Mr. Marc Dupuis Director General, Engineering, Planning and Standards Branch Industry Canada 19 th Floor, 300 Slater Street Ottawa ON K1A 0C8

Transcription

1 Rogers Communications 333 Bloor Street East Toronto, Ontario M4W 1G9 Tel. (416) Fax (416) Dawn Hunt Vice-President Regulatory October 21, 2011 Mr. Marc Dupuis Director General, Engineering, Planning and Standards Branch Industry Canada 19 th Floor, 300 Slater Street Ottawa ON K1A 0C8 Sent via Dear Mr. Dupuis, Re: Canada Gazette, Part I, July 23, 2011, Consultation on Spectrum Utilization of Frequency Bands GHz, GHz and GHz by the Fixed Service SMSE Rogers Communications Partnership (Rogers) appreciates the opportunity to provide comments on the above-noted consultation. The documents are being sent in Adobe Acrobat Pro X Version 10. The operating system used is Microsoft Windows XP. Regards, Dawn Hunt DH/gt Attach WIRELESS DIGITAL CABLE INTERNET HOME PHONE VIDEO PUBLISHING BROADCASTING

2 Comments of Rogers Communications Partnership Consultation on Spectrum Utilization of Frequency Bands GHz, GHz and GHz by the Fixed Service Published in the Canada Gazette, Part I, on July 23, 2011 Submitted October 21, 2011

3 Rogers Communications Partnership Page 1 Executive Summary 1. Rogers Communication Partnership ( Rogers ) strongly supports making the bands GHz, GHz, GHz and GHz available for pointto-point fixed links use, in order to construct fixed links that are required for our evolving and expanding networks. 2. Rogers recommends the use of a frequency division duplex (FDD) band plan arrangement such as the European CEPT Recommendation ECC/REC/(05)07. This arrangement has the added benefit of allowing for the aggregation of channels to support higher capacities when needed. 3. Measures such as frequency coordination and pre-construction interference analysismust be taken tominimize the risk of harmful interference. Rogers supports the RABC in recommending that the European CEPT technical specifications listed in EN and in EN , which will facilitate the availability of 70 GHz and 80 GHz infrastructure in Canada. 4. A spectrum licence model is the most appropriate authorization approach. Rogers favours a light licensing approach and does not agree with the concept of an independent band manager due to the likely high level of fees that would result. Introduction 5. The Department issued a consultation paper titled Consultation on Spectrum Utilization of Frequency Bands GHz, GHz and GHz by the Fixed Service, Canada Gazette, Part I, Notice No. SMSE , ( the Consultation ) on July 23, In the Consultation paper, the Department invited comments on the future use of the bands GHz, GHz and GHz (the Bands ) by the fixed service, including designation, band plan, technical characteristics and the licensing approach. Following are the comments of Rogers. 6. Rogers is pleased to provide the following comments regarding the issues under consideration in the Consultation Paper. Rogers participated in the development of the comments that have been prepared by the Radio Advisory Board of Canada ( RABC ). Rogers support for certain specific positions is identified below.

4 Rogers Communications Partnership Page 2 Detailed Comments 7. Following are Rogers detailed comments regarding the specific issues raised in the Consultation Paper. Applications in Canada The Department seeks comments on making the bands GHz, GHz, GHz and GHz available for point-to-point fixed links. Comments are also sought on the technical parameters for satellite systems in the GHzand GHz bands that should be used in the development of measures to coordinate the useof the fixed and satellite services in these bands. 8. Rogers provided comments to the Department s consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum ( the 700 MHz consultation; SMSE ) 1 in February Among the questions asked in this consultation was, [w]hat is the general need for additional commercial mobile spectrum at this time and what do you anticipate the future needs to be? 9. In its comments to the 700 MHz consultation, Rogers stated 2 that its commercial mobile network, which serves over nine million Canadians, is undergoing a transformation from providing voice-related services to providing mobile broadband services which require much more bandwidth. 10. Rogers deployment of advanced wireless access technologies, such as HSPA and LTE, which support mobile broadband services, has in turn required an unprecedented network densification and backhaul augmentation program. 3 This technology shift has placed a significant demand on Rogers backhaul network facilities, above and beyond the regular subscriber and traffic growth that we experience each year. As a result, Rogers is in need of access to more spectrum for fixed point-to-point backhaul services abridged.pdf 3 abridged.pdf, paragraph 21.

5 Rogers Communications Partnership Page In addition, the short-distance propagation properties, extremely directional main beam characteristics,and commercially available infrastructure capable of gigabit per second capacity make equipment in the Bands very suitable for deployment in urban environments. These installations typically require short range and high capacity links. For Rogers, it is a good alternative to fiber-based, last mile transport systems due to its relative cost and speed of deployment. 12. For these reasons, Rogers strongly supports making the bands GHz, GHz, GHz and GHz available for point-to-point fixed link use. 13. Rogers supports the Department s proposal of harmonization with the U.S. technical rules on equipment technical characteristics. Rogers agrees that the fixed servicesuse of the bands GHz, GHz, GHz and GHz should be permitted only on a licensed basis. Frequency Band Plan Structure and Technical Considerations The Department seeks comments on the band plan structure. 14. Rogers recommends the use of a frequency division duplex (FDD) arrangement for the band plan structure. Rogers notes that the European CEPT Recommendation ECC/REC(05)07 4 has such an arrangement, with the GHz frequency band segmented into 19 x 250 MHz channels, and the same segmentation in the GHz band. This arrangement allows channel aggregation and simplified interference coordination. Included in the CEPT Recommendation are two 125 MHz guard bands on both sides of the GHz and GHz bands. 15. The U.S. band plan structure is divided into unpaired segments. After comparing the U.S. and European band plan structure options, and in light of the FDD band segmentation in the European CEPT Recommendation, Rogers favours the European CEPT Recommendation over the U.S. band plan structure. 16. In general, band plans should support expanding fixed link capacity provisioning levels by allowing flexibility in channel aggregation to provide for larger bandwidths when needed. This flexibility will be important for supporting the dramatic growth of mobile broadband traffic over the next several years. The 4

6 Rogers Communications Partnership Page 4 European CEPT Recommendation band plan structure allows for channel aggregation to provide larger bandwidths when needed. 17. By means of the frequency band segmentation, the CEPT Recommendation band plan structure also simplifies interference-reduction coordination which is an important practice to Rogers for the reasons outlined below. Interference Analysis and Mitigation Measures The Department seeks comments, with technical justification and interference analyses, on the likelihood of interference to/from other radio services and on the appropriate mitigation measures that should apply in the bands GHz, GHz and GHz. 18. Rogers recognizes that the likelihood of harmful interference that a proposed link may receive from or impose upon existing linksin the Bands is relatively low due to the high attenuation over short distances and the narrow beam characteristics of microwave signals in the Bands. 19. However, despite the reduced probability of interference, any harmful interference, no matter how brief, would have a significant impact due to the high link capacity. 20. As microwave links in these bands operate at gigabit per second (Gbps) speeds, even a brief outage spanning a few seconds would translate into a huge loss of data intended for transmission. Therefore, Rogers believes that interference analysis should be required by the licensee proposing the new or modified fixed link prior to activating any new or modified fixed linkwithin the Bands. 21. In the event that interference analysis indicates that interference is likely to occur, the licensee proposing the new or modified fixed link must apply common interference mitigation techniques to minimizethe possibility of interference. These methods include antenna discrimination, polarization, frequency offset, shielding and power control. The licensee that is proposing the new or modified link must be required to re-perform and pass the interference analysis again after applying the mitigation techniques to confirm that the possibility of interference has been eliminated prior to construction. Comments are also sought on what requirements would be necessary to facilitate sharing between the various services, such as coordination requirements, operational constraints and/or power flux density (PFD) limits.

7 Rogers Communications Partnership Page Rogers believes that the coordination criteria for the Bands should be similar to those in the 38 GHz band, but with reduced distances to reflect the shorter propagation and narrow beam characteristics of the 70/80/90 GHz Bands. Comments are additionally sought on the feasibility of uncoordinated deployment of fixed systems. If coordination is needed, input is sought on appropriate technical and/or operational mechanisms for coordination. 23. As stated above, Rogers requires a high grade of service on its fixed links so that it can provide high quality mobile broadband services to its customers. Any harmful interference, no matter how brief, would result in huge data transmission losses resulting in degraded services to end users. 24. Rogers believes that uncoordinated deployment of fixed systems would hinder interference analysis prior to the activation of a fixed link in the Bands, which is required to reduce the likelihood of harmful interference. 25. In other words, Rogers believes that uncoordinated deployment of fixed systems within the Bands would lead to harmful interference which would significantly impact its fixed systems and availability of services being backhauled over these links. For this reason, Rogers does not support uncoordinated deployment of fixed systems within the Bands. 26. As stated above, Rogers believes that the coordination criteria for the Bands should be similar to those in the 38 GHz band, but with reduced distances to reflect the shorter propagation and narrow beam characteristics of the 70/80/90 GHz Bands. Technical Specifications Comments are sought on the technical rules for the GHz, GHz, GHz and GHz bands, as listed above. Interested parties are invited to comment on the technical specifications such as minimum and maximum antenna gain, power spectral density limit, etc. Parties who advocate different service rules for these bands should include a technical analysis and justification.

8 Rogers Communications Partnership Page Rogers recommends that the European CEPT technical specifications found in documents EN and EN be adopted, in order to facilitate the availability of 70 GHz and 80 GHz infrastructure in Canada. We support the comments of the RABC regarding the use of these technical specifications. 28. Rogers agrees with the RABC s observation that there are currently insufficient technical specifications available for the 90 GHz band to provide the Department with an informed response. Rogers is prepared to work with the Department and the RABC to develop technical rules for the 90 GHz band. Licensing The Department requests comments on the authorization approach to be undertaken for use ofthe GHz, GHz and GHz frequency bands. Should licensing be recommended,comments are requested on the manner in which such authorizations are to be issued(i.e. non-exclusive spectrum licences, FCFS, spectrum auction, etc.). 29. In the Consultation, the Department offers three authorization options: radio licences, spectrum licences or licence exemption. 30. Fixed links in the Bands accommodate high capacity systems. Radio licence fees have a cost structure that is based upon fixed link throughput. As a result, high capacity fixed links in the Bands will drive high spectrum fees. High spectrum fees will jeopardize the business case of any proposed fixed link system. Further, the need for radio licences for each link would require a higher level of administration for both the Department and licensees. Radio licensing is therefore less efficient than other alternatives. 31. Rogers understands that the licence exemption approach assumes no spectrum fees and no frequency coordination. Although the risk of harmful interference in the Bands is less than that of alternate bands that are comprised of lower frequencies, Rogers believes that some form of frequency coordination will be required in order to minimize the risk of harmful interference and to ensure that the necessary operational performance standards will be met to support the high quality of service required by these high-speed transport facilities.

9 Rogers Communications Partnership Page The spectrum licence approach offers a balance between licensing which will prevent harmful interference and a light level of administration. 33. Given the above observations, Rogers believes that the most appropriate authorization approach for the Bands would be the spectrum licence model, which offers a balance of protection from harmful interference and a light licensing approach. 34. In terms of a licensing mechanism, Rogers recommends that the Department adopt a First-Come, First-Served (FCFS) process with a non-exclusive spectrum/area licensing approach. This process will facilitate the timely and cost-effective acquisition of spectrum licenses for fixed links. Whichever mechanism is chosen, it is important that the fee structure supports a high level of deployment and band utilization. Rogers is concerned that, if the current fee schedule used for fixed point to point bands is used, this spectrum will not be an economical candidate for broadband backhaul. For example, under the current fee schedule a link with 1GHz bandwidth would attract annual spectrum fees of $13,456. This is based upon the calculation of 15, khz voice channels (BD code) multiplied by 4 (to account for transmit and receive at each end of the link)). This is in excess of 650 times more than the fee proposed by the RABC which is based on Ofcom s light licensing regime. 35. Rogers strongly recommends that the Department harmonize its fixed point-topoint backhaul spectrum fees with the more reasonable fees that are currently used in other major jurisdictions such as those in the U.S. or U.K. In the event that any such harmonization cannot be completed in the near term, Rogers urges the Department to waive fees associated with the 70/80/90 GHz bands to facilitate deployment of fixed links in the bands. 36. In order for link deployment to be cost effective, Rogers proposes that the annual fee be based upon utilized bandwidth and reflect a cost recovery mechanism. 37. As a means of encouraging efficient use of the spectrum, Rogers recommends that the licensee be required to place each registered link into service within twelve months from the date stamp of the registration.

10 Rogers Communications Partnership Page 8 Comments are also sought on the option to allow independent band managers to oversee useraccess and coordination within these bands. 38. In the Consultation, the Department has proposed that independent band managers could be assigned responsibility to facilitate and manage access to the Bands. 39. As stated above, Rogers believes that some form of light licensing should be implemented in order to prevent the possibility of harmful interference. 40. However, Rogers does not support the concept of independent band managers that are licensed as a result of winning a competitive selection process, especially if these parties will be permitted to impose any form of fees upon the licensees. The risk involved with the band manager charging fees to the licensees is that the band managers will seek to earn a profit by charging higher fees than would be applied to merely recover the cost of managing the spectrum. This would unreasonably inflate the fees charged to spectrum users. As stated above, a high fee structure will jeopardize the business case of a proposed fixed link system and will discourage the use of this spectrum to support new and innovative services, including mobile broadband services. Conclusions 41. Rogers strongly supports making the bands GHz, GHz, GHz and GHz available for point-to-point fixed links use, in order to construct fixed links for our evolving and growing broadband networks. 42. Rogers supports a frequency division duplex (FDD) band plan arrangement such as the European CEPT Recommendation. This arrangement will permit the aggregation of channels to support higher capacities when needed. 43. The risk of harmful interference in these Bands must be minimized through measures such as frequency coordination and interference analysis prior to the construction or modification of a fixed link system that utilizes the Bands. For these reasons, uncoordinated deployment of the Bands should not be permitted. 44. Rogers supports the use of the European CEPT technical specifications listed in EN and in EN , which will facilitate the availability of 70 GHz and 80 GHz infrastructure in Canada. 45. Rogers believes that the most appropriate authorization approach for the Bands is the spectrum licence model, which offers a balance of protection from harmful interference and a light licensing approach that reduces administrative overhead. Rogers supports the use of a First-Come, First-Served process with a non-

11 Rogers Communications Partnership Page 9 exclusive spectrum/area licensing approach. 46. Rogers does not support the concept of independent band managers that are licensed as a result of a competitive selection process. Rogers believes that this may unreasonably inflate fees charged to spectrum users, which will jeopardize the business case of proposed fixed link systems and will discourage the use of the Bands to support new and innovative services. 47. Rogers Communications Partnership appreciates the opportunity to provide comments to this important consultation.