LMDS: A WASHINGTON PERSPECTIVE

1
Spectrum Management 2006 Industry Association
Roundtable Paul J. Sinderbrand Wilkinson Barker
Knauer, LLP 202.783.4141 psinderbrand_at_wbklaw.com

2
Wireless Communications Association

• Represents Wireless Broadband Service Providers
  and Manufacturers
• Primary Current Focus
• 700 MHz
• WCS
• BRS/EBS
• 24 GHz, LMDS and 39 GHz
• Above 70 GHz

3
2004 2.5 GHz Restructuring
FORMER PLAN
4
2.5 GHz Benefits of Rebanding

• Accommodate demand for high-power video and data
  transmissions in MBS
• De-interleaved Lower Band Segment (LBS) and Upper
  band Segment (UBS) provide large, contiguous
  blocks of spectrum with good upstream/downstream
  separation and natural pairings
• Separate video from cellularized data to protect
  both against interference
• Flexible use technical rules allow FDD and TDD to
  coexist but require innovative approaches to
  avoidance of interference

5
Flexibility/Protection

• Adjacent Channel Interference
• Standard 43 10 log (P) spectral mask not
  sufficiently protective when non-synchronized
  technologies involved
• WCA proposed dual mask
• 43 10 log (P) certification mask
• 67 10 log (P) dB operational mask measured 3
  MHz and beyond, but only upon request of other
  licensee in market, who must also meet tighter
  mask
• FCC adopted dual mask, but 4/27/06
  Reconsideration Order confirms protection only
  upon showing of documented interference and
  after day 60 period
• And, FCC limited complaints to first adjacent
  channel licensee despite acknowledging that
  threat can come from beyond first adjacent channel

6
Flexibility/Protection

• Cochannel Interference
• Limiting signal strength at boundary to 47 dBµV/m
  does not protect base station from interference
  by non-synchronized cochannel base station
• Height benchmarking provides additional
  protection against base-to-base interference
• If height of antenna above average terrain along
  the radial between stations exceeds D²/17,
  station is outside of height benchmark
• Base station exceeding benchmark must restrict
  received signal level to -107 dBm or less at base
  station that is within benchmark
• 4/27/06 Reconsideration Order fails to address
  debate over process for relief how long must
  interference be suffered?

7
2.1 GHz BRS Relocation

• Relocation of BRS 1 and 2 4/21/06 Ninth Report
  and Order in ET Docket No. 00-258
• FCC limits relocation obligation to cochannel AWS
• Adjacent channel interference must be cured by
  AWS, but only after the fact jeopardizing
  existing operations!
• Comparable facilities need not be wireless
• Rules do not sunset for 15 years, but
• BRS is not compensated for increase in throughput
  during interim
• Nor can BRS self-relocate and then increase
  throughput
• Responsibilities governing involuntary relocation
  are not clearly spelled out

8
3650-3700 MHz

• 3/16/05 RO in ET Docket No. 04-151
• Innovative licensing system
• Unlimited number of nationwide licenses for
  entire 50 MHz
• Equipment must employ some contention based
  protocol
• Each higher power fixed and base station must be
  registered with FCC prior to use
• Unregistered low power mobile and portable
  stations permitted but must be authorized by a
  registered base station

9
3.6 GHz Interference Rules

• Govt radiolocation 80 km coordination zones
• FSS 150 km circular protection zones
• Intra-service protection
• Each terrestrial licensee must consult database
  prior to registration and make every effort to
  ensure that contemplated location and
  parameters will minimize the potential to cause
  and receive interference
• Yet, no terrestrial licensee is entitled to
  interference protection from another
• And, each terrestrial licensee must cooperate to
  avoid interference to others, even those that
  come later in time

10
3.6 GHz The Problems

• FSS protection too conservative
• Contention based protocol requirement doesnt
  avoid interference
• Interference rules deter investment
• every effort vs. no protection
• Obligation of first in to resolve interference to
  newcomers

11

• THANK YOU!
• Paul J. Sinderbrand
• Wilkinson Barker Knauer, LLP
• 202.783.4141
• psinderbrand_at_wbklaw.com