Rogers Communications 333 Bloor Street East Toronto, Ontario M4W 1G9 Tel. (416) 935-7211 Fax (416) 935-7719 rwi_gr@rci.rogers.com Dawn Hunt Vice-President Regulatory May 24, 2013. Sent via email: spectrum.engineering@ic.gc.ca Manager, Fixed Wireless Systems Industry Canada 19 th Floor, 300 Slater Street Ottawa, Ontario K1A 0C8 Re. Canada Gazette, Part 1, December 22, 2012, Consultation on Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum in Various Bands, Including Bands Shared With Satellite, Mobile and Other Services (SMSE-018-12) Pursuant to the procedures outlined in the above noted document, the attached reply comments are filed on behalf of Rogers Communications ( Rogers ). The document is being sent in Adobe Acrobat X Pro version 10. Operating system: Microsoft Windows 7. Sincerely, Dawn Hunt DH/sh Attach. WIRELESS DIGITAL CABLE INTERNET HOME PHONE RETAIL PUBLISHING BROADCASTING
Reply Comments of Rogers Communications Consultation on Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum in Various Bands, Including Bands Shared with Satellite, Mobile and Other Services (SMSE-018-12) May 24 th, 2013
Rogers Communications Page 1 Executive Summary E1. In our comments, Rogers supports Industry Canada s proposals to release more spectrum for backhaul and for encouraging greater spectrum efficiency. With the rapid advancements in technology, it is only appropriate that Industry Canada update its policies related to backhaul spectrum in various bands. This consultation is a very positive development for all users of backhaul spectrum. E2. Ensuring the availability of adequate amounts of backhaul spectrum is central to supporting the roll-out of mobile broadband across Canada. A number of suggestions are made with regard to what bands are most desirable based on existing equipment and international decisions. Key bands identified for microwave backhaul include the 4 GHz, 7 GHz, 8 GHz, 32 GHz and 42 GHz bands. E3. A number of the telecommunication carriers call on the Department to postpone making any decision regarding backhaul in the 3.5 GHz band until there has been a consultation on the use of this band for mobile services. However, the organisations representing the utilities industry have requested preferential access to this band. Based on the possible intended action of the Department as communicated in the Commercial Mobile Spectrum Outlook, Rogers believes these requests are premature. E4. The importance of spectrum efficiency is identified in many of the submissions, and recommendations are made on how to achieve this which include; allowing wider channels, and relaxing antenna restrictions. There is general consensus that the definitions of capacity are outdated and need to be revised. E5. There are a few issues highlighted in the submissions which require further input and study. These include updating the GDP guideline, as well as changing the current licence fee structure for backhaul spectrum. While Rogers recommends that backhaul licence fees should be addressed in a separate consultation, we maintain that any licencing structure should encourage the most efficient use of fixed service spectrum.
Rogers Communications Page 2 Introduction 1. Rogers Communications Rogers is pleased to provide the following reply comments in response to comments filed by other parties regarding the Consultation on Spectrum Utilization Policies and Technical Requirements Related to Backhaul Spectrum in Various Bands, Including Bands Shared with Satellite, Mobile and Other Services. 2. Rogers stated its position on all of the issues raised in the Consultation Paper in its initial comments of April 22, 2012. This reply is therefore primarily limited to comments on proposals made by other parties. 4.2 Backhaul Spectrum in Support of Fixed and Mobile Broadband 3. Rogers filed its comments on this section in confidence; however some of the other submissions were not classified as such. Rogers would like to take the opportunity to respond to a suggestion from the CBC. The broadcaster proposes that Industry Canada add additional 24 MHz bandwidth for TV pick-up in the 2025-2110 / 2200-2285 MHz frequency band. 1 This block is adjacent to the AWS band. At the December 2012 quarterly meeting, the RABC recommended that the Department review SRSP-302 to address sharing issues between fixed service and adjacent AWS service. If the Department decides to positively respond to CBC s request, Rogers would respectfully request that it be mindful of existing users of the AWS band. 4. Rogers also requests that the Department undertake necessary measures to manage any potential interference issues and update, as required, SRSP-302 to cover sharing issues between TV pick-up and adjacent AWS services. Any guard band that may be required to prevent interference between broadcasting and AWS services should be sourced from the 24 MHz that the CBC has requested in its comments. 5. Additionally, the CBC states in its response that despite the fact its Live U service is using cellular technologies, these are not capable of efficiently sending high definition video to the broadcaster s studio during a big event. 2 Although Rogers isn t aware of which cellular technology is being used, it is worth noting that LTE technology is capable of significantly higher data speeds and lower latency over existing cellular technologies. LTE is currently being deployed across Canada and could better support services such as Live U in some instances. Rogers recommends that the Department take this into consideration before granting CBC s request to allocate additional spectrum to TV pick-up within the 2025-2110 / 2200-2285 MHz frequency band. 4.2.4.1 Geographical Differences Policy Guideline (GDP guideline) 6. In our response, we outline the benefits and limitations of the GDP guideline and call on the Department to undertake a more detailed analysis. This approach is also suggested by the RABC 3 and SaskTel. SaskTel recommends a full review of the process by the Department, 1 CBC Comments, p.2. 2 CBC Comments, p.2. 3 RABC Comments, p.11.
Rogers Communications Page 3 with possible inclusion of outside consultants. 4 We would re-iterate our support for such a review. 5.1 4 GHz Band (3700-4200 MHz) 7. We explained in our comments that we are interested in the deployment of heavy route backhaul in the 4 GHz band. This position is also advocated by Shaw and Telus who, if the band became available, would use it for heavy route backhaul to support rural locations. 5 However, we note in our response that the Department should hold off making any decisions related to the 3.5 GHz band for backhaul until Industry Canada has undertaken a consultation on the allocation and use of the band for mobile. This position is supported by Telus and Bell. Bell strongly urges the Department to not make any decision on the use of the 3.5 GHz band for backhaul use until such time that the Department has initiated its consultation on the use of this band for mobile services. 6 8. Rogers notes that both the Canadian Electricity Association (CEA) and the Utilities Telecom Council of Canada (UTCC), in response to question 5.18 request that the Department consider providing utilities with preferential access to the 3550-3650 MHz band. 7 Rogers would respectfully point out that the primary use of this band is for fixed wireless access (FWA) applications. Furthermore, as noted in the Commercial Mobile Spectrum Outlook that was published in March 2013, Industry Canada may undertake a consultation to review the current allocation for this band. Based on the Department s potential future actions with respect to this band, Rogers submits that it is premature for the utilities to make any request for the 3.5 GHz spectrum. As we state in our comments, Rogers urges the Department to refrain from making any changes to the use of this band until it has completed its consultation on the potential future use of the band for mobile services. 5.2 6930-7125 MHz 9. The RABC response recommends expanding SRSP 306.4 to include SRSP 306.5 covering the band 6590-6770 and 6930-7125 MHz. 8 It also suggests that the whole band should be re-channelized for two-way backhaul. We note that this position is supported by Telus who views this as a high-priority need which should be addressed as expeditiously as possible. 9 Rogers also supports this, as the proposal aims to maximise the use of this spectrum. 5.3 7 GHz Band (7125-7725 MHz) 10. In our submission we call for maintaining the terms laid out in the existing SRSP, and request that the band be opened up for others to access. Rogers would like to express concern with regard to spectrum efficiency. The UTCC submission notes that Industry 4 SaskTel Comments, paragraph 20. 5 Shaw Comments, paragraph 26 & Telus Comments, paragraph 11 & 12. 6 Bell Comments, paragraph 12 & Telus Comments, paragraph 13. 7 CEA Comments, page 5 and UTCC Comments, page 9. 8 RABC Comments, page 15. 9 Telus Comments, paragraph 15.
Rogers Communications Page 4 Canada has provided utility companies with preferential access to 30 MHz channels in this band since 1977. 10 The submission also references the use of multiple legacy analog microwave radios in this band. In the 36 years since the preferential allocation decision there have been considerable improvements in technology. Rogers requests that Industry Canada ensure that all users of this band are taking advantage of new technology to maximise the efficient use of this spectrum. As submitted in our comments, we are in favour of preferential access in the name of the provision of essential services, but if this access is discouraging an efficient use of spectrum, it should be reviewed. 11. BC Hydro makes a similar request to UTCC. It asks Industry Canada to provide it with preferential assignment of eight 30 MHz frequency pairs in the 7 GHZ band and further frequency allocations in the 8 GHz band. 11 As noted above, we recommend that Industry Canada ensure that all holders of spectrum have exhausted the use of their existing allocations before being granted further spectrum. Advances in technology, as well as improvements in antennas and power management allow spectrum to be used more effectively. Industry Canada should ensure that all users of existing spectrum are implementing necessary measures to ensure spectrum efficiency before any new spectrum is allocated. 12. The submission from CEA includes a request to be permitted use of frequency diversity as needed in the 7, 8 and 11 GHz bands. 12 While the 11 GHz band is not directly addressed in this consultation, Rogers would like to draw attention to SRSP-310.7 (Standard radio System Plan for 11 GHz band) which contains some guidance on protection channels for the 11 GHz band. The relevant sections read; 4.6.1 One protection channel is normally permitted for HC systems with more than one working channel. 4.6.2 For single channel systems, protection channels are normally not permitted. However, quad-path diversity applications will be considered on a case-by-case basis to solve special propagation problems. 13. This SRSP does permit the use of additional frequency or channels for protection for high capacity systems with multiple channels running in parallel on the same hop. However, for single channel systems it is only considered in special cases to solve special propagation problems. 14. It is the opinion of Rogers that the use of quad diversity (space diversity combined with frequency diversity) is not warranted in the 11 GHz band, especially when there is increasing demand for use of this band. Space diversity is already a powerful technique to combat propagation problems and while there could be circumstances where its use may be considered in the 11 GHz band, such as over very long or highly reflective paths, adding frequency diversity to this would be an extreme and unnecessary measure. Given the propagation properties of the 11 GHz band, the performance improvement of quad diversity versus space diversity on the same path would be insufficient to justify such an inefficient use of spectrum. 10 UTCC Comments, page 6. 11 BC Hydro Comments, page 1. 12 Canadian Electricity Association Comments, page 2.
Rogers Communications Page 5 15. Shaw also indicates concerns with frequency diversity saying that frequency diversity takes up more bandwidth than required for a system to work properly because it uses a second channel that could be used by another carrier 13 and that frequency diversity should be discontinued by the utilities in the 7 GHz band. 14 5.4 8275-8500 MHz 16. Quebecor, in its submission calls for opening up the 8 GHz band to alleviate some of the congestion in the upper 6 GHz band. 15 Quebecor also requests that channels of a minimum bandwidth of 20 MHz be permitted. Furthermore, the RABC submission indicates that it could be possible to use existing equipment based on the ITU standard in the band 8275-8500 MHz. 16 Rogers concurs with the proposals to open this band as it will support the deployment of LTE and LTE Advanced technologies. 5.7 31.8-33.4 GHz 17. The 32 GHz band represents another valuable source of backhaul spectrum. With equipment readily available, we, along with others including Quebecor and Mobilicity are in favour of using this band should it become available. 17 18. Mobilicity notes that, dependent on equipment being available it would likely be in a position to fully utilize these bands if and when they are made available to microwave backhaul and that it expects that these bands may become a more efficient substitute to the highly congested 23 GHz links. 18 19. Aviat Networks calls for link by link licensing in the 32 GHz band. 19 The rationale given for this is to avoid tying up large amounts of spectrum for exclusive use. Rogers sees no justification for this approach as we are not aware of any instance of spectrum hoarding. In our experience, before we are assigned any new block of spectrum, we have to provide Industry Canada with a detailed explanation and justification of our requirements. 20. The 32 GHz band has similar propagation characteristics to the 38 GHz band, so we urge Industry Canada to implement the same licensing structure that is used in the 38 GHz band, i.e. on a spectrum grid-cell basis. This would permit more efficient management and coordination, which promotes the maximum utilization of the spectrum. Telus makes a similar suggestion for the 42 GHz band, which is covered in paragraph 22. While Rogers supports the current fee structure for the 38 GHz band, we would urge Industry Canada to include the 32 GHz and 42 GHz bands in any future consultation on license fees. 13 Shaw Comments, paragraph 30. 14 Shaw Comments, paragraph 32. 15 Quebecor Comments, paragraph 31. 16 RABC Comments, p.18. 17 Quebecor Comments, paragraph 40 and Mobilicity Comments, paragraph 33. 18 Mobilicity Comments, paragraph 33. 19 Aviat Networks Comments, p.3.
Rogers Communications Page 6 5.9 40.5-43.5 GHz 21. One of the motivating factors behind this consultation is the desire of Industry Canada to identify additional spectrum for backhaul use to support the growing demand for mobile broadband services. The 42 GHz band represents a significant amount of spectrum suitable for backhaul and helps meet the intended goal of the consultation. Rogers and others including Quebecor, RABC, Telus and TeraGo Networks have expressed interest in the appropriateness of this band for microwave backhaul to support dense deployment as well as LTE and LTE Advanced technologies. 20 22. Telus recommends that the Department implement a similar licensing mechanism as that used for the unallocated portion of the 38 GHz band (i.e., FCFS applied on a geographic basis) as per the CPC-2-1-17 policy, given its similar propagation characteristics. Exclusive allocation on a FCFS basis within a constrained geographic region would permit selfcoordination and management, thus facilitating rapid deployment of links, which would particularly support dense urban deployment. 21 Rogers agrees with this approach as it maximises the use of the spectrum, which is the intended outcome of this consultation. It also helps meet increasing demand for small cell deployments in urban areas. We also support this approach for the 32 GHz band (see paragraph 20). 23. EchoStar suggests that Industry Canada s proposal for the 42 GHz band is inconsistent with the arrangement between Canada and US on rules that were made over a decade ago with regard to use of this band by the FS and FSS. 22 The suggestion that a change of policy is inconsistent with Canada s past commitments to this band somehow infers that it isn t the role of the Department to update policy. However, we would submit that it is a central role of Industry Canada to acknowledge that the technical landscape has evolved dramatically in recent history. It is also the Department s responsibility to review rules that were made 11 years ago and update them to reflect current and future needs. 24. As the RABC notes, ETSI standard point-to-point equipment is currently available for the band, so there is no reason for further delay in the use of this band for microwave backhaul. 23 Rogers and others such as Mobilicity and Quebecor could start using this band in a short timeframe. 24 Telus further suggests restricting fixed system deployments in this band to point-to-point links and proposes the allocation of large channel sizes for this band. 25 This is consistent with Rogers comments. 5.10 Additional Backhaul Spectrum 25. There is general consensus amongst the submissions from the telecommunications companies calling for a review of the bands 21.6-21.8 GHz and 22.8-23.0 GHz, as well as the bands 21.2-21.6 GHz and 22.4-22.8 GHz. In addition to our support, RABC and TeraGo Networks suggest this, as does Telus, who identify a potentially large amount of available 20 Quebecor Comments, paragraph 42 & 43, RABC Comments, p. 26, Telus Comments, paragraph 27 and TeraGo Networks Comments, page 12. 21 Telus Comments, paragraph 28. 22 EchoStar Comments paragraphs 13 and 16. 23 RABC Comments, p. 26. 24 Mobilicity Comments, paragraph 35, Quebecor Comments, paragraph 43 & 44. 25 Telus Comments, paragraph 25.
Rogers Communications Page 7 spectrum and calls for this band to be reviewed as a matter of priority. 26 Telus recommends that the Department should adopt the policies established for 38 GHz in the CPC -2-1-17 27, an approach which Rogers endorses. 26. Both the CEA and the UTCC call for preferential access to the 3.5 GHz band. 28 Rogers believes that this is premature and has addressed this issue in our response to question 4.6 (paragraph 10). 6.1.1 Spectral Efficiency 27. Rogers calls on Industry Canada to devise a fee structure that encourages the most efficient use of fixed services spectrum. We recommend that the Department undertake a consultation to specifically address backhaul spectrum fees. Rogers believes that any licence fee should encourage the most efficient use of spectrum and not reward those who use spectrum inefficiently. Telus echoes this view by stating that the existing licence fee structure does not promote spectral efficiency. It makes it cheaper to licence a new channel than upgrade an existing link. 29 28. Our initial submission doesn t contain any details on what a new license fee structure should look like, as we believe it should be addressed in a separate consultation. However, some of the responses by other parties make requests related to fees. For example, TeraGo Networks suggests that license fees in the 24/38 GHz band should only apply to those that have not deployed in those bands, but should not extend to those who have put the spectrum to use. 30 Rogers would respectfully submit that such a request would be best considered in a separate consultation regarding backhaul spectrum fees. 29. ABC Communications proposes that licence fees should be priced based on congestion, such that prices should be higher in highly congested areas and lower in uncongested areas. 31 Rogers opposes ABC s proposal. As we explain in our comments, backhaul spectrum fees should be set at a level that encourages the efficient use of backhaul spectrum. Operators that use spectrum efficiently should not be penalized for the fact that a given geographic area is congested. We fully support measures to address congestion and advocate spectrum efficiency, but we do not foresee a situation in a congested area where Rogers wouldn t already maximise the efficiency of available spectrum. In any event, as stated in the paragraph above, Industry Canada should undertake a specific consultation on backhaul spectrum fees. 30. SaskTel suggests that the best method to encourage the use of smaller bandwidths is to base license fees directly on the amount of radio frequency used. 32 In other words, the more you use, the more you should pay for. If by smaller bandwidths SaskTel means that fees should encourage operators to use spectrum as efficiently as possible, then Rogers supports this. However, if SaskTel is suggesting that the Department should encourage the use of narrow bandwidths rather than the use of wide bandwidths, then Rogers does not 26 RABC Comments, p.27, Telus Comments, paragraph 30 and TeraGo Network Comments, p. 13. 27 Telus Comments, paragraph 30. 28 CEA Comments, page 5 and UTCC Comments, page 9. 29 Telus Comments, paragraph 26. 30 TeraGo Network Comments, paragraph 8. 31 ABC Communications Comments, paragraph 32. 32 SaskTel Comments, paragraphs 34 and 35.
Rogers Communications Page 8 agree with SaskTel. As we explain in our comments, operators need wider channels to facilitate LTE deployments and faster mobile broadband speeds. The RABC response also references the need for wider channel bandwidths to accommodate higher data transmission capacities. 33 If SaskTel is seeking to discourage changes to policy that will allow for wider channels this would be in contradiction to one of the key backhaul requirements identified by Rogers and other parties in this consultation. LTE and LTE Advanced technologies require wider channels and they represent a much more efficient use of spectrum compared to older technologies. 31. A change in policy to allow for wider channels is supported by a number of submissions including the Electro -Federation Canada, Shaw and Quebecor. 34 The Electro-Federation Canada submissions states that newer equipment is capable to support larger channel bandwidth so there is no reason for Industry Canada not to allow for channel sizes of 10-40 MHz. 32. With regard to updating the capacity definitions, there was broad consensus that they are out of date and need to be revised. Rogers recommends the following: Low capacity Medium capacity High capacity < 150 Mbps > 150 Mbps, < 500 Mbps > 500 Mbps 33. Shaw suggests a different set of definitions for capacity, with the following ranges: low capacity between 1.544 and 51.840 Mbps, medium capacity between 51.840 and 155.008 Mbps and high capacity greater than 155 Mbps. 35 Based on the rapid change in technical innovation and demand for data, we expect that these numbers would need to be revised again in just a few years. We would request that Industry Canada set higher levels, such as those recommended by Rogers. 6.1.2 Antenna Standards 34. Rogers supports changes to antenna policies and standards and notes that CBC, in its response suggests that in congested markets, the antennas used should be full size to avoid any interference. 36 For the reasons that Rogers has already explained, there is a greater need for smaller antennas in urban areas to support small cell LTE deployments. Quebecor and Shaw support Canada harmonising its antenna standards with the U.S. FCC. 37 We therefore urge the Department to reject CBC s proposal regarding full size antennas. 33 RABC Comments, p. 37. 34 Electro-Federation Canada Comments, p.1, Quebecor Comments, paragraph 45 & Shaw Comments, paragraph 23. 35 Shaw Comments, paragraph 45. 36 CBC Comments, p. 12. 37 Quebecor Comments, paragraph 56 and Shaw Comments, paragraph 49.
Rogers Communications Page 9 6.2 Department Publications 35. Rogers supports Shaw s request for flexibility to those that wish to convert their existing analog systems to a digital system utilizing the same amount of bandwidth as the analog system. 38 We support this with some conditions. Rogers does not support any mandatory conversion of Studio-to-Transmitter links (STLs) from analog to digital. As outlined in our initial submission, all broadcasters use microwave frequencies to run STLs and for Live Eye news production, used to feed breaking news back to the studio for integration into news production. Broadcasters run STLs and Live Eye news on analog and digital transmitters. Depending on the situation, one type of transmission will perform better than the other. Having this flexibility is crucial to the provision of this service. In addition, the mandatory conversion of analog STLs to digital would be very costly for STL operators. We note that no proposal has been made by the Department or any other party to require that analog STLs be converted to digital transmission but the importance of this issue requires us to state our position. 36. With respect to Live Eye news production, Rogers also requires the flexibility to transmit via analog or digital technology. This is primarily a technical reason, as digital technology cannot match analog s ability to transmit over significant distances. Unlike STL, which is a fixed point-to-point application, Live News can occur anywhere; in urban, semi-urban or very remote areas. At the moment digital is best suited for short haul use within the boundaries of a city, whereas analog can provide both short haul and long haul as far as 60 km. Based on these technical reasons broadcasters must have this flexibility of using digital or analog, to provide breaking news or coverage on matters of public health, safety and security. *** End of Document *** 38 Shaw Comments, paragraph 54.