellite Spectrum Demand 17 Q12 Priority Satellite Applications 17 Q13 Demand for Backhaul Spectrum 18 Q14 Potential Changes in Backhaul Technology Mix 19 Q15 Developments to Address Backhaul Spectrum Demand 20 Q16 Impact of Access Demand on Backhaul Spectrum Demand 20 Q17 Priority of Backhaul Spectrum Bands 20 Q18 Flexible Use Licensing Impact on Backhaul Deployments 21 Q19 International Mobile, Fixed, Satellite, & Licence-Exempt Bands 21 Q20 Potential Frequency Bands for Release 2018 to Q21 Additional Bands for Release 2018 to Q22 Specific Bands for Specific Applications 26 Q23 Factors Impacting Potential Release of Bands 2018 to Page 1 of 27

4 Executive Summary E1. Access to interference free, exclusively licensed spectrum is needed in order to satisfy Canadians growing demand for mobile data services. Additional spectrum is key for enabling the deployment of 5th generation wireless technology, which will also increase the need for more fixed service spectrum to provide backhaul to mobile networks. Since Canadians connect more and more devices to their home Wi-Fi networks and take advantage of faster broadband Internet speeds, more unlicensed spectrum will also be needed. As Canada s largest wireless provider, Rogers continues to invest heavily in advanced communication networks and requires access to additional mobile, fixed, and unlicensed spectrum. E2. Innovation, Science and Economic Development should look to maximize the use and release of low, mid, high, microwave, and millimetre wave spectrum for new services using a technologically-neutral approach while ensuring reasonable protection of incumbent services. Increasing and enhancing spectrum availability is vital to supporting the advanced network speeds, capacity, and wireless innovations that Canadians have come to enjoy and demand. E3. Providing access to additional flexible use, exclusively licensed spectrum in a variety of frequency ranges will allow providers to increase network coverage and capacity while supporting the deployment of advanced next-generation wireless technologies. It will also allow operators to deploy fixed terrestrial or fixed or mobile wireless access services based on network needs and market demands, acting as a key building block for advancements in wireless technology. E4. The Department should carefully weigh the importance of the mobile industry for the majority of Canadians and Canadian businesses when evaluating competing demands for spectrum, especially in urban and suburban areas. Rogers believes there will be significant demand in Canada for the services provided by terrestrial 5th generation fixed and mobile services, and the potential benefits to Canadians and the economy are substantial. The Department has an important role to ensure that Canada continues to be at the forefront of 5th generation technology innovation and adoption by providing access to the spectrum bands discussed in this consultation as quickly as possible. E5. Access to spectrum is essential but equally important is access to infrastructure. The Department needs to take steps to ensure a level playing field for infrastructure access if Canada is to become an innovation leader. 5th generation wireless technology will result in a large increase in network base stations and the amount of traffic they carry. The Department must work with the Canadian Radio-television and Telecommunications Commission and all levels of government to ensure Page 2 of 27

5 carriers have access to the poles (hydro and telecom), ducts, streetlights, and municipal property that are needed to place antennas and wires. Further, it is essential that the Department ensure that any Federal, Provincial or Municipal accesses or infrastructure that local telephone companies possess from their monopoly period are similarly made available to all types of carriers in order to increase the quality of services that are provided and to increase the level of competition for the benefit of all Canadian businesses and consumers. Introduction 1. Rogers Communications Canada Inc. (Rogers) welcomes the opportunity to reply to comments filed by other parties in response to SLPB : Consultation on the Spectrum Outlook 2018 to (the Consultation), published in the Canada Gazette, Part I, October 21, Rogers stated its position on all of the issues raised in the Consultation in its comments of February 16, This reply is limited to comments on proposals made by other parties. Failure to address any specific issue raised by other parties should not be taken by Innovation, Science and Economic Development Canada (ISED or the Department) as Rogers acquiescence with the position. 3. At the outset, Rogers notes that there is overwhelming support for the Department to release new mobile, fixed backhaul, and unlicensed spectrum bands to support current and future growth in demand. Many parties are skeptical of the need for additional spectrum for satellite services in general and very little evidence is provided to demonstrate a need for additional amounts of this spectrum. 4. There is broad support for the release of 5 th generation (5G) spectrum bands in a variety of frequency ranges as soon as possible. The majority of parties support flexible use, exclusively licensed spectrum for 5G and other services to promote investment in, and enable the successful implementation of, this important new technology. 5. There is a general concern regarding opportunistic or dynamic spectrum access, particularly in exclusively licensed mobile spectrum bands, due to the lack of real world experience with this nascent technology. The few proponents of opportunistic or dynamic access are those that have limited or no experience building and operating networks using exclusively licensed spectrum. 1 ISED, SLPB : 2018 to 2022 (the Consultation); gst.nsf/eng/sf11333.html. Page 3 of 27

6 6. There is broad support for the release of new spectrum for fixed backhaul services among parties that are not former telephone monopolies that enjoy unrivalled access to certain infrastructure enabling them to extensively deploy fibre backhaul. Some parties also call for all levels of government and the federal regulators to take action to ensure that all carriers will have access to the public and private infrastructure that are needed to place antennas and wires to successfully deploy competitive 5G networks. 7. The majority of parties note that the current licence fee model for backhaul spectrum penalizes efficient use of the spectrum, results in unreasonably high costs, and thereby discourages utilization of new high capacity backhaul spectrum bands. These parties call on the Department to urgently address this issue. 8. Some parties stray beyond the scope of the Consultation and raise issues that have either already been addressed in recently concluded consultations, or that would be more appropriately dealt with in upcoming consultations. 9. For example, Shaw asserts that it must be provided with a 40 MHz spectrum setaside in the upcoming 600 MHz auction. 2 Shaw also similarly asserts that it is in greater need of low-band 600 MHz spectrum compared to incumbent licensees which already hold low-band mobile spectrum. 3 Shaw raises these issues even thought they were already raised and addressed in the Department s 600 MHz band consultation, the record for which has already been closed. 4 In that consultation, Rogers and other parties provided comprehensive justification for why the proposed 30 MHz set-aside of 600 MHz spectrum is not necessary, would be poor public policy, and should be reduced to 20 MHz. 5 Rogers and other parties have also explained why Shaw and other carriers do not have a greater need for 600 MHz spectrum compared to incumbent licensees For its part, Telus raises several detailed issues regarding the 3500 MHz band 7 even though the Department has already indicated that it will hold a public consultation regarding the licensing and possible expansion of the 3500 MHz band for mobile services. 8 2 Shaw Comments, para Shaw Comments, para 23 and ISED, Consultation on a Technical, Policy and Licensing Framework for Spectrum in the 600 MHz Band (SLPB ). 5 See for example Rogers Comments (SLPB ), pp See for example Rogers Reply Comments (SLPB ), pp Telus Comments, pp See Decisions Concerning the Renewal of 2300 MHz and 3500 MHz Licences, November 2013, Decisions Regarding Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process, December 2014, and 2018 to 2022, October 2017, para 109 and 142. Page 4 of 27

7 11. While Rogers will respond briefly to these and other issues raised by Shaw, Telus, and other parties in the following reply comments, we would respectfully request that the Department review the detailed comments filed by Rogers in recently concluded consultations for Rogers comprehensive positions regarding these matters. Rogers reserves the right to file more detailed comments regarding matters that will be addressed in upcoming consultations, such as the 3500 MHz consultation. 12. The remainder of Rogers reply comments will respond to certain specific issues raised by other parties in their comments. Q1: What future changes, if any, should ISED examine with regard to the existing licensing regime to better plan for innovative new technologies and applications and allow for benefits that new technology can offer, such as improved spectrum efficiency? 13. In our comments, Rogers explains why ISED should release spectrum to support 5G and other next-generation wireless technologies ahead of International Telecommunication Union (ITU) World Radiocommunication Conferences (WRC) when there is an expected radio equipment ecosystem or when it is clear that there will be global standards in the respective bands. Spectrum should be made available as rapidly as possible using a technologically-neutral approach while ensuring reasonable protection of incumbent services to enable greater spectrum utilization and allow Canadian consumers to benefit from wireless innovations. 14. There is general support in the comments filed by other parties for the release of additional spectrum bands to satisfy growing demand for most of the services under consideration in the Consultation. The majority of parties support the release of additional spectrum to support current and future growth in demand for mobile, fixed backhaul, and unlicensed services. Only a minority of parties call for the release of additional satellite spectrum, although most believe that there will be very little, if any, growth in demand for satellite services generally and that advancements in technology will adequately address any such demand. 15. A number of parties note the importance of releasing additional spectrum to support future 5G technology and the many innovative services it will enable. With respect to the GHz band, Bell recommends that the Department not wait for the outcome of WRC-19 to initiate the process of releasing this band. 9 Rogers agrees with Bell that there is growing international interest in this band for 9 Bell Comments, para 67. Page 5 of 27

8 5G and that it will likely be identified for mobile use at WRC-19. Telus notes that the U.S. Federal Communication Commission (FCC) has already determined that a portion of this band will be designated for flexible use licensing for fixed or mobile applications. 10 Taking immediate action on this band now will ensure the rapid deployment of 5G in Canada. 16. The Department should take a very cautious approach when exploring opportunistic or dynamic spectrum sharing so as not to negatively affect the advanced mobile networks that will continue to enhance the level of innovation and productivity in the Canadian economy and will be key to Canada s success in a digital world. Opportunistic sharing technology is still years away from commercial deployment and has substantial technical, regulatory, and business challenges to overcome before it can become a reality. Once these technical challenges have been solved, trials should be restricted to bands with open spectrum designations, lightly licensed mobile bands or bands with limited users in restricted geographic areas that will be protected from interference. Once trials have proven successful and stakeholders have a better understanding of the implications of the technology, the Department should launch a comprehensive consultation process to ensure such a fundamental change in spectrum planning and usage is in the public interest. 17. Several parties support the Department s practice of exclusively licensing certain spectrum bands and they urge the Department not to introduce opportunistic or dynamic spectrum access or to proceed with caution with respect to this new technology. Bell notes that much of the research supporting this technology was completed over ten years ago and does not reflect current realities. 11 Cogeco cautions that this technology is not mature nor widely available and that it is therefore not ready for deployment in Canada. 12 The Canadian Wireless Telecommunications Association (CWTA) also views this technology as not ready for commercial deployment and recommends that it should only be adopted once it is found to be technically feasible and without adverse impact on the quality of services provided to Canadians, and only after a standalone consultation has been conducted by the Department. 13 Quebecor is concerned about the potential adverse impact that this technology could have on the services that are provided using exclusively licensed spectrum that licensees have acquired at considerable expense in spectrum auctions. 14 SaskTel observes that it is premature to introduce this technology into commercial mobile spectrum bands due to the possibility of interference and service disruptions, and it calls on the Department to fully test and 10 Telus Comments, para Bell Comments, para Cogeco Comments, para 30 and CWTA Comments, para Quebecor Comments, para Page 6 of 27

9 consult on this technology before introducing it. 15 Shaw raises similar concerns as Quebecor. 16 Xplornet opposes this technology because carriers require certainty for the amount of spectrum available to support their operations A small number of parties, including Dynamic Spectrum Alliance (DSA), Fontur, Seaside, and Telrad, support the introduction of opportunistic or dynamic spectrum access technology. Many of these parties have limited or no experience building and operating commercial networks using exclusively licensed spectrum and therefore fail to appreciate the potential harmful impact this technology could have on commercial services that are currently provided using exclusively licensed spectrum. 19. Exclusively licensed spectrum bands are key inputs in current networks and create a more certain spectral environment. This will be crucial as operators roll out 5G infrastructure and overcome any engineering challenges resulting from the unprecedented densities and usage, especially with the usage of mmwave spectrum. These licences should be flexible for service providers to deploy different services including fixed or mobile wireless access or wireless backhaul or fronthaul, or even dynamically change between usage depending on network need and user demand. 20. Several parties support flexible use licensing for a variety of reasons. Bell supports it on the basis that it will provide greater flexibility to carriers in deploying services, will accelerate innovation, and will allow carriers to quickly respond and adapt to market dynamics and technological advancements. 18 For these reasons, Bell recommends that the flexible use approach should be used for all bands contemplated for release in the Consultation. 19 Shaw supports flexible use licensing since it gives wireless operators the ability to use spectrum for mobile access, fixed wireless access, and/or backhaul, based on the needs in a given area, often resulting in greater spectral efficiency. 20 Telus also supports flexible use licensing and envisions that it will play an important role in addressing backhaul demand. 21 SaskTel believes that the flexible use licensing model is appropriate for the highly complex 5G networks now being tested and developed and for the rapidly evolving wireless industry SaskTel Comments, para Shaw Comments, para Xplornet Comments, pg 7 and Bell Comments, para Bell Comments, para Shaw Comments, para Telus Comments, para SaskTel Comments, para 37 and 127. Page 7 of 27

10 21. Some parties call on the Department to reduce the size of the geographic areas covered by licences in certain spectrum bands. CanWISP, for example, calls on the Department to introduce new Tier 5 licence areas or hexagonal grid cells. 23 These parties note that some operators tend to focus their deployment on populated regions within existing licence areas leaving less populated areas uncovered. These parties argue that spectrum that is not deployed in less populated areas could be used by other operators whose business plans are focused on serving such areas. They assert that the use of smaller licence areas will result in operators focused on more populated areas acquiring only spectrum in those areas while spectrum in less populated areas will be available for other operators to acquire and deploy. Some of these parties complain that the Department s rollout requirements focus too narrowly on population covered. 22. With the benefit of real world experience in deploying both wide area commercial mobile and fixed wireless access services, Rogers believes that these parties significantly understate the operational challenges already faced by operators using the existing, relatively small Tier 4 licence areas. These challenges include frequency coordination and the deployment of non-compatible technologies. For example, Rogers is aware of at least seven different kinds of technologies that are currently used in the 3500 MHz band alone. Further reducing the size of geographic licence areas by introducing new Tier 5 areas or hexagonal grid cells will only further complicate these challenges. 23. With respect to the possibility of third parties utilizing spectrum in areas that have not been deployed by the primary licensee, Rogers notes that the Department has already established policies which enable parties to enter into subordinate licensing arrangements thereby allowing unused spectrum to be deployed in less populated areas. 24 Rogers has entered into several such arrangements with other parties resulting in the deployment of mobile services in rural and remote areas. 24. With respect to the 3500 MHz band, Rogers notes that Inukshuk Wireless Partnership has also entered into such arrangements with other parties who have extensively deployed fixed wireless access services in rural and remote areas. Since renewed licences in the 3500 MHz band are now limited to one-year terms, the band has been reallocated for mobile services, and will be subject to a future consultation and a possible band expansion, new spectrum subordination arrangements are no longer practical in this band. It would make little sense for a third party to invest in and deploy fixed wireless access technology when it must 23 CanWISP Comments, pp See Framework Relating to Transfers, Divisions and Subordinate Licensing of Spectrum Licences for Commercial Mobile Spectrum, June 2013 and CPC Licensing Procedure for Spectrum Licences for Terrestrial Services, Issue 4, October Page 8 of 27

11 recoup this investment over the one-year term of the licence, with no guarantee that the licence will be renewed again in the future. 25. With regards to the fact that the existing rollout requirements are tied to population covered, Rogers would note that this model is commonly used by regulators globally 25 for the simple reason that it provides an incentive to deploy services to the maximum number of citizens within a relatively short period of time and it reflects the economic reality that investments are initially focused on areas that will provide the largest and most rapid return. Subsequently, smaller incremental investments can be made to gradually extend services to less populated areas over time. This model has worked well in Canada with the original commercial mobile operators having far exceeded their initial rollout requirements and mobile services are now available to 99% of the Canadian population. 26 It has also led to the extensive deployment of multiple fixed wireless access networks in Canada, in both urban and rural areas. 26. The use of licence areas no smaller than Tier 4 areas, rollout requirements based on population covered, and the Department s subordinate licensing policies provide the necessary incentives and flexibility to extend mobile and fixed wireless access services deeper into less populated areas of Canada over time. Government funding programs also help to extend services to areas where the economics for deployment are very challenging. 27. We note that Facebook recommends in its comments that the Department should allow for the possible development of high altitude platform stations (HAPS) in the millimetre wave bands. 27 While Rogers agrees that HAPS could hold great potential for providing services in remote and rural areas in Canada, this technology is in the very early stages of development. The proposed frequency ranges are currently extensively used in Canada for terrestrial-based microwave backhaul links and it is important to ensure their ongoing protection if both services will be required to share the same frequency band. In addition, the policy and licensing framework that would be required for HAPS deployment and sharing with incumbent fixed services does not yet exist and would require future consultations. We therefore believe that HAPS are still years away from commercial deployment. For these reasons, Rogers recommends that HAPS applications should not be considered in any millimetre wave decisions at this time. At a minimum, Canada should wait for the completion of deliberations on HAPS at WRC ECC REPORT 231 Mobile Coverage Obligations March 2015, pg CRTC, Communications Monitoring Report, 2017, pg Facebook Comments, pg 2. Page 9 of 27

12 Q2: Do you agree with the above assessment on demand for commercial mobile services in the next few years? Is there additional information on demand, which is not covered above, that should be considered? If so, please explain in detail. 28. Rogers continues to generally agree with ISED's assessment on the future demand for commercial mobile services. We note in our comments that the actual growth in demand for mobile spectrum far exceeds ISED's current and planned future spectrum releases and that the growth is exponential. Based on evidence provided by the ITU, our comments note that the demand for 1960 MHz forecasted by the ITU is far in excess of the 648 MHz allocated by ISED to date. 29. Several parties also believe that additional mobile spectrum will be required to satisfy current and future demand, despite upcoming technological developments that will allow operators to make more efficient use of their licensed mobile spectrum. Telus agrees that additional mobile spectrum will be required noting that many industry forecasts reflect the fact that growth will be exponential. 28 Telus anticipates that the emergence of 5G technology will introduce unforeseen applications that will create additional significant demand and it calls on the Department to allocate spectrum in a variety of bands to support all 5G use cases. 29 Shaw also believes that demand assessments cited in the Consultation may understate the projected demand for mobile spectrum. 30 Shaw cites video services as well as virtual and augmented reality applications as likely to drive even greater demand in the future. 31 Bell, Cisco, Corridor, CWTA, Ericsson, GSMA, Qualcomm, SaskTel, Xplornet and other parties also agree with the Department s demand assessment for mobile spectrum. Some parties such as GSA and Ericsson make the case that Canada will experience a mobile spectrum shortfall 32 or that growth will exceed forecasts. 33 Q3: What new technology developments and/or usage trends are expected to address traffic pressures and spectrum demand for commercial mobile services? When are these technologies expected to become available? 28 Telus Comments, para Telus Comments, para Shaw Comments, para Shaw Comments, para GSMA Comments, pg Ericsson Comments, pg 14. Page 10 of 27

13 30. There is general agreement on the kinds of new technology developments and/or usage trends that are expected to address traffic pressures and spectrum demand for commercial mobile services, and the expected availability of these technologies. Most parties agree that, although these technologies will help, they will not negate the need for additional mobile spectrum to address demand. Q4: Recognizing the trend of increasing commercial mobile traffic, what operational measures (e.g. densification, small cells or advanced traffic management) are being taken to respond to, and support, increasing traffic? To what extent are these measures effective? 31. There is general agreement on the operational measures (e.g. densification, small cells or advanced traffic management) that are being taken to respond to, and support, increasing traffic and the extent to which these measures are effective. 32. Like Rogers, a number of parties express concern that the telecommunications site acquisition situation will only grow worse in the coming months and years. This will significantly limit network densification efforts in urban and suburban areas the very areas where additional capacity and coverage will be essential in order to provide the bandwidth-intensive and latency-sensitive services that will be enabled by 5G technology. 33. Quebecor notes that the implementation of small cells will cause issues with local municipalities and calls on the Department to put in place policies to reduce the administrative burden on carriers seeking to install small cells. 34 The company also supports the CWTA s recommendations on this issue. The CWTA recommends that the Department should consider developing a national policy framework of best practices that local governments can adopt to speed consideration of siting applications. 35 Bell makes a similar point, asking the Department to implement a campaign to inform land use authorities that small cells are exempt from consultation requirements Shaw voices concern that small cell deployment is being impeded by challenges in accessing infrastructure, such as towers, telephone poles, utility poles, and rightsof-way, and it also highlights excessive, unjustified rate increases, such as the Hydro One Pole attachment charges recently imposed by the Ontario Energy Board (OEB). 37 Shaw also urges the Department to follow the lead of the U.S. 34 Quebecor Comments, para CWTA Comments, para Bell Comments, para Shaw Comments, para Page 11 of 27

14 National Telecommunication & Information Administration (NTIA) and work to address the patchwork of permitting and siting approvals and policies that apply across the country and to reduce barriers to deployment of mobile networks Rogers remains supportive of any role the Department can play in facilitating the rapid deployment of 5G infrastructure, beyond simply allocating more spectrum. These efforts should also include making any facilities advantages that the former monopoly local telephone companies possess available to all other competitors in order to increase competition in the provision of 5G services for the benefit of all Canadian businesses and consumers. These facilities advantages are a result of having built their own network of structures during their monopoly period, and accompanying pole-sharing arrangements with hydro utilities. Access to (wireline) local connectivity is critical to 5G deployments. 36. The other key to 5G deployments in urban areas is access to real estate (municipal and private sector) for new micro sites (poles, lamp posts, street furniture, etc.). The Department should ensure that any facilities advantages by ex-monopoly local telephone companies are made available to all other competitors in order to increase competition for the benefit of all Canadian businesses and customers. 37. Building telecommunications networks is enormously costly and challenging. Governments, at all levels, need to adopt policies that will spur deployment and construction of broadband networks and not restrict them. 38. Rogers continues to believe specific recommendations that the Department and the Government of Canada could enact to improve the deployment of wireless infrastructure in Canada would include the following. i. Grant wireless carriers better access to public rights-of-way. ii. Facilitate greater cooperation from municipalities for the establishment of wireless radio transmission sites. iii. Interpret the statutory right under the Telecommunications Act to construct transmission lines to include wireless facilities, including antennas. iv. Grant statutory authority under the Telecommunications Act to the Canadian Radio-television and Telecommunications Commission (CRTC) to regulate the use of hydroelectric utility poles and ducts by telecommunications carriers. v. Extend the CRTC s regulatory oversight of access to telephone poles to include the attachment of wireless equipment, including antennas. 38 Shaw Comments, para 51 and 54. Page 12 of 27

15 Q5: Do you agree with the above assessment of demand for licence-exempt spectrum in the next few years? Is there additional information regarding demand, which is not covered above, that should be considered? If so, please explain in detail. 39. There is broad agreement that growth in demand for licence-exempt spectrum will continue, as will the current practice of off-loading traffic from commercial mobile to Wi-Fi networks and that this will only increase. 40. Rogers reiterates that the Department should avoid placing restrictions such as indoor use only, or low transmit power, or limiting certain bands to specific applications, wherever possible, since doing so will be beneficial to the federal government s broader innovation agenda and to the successful development of the Internet of Things (IoT) in Canada. Q6: What new technologies and/or sharing techniques are expected to aid in relieving traffic pressures and addressing spectrum demand for licence-exempt applications? When are these technologies expected to become available? 41. There is general agreement on the new technologies that are expected to aid in relieving traffic pressures and addressing spectrum demand for licence-exempt applications, and the expected timing of these technologies. 42. As noted above, a number of parties are opposed to the introduction of opportunistic and dynamic spectrum sharing technology at this time. Some of these parties are equally as concerned about this technology being introduced in licenceexempt spectrum bands as in licensed bands. A minority of parties support the introduction of this technology in licence-exempt spectrum bands. 43. Rogers continues to believe that the Department should exercise caution when considering the introduction of this technology, including in licence-exempt bands, and we agree with others that this technology is not ready for commercial deployment. The Department should thoroughly test this technology and undertake a public consultation before deciding on whether and the extent to which it should be introduced in Canada. Page 13 of 27

16 Q7: What existing licence-exempt frequency bands will see the most evolution in the next five years? Are there any IoT applications that will have a large impact on the existing licence-exempt bands? If so, what bands will see the most impact from these applications? 44. There is general agreement on the existing licence-exempt bands that will see the most evolution, the IoT applications that will have an impact, and the bands that will see the most impact. Most parties believe that the bands that will see the most evolution and be impacted the most will be the following bands: 900 MHz, 5 GHz, GHz, and GHz. Q8: Will the trend for offering carrier-grade or managed Wi-Fi services continue to increase over the next five years? If so, will this impact congestion in Wi-Fi bands and which bands would be most affected? 45. There is general agreement that the trend for offering carrier-grade or managed Wi-Fi services will continue to increase and that the 5 GHz band will be most affected. Q9: ISED is seeking comments on the above demand assessment for MSS and earth observation applications for the period Is there additional information on demand, which is not covered above, that should be considered? 46. Rogers continues to believe that more consideration may be warranted by the Department to use auctions for satellite spectrum licences, rather than a firstcome, first-served licensing process to award spectrum. Auctions provide much greater incentives to licensees to deploy. 47. Rogers also highlights the massive disparity between the spectrum costs for mobile spectrum and satellite spectrum. Mobile operators must acquire spectrum through auctions at a very high cost excepting when regional operators are massively subsidized and able to acquire set-aside spectrum at a discounted rate to the national operators, and that their cost is, relatively, only high compared to satellite providers. Satellite operators must pay a mere fraction of these costs and are only charged annual fees once they have deployed satellites. The satellite Page 14 of 27

17 industry has nearly 43 times the spectrum as the mobile industry but pays less than 2% the annual fees. 48. Rogers continues to believe that the demand for satellite services, especially outside of rural and remote locations, is overstated. As such, Rogers believes satellite bands should be repurposed, especially in urban areas. At the very least, the spectrum bands could be converted to exclusive flexible use bands similar to the Department s proposals for the 5G mmwave Consultation bands. The Department should use this Consultation process to help redress the spectrum imbalance between the mobile and satellite industries. 49. Of the parties that commented on the Department s demand assessment for MSS and earth observation applications, most agree with the Department that existing spectrum allocations are sufficient to meet demand in Canada. Q10: ISED is seeking comments on the above demand assessment for FSS/BSS for the period Is there additional information on demand, which is not covered above, that should be considered with regards to the below bands? a. C-band b. Ku-band c. Ka-band a. C-band 50. Rogers continues to agree with the Department and the CRTC that this band is in decline from traditional satellite services and we believe that the spectrum in GHz should be allocated to the mobile industry, particularly in populated areas. Further, if the band is allocated to mobile, deployment of services in rural areas should be market-driven in competition with satellite services. While incumbent satellite earth stations should have protection, it should not be overly restrictive and nothing should prevent mobile licensees from developing a mutually agreed arrangement, including site shielding or relocation, allowing terrestrial network operators to deploy their services in a geographic area where there is an existing grandfathered earth station. 51. Other parties also note that demand for this spectrum is flat and call on the Department to repurpose it. Bell recommends that satellite users should be consolidated in the upper portion of the C-band to allow for the expansion of fixed and mobile services into the lower portion of the band. 39 CanWISP similarly calls 39 Bell Comments, para 44. Page 15 of 27

18 for the band to be repurposed and used to expand the 3500 MHz band 40 as does Xplornet. 41 Cogeco calls on the Department to allocate C-band spectrum for 5G Rogers does not agree with CanWISP s suggestion that it would be relatively simple and straightforward for ISED to immediately expand the portion of the C- band adjacent to the 3.65 GHz band (the block between 3700 and 3800 MHz) for FWA deployment in a manner similar to what has been done with the 3.65 GHz band (lightly licenced, no priority, no protection and 1 year terms) with the caveat that existing FSS stations operating in the C-Band must not be disturbed by FWA operations. 43 This change would run counter to a worldwide trend towards using the MHz band for 5G mobile services. 5G will provide an opportunity for Canadian broadband internet users to benefit from the latest technologies and services, and most importantly including affordable, high speed access. In Rogers view, it would be more forward-looking to freeze the existing FWA/WBS bands at their current allocations, while the Department and the industry consider the best way forward for the entire MHz band. 53. Shaw asserts that use of the C-band by it and other satellite providers continues to be important, although it concedes that this is particularly the case in underserved and northern communities. 44 SaskTel also suggests that it will continue to require access to C-band spectrum, but only to serve remote and northern locations. 45 SES (Ciel) also asserts its ongoing need for C-band spectrum to serve communities in the far North. 46 Telesat suggests that it will require ongoing access to the C-band and asserts that demand will possibly grow due to 4K TV. 47 None of these parties have provided any forecasts to justify their demand assessments. Also, as noted below, Rogers believes that the impact of 4K TV on satellite spectrum demand is likely overstated. 54. Rogers believes that every effort should be made to repurpose as much C-band spectrum as possible to expand the 3500 MHz band in support of terrestrial fixed and mobile services. At the very least, arrangements to provide reasonable protection to C-band systems should be implemented to enable use of this spectrum by terrestrial operators. 40 CanWISP Comments, para Xplornet Comments, pg Cogeco Comments, para CanWISP Comments, pg Shaw Comments, para SaskTel Comments, para SES Comments, pp Telesat Comments, para 13. Page 16 of 27

19 b. Ku-band 55. Rogers continues to believe that capacity requirements for 4K TV may be overstated. 48 Our understanding is the Over The Top (OTT) services that deliver 4K TV can minimize the impact on spectrum bandwidths through newer codecs. As such, 4K TV capacity may only be required for real-time live events. 56. In addition to new OTT technologies continuing to make their services more efficient, we expect that satellite services will continue to modernize their systems and become more spectrally efficient. The replacement of existing satellite systems with more advanced satellites that could achieve greater efficiencies and higher data rates to meet increasing customer demand will reduce the need for additional spectrum. c. Ka-band 57. Rogers has no comments regarding this band. Q11: What and how will technology developments and/or usage trends aid in relieving traffic pressures and addressing spectrum demand for satellite services? When are these technologies expected to become available? 58. Rogers notes in its comments that several new technologies will aid in relieving traffic pressures and address spectrum demand for satellite services. 59. Bell makes a similar observation in its comments and recommends that the Department carefully consider the spectral efficiency of existing satellite systems and not allocate additional spectrum where outdated and inefficient satellites are in operation. 49 Q12: What satellite applications (e.g. broadband Internet, video broadcasting, backhaul, etc.) do you consider a priority for the period ? 60. Rogers continues to believe that satellites support broadband, video broadcasting, and telephone services for remote parts of Canada and should be a priority. The spectrum should however be repurposed for terrestrial fixed and mobile services in non-remote areas. 48 ISED, Consultation, para Bell Comments, para Page 17 of 27

20 61. Shaw also believes that satellite spectrum that is used to serve underserved Canadians should continue to be protected. 50 Xplornet similarly voices support for satellite services that are provided to Canadians in rural and remote areas. 51 Q13: Do you agree with the above assessment on demand for backhaul in the next five years? Is there additional information on demand, which is not covered above, that should be considered? If so, please explain in detail. 62. Rogers notes in its comments that current backhaul licence fees are too high in Canada and are a major impediment to the efficient use of certain frequency bands for backhaul. The current Canadian fee model does not give the operator sufficient incentive to maximize spectral efficiency; in fact, it penalizes efficient backhaul operators. Rogers recommends that backhaul spectrum fees in Canada be modernized and based on cost recovery, rewarding users who employ technologies and practices that yield maximum spectral efficiency per unit area. 63. Several other parties similarly note that backhaul spectrum fees are excessively high for high capacity microwave bands, that these costs are an impediment to the use of newly allocated high capacity bands, and that the Department must urgently address this situation. 64. For example, Cogeco notes that the current backhaul spectrum fee model is based on throughput rates of 64kbps and is therefore obsolete in the current age of broadband connectivity. 52 Shaw makes a similar observation and states that the enormous fees that result under the current fee model penalize more efficient use of the spectrum. 53 At the same time, Shaw highlights the importance of backhaul spectrum for the implementation of small cells and 5G in Canada. 54 Xplornet notes that a reduction in the cost of backhaul spectrum, particularly in rural and remote communities would enable lower priced services for consumers. 55 Other parties raise similar concerns regarding Canada s existing backhaul fee model, the level of backhaul fees for high capacity backhaul links, and the urgent need for the Department to address this issue by introducing a more progressive fee model that 50 Shaw Comments, para Xplornet Comments, pg Cogeco Comments, para Shaw Comments, para Shaw Comments, para Xplornet Comments, pg 13. Page 18 of 27

21 will encourage rather than impede the use of high capacity backhaul spectrum bands While there is general agreement that demand for backhaul spectrum will continue to grow, the most vocal proponents for additional backhaul spectrum are service providers other than the former telephone monopolies that enjoy unrivalled access to certain infrastructure enabling them to extensively deploy fibre backhaul. 66. For its part, Rogers operates a nationwide wireless network, with much of the coverage outside of our fixed network footprint, and as a result we are forced to use microwave backhaul spectrum to a much greater extent than the former telephone monopolies. 67. The former monopolies on the other hand have legacy monopoly rights-of-way access and other infrastructure which enables them to more easily, rapidly and cost-effectively deploy fibre backhaul. 68. It is therefore essential that, in addition to increasing the amount of backhaul spectrum available, the Department ensures that any Federal, Provincial or Municipal accesses or infrastructure that local telephone companies possess from their monopoly period are similarly made available to all types of carriers in order to increase competition for the benefit of all Canadian businesses and consumers. Q14: Backhaul service in Canada is delivered using a variety of solutions, including fibre optics, microwave radio and satellites. What changes, if any, are anticipated to the mix of backhaul solutions employed? 69. There is general agreement regarding the changes to the mix of backhaul solutions that will be employed. While service providers will make increasing use of fibre backhaul in urban centres, microwave radio backhaul will continue to be relied upon in both urban and non-urban areas for a variety of reasons. 70. There is broad agreement that the backhaul spectrum fee model results in fees that are unreasonably high for high capacity backhaul bands and must be urgently addressed by the Department. 56 BCBA Comments, para 33 37; CanWISP Comments, pg 13; CEA Comments, p 7; Corridor Comments, pg 8; Ericsson Comments, pg 25 and 27; Seaside Comments, pg 10; TeraGo Comments, para Page 19 of 27

22 Q15: What and how will technology developments and/or usage trends aid in relieving traffic pressures and addressing spectrum demand for backhaul services? When are these technologies expected to become available? 71. There is general agreement on what and how technology developments and/or usage trends will aid in relieving traffic pressures and addressing spectrum demand for backhaul services and the timing of these technologies. Most parties cite techniques such as adaptive modulation, higher orders of modulation, carrier aggregation, and MIMO as enabling more efficient use of backhaul spectrum. 72. The majority of parties agree that additional backhaul spectrum will be required despite these technology developments. Q16: Will the demand for commercial mobile, licence-exempt, satellite, or fixed wireless services/applications impact the demand for backhaul spectrum? If so, how and which of these services/applications will create the most impact? 73. There is general agreement that demand for commercial mobile, licence-exempt, satellite, and fixed wireless services/applications will impact demand for backhaul spectrum and that commercial mobile and fixed wireless access services and video applications will create the most impact. Q17: Is there a range or ranges of frequencies that will be in higher demand over the next five years? Why is higher demand anticipated for these frequency ranges? 74. There is general agreement that low, medium, high and millimetre wave frequencies ranges will be in higher demand going forward. 75. Most parties agree that a variety of frequency ranges will be required, for example, to support the various 5G use cases which require low, medium, high and very high frequency ranges and the relative signal propagation and capacity characteristics that each of these ranges have. Page 20 of 27

23 76. Many operators that rely on microwave backhaul to a greater extent than the former telephone monopolies who have extensive fibre infrastructure call for the Department to release more low and mid-band spectrum bands for backhaul. Q18: Will allowing flexible fixed and mobile services within the same frequency band change how backhaul is planned and used? 77. There is general agreement regarding the extent to which allowing flexible use fixed and mobile services within the same frequency band will change how backhaul is planned and used. 78. The majority of parties believe that flexible use licences will be beneficial but will not negate the extent to which additional backhaul spectrum bands will be required. Bell notes that flexible use licensing will encourage efficient and effective use of the spectrum. 57 Q19: Provide, with rationale, your view of the above assessments on the bands being considered internationally for commercial mobile, fixed, satellite, or licence-exempt. 79. Rogers continues to support the Department s assessments on the bands being considered internationally for commercial mobile, fixed, satellite, or licence-exempt use. Rogers also continues to maintain the positions reflected in our comments regarding these and other bands. 80. With respect to the 3500 MHz band, Rogers continues to recommend that the Department follow the lead of Europe, Asia, and the Americas in adopting a globally harmonized band for 5G mobile services. Further, we support the Department s decision to expand the upcoming consultation to include a review of the range MHz. 58 We also continue to believe that the Department should adopt the European 3500 MHz spectrum licensing model and retain exclusive licensing within the band for Canada. We believe that the Department should move from a fixed wireless usage to a flexible use model, similar to the Department s 5G mmwave Consultation, which will allow licensees to deploy fixed 57 Bell Comments, para ISED, Consultation, para 142. Page 21 of 27