FiberTower Ex Parte Notice and mmWave Security Attachments for the Spectrum Frontiers Proceeding GN Docket No. 14-177

Notice of Ex Parte Filing - Use of Spectrum Bands Above 24GHz for Mobile Radio Services GN Docket No. 14-177 filed March 28, 2016.

On March 24, 2016, Joseph Sandri and Christopher Naoum of FiberTower Spectrum Holdings, LLC (“FiberTower”), along with Douglas Brandon and Steven Rowings of Akin Gump Strauss Hauer & Feld LLP, met with the following staff of the Federal Communications Commission (“Commission”) in the above-captioned proceeding: John Schauble, Brian Regan, Tim Hilfiger, Simon Banyai, Catherine Schroeder, Nancy Zaczek, and Matthew Pearl of the Wireless Telecommunications Bureau; Serey Thai of the Office of Engineering and Technology; Jose Albuquerque of the International Bureau; and Ahmed Lahjouji of the Public Safety and Homeland Security Bureau.

In the meeting, FiberTower discussed the importance of ensuring the resiliency and security of 5G networks deployed over the millimeter wave (“mmW”) band spectrum, as described more fully in the attached materials. In particular, FiberTower emphasized the need for mission-critical networks to be physically diverse and independently powerable to ensure ongoing operations in the event of natural or manmade disruptions to a portion of the network. FiberTower also discussed the measures that can be taken to ensure that 5G communications are physically secure, such as by exclusive licensing to prohibit use of certain frequencies by any party other than the licensee and by unique device configurations that preclude access to the communications by devices outside the network. FiberTower and the staff then discussed the importance of encrypting the communications themselves to further ensure their security. Additionally, FiberTower discussed its support for the concept of “security by design,” and for the Commission’s setting of minimum security standards for the deployment of 5G networks to safeguard the mission-critical services that will be delivered over 5G.

To read the entire filing with all of the attachments click HERE.

FiberTower Reply Comments in the Above 24Ghz Spectrum Bands Notice of Proposed Rulemaking

REPLY COMMENTS OF FIBERTOWER SPECTRUM HOLDINGS, LLC

 

FiberTower Spectrum Holdings, LLC (FiberTower) hereby replies to the comments filed in response to the Notice of Proposed Rulemaking of the Federal Communications Commission (Commission) in the above-captioned proceeding.[1]  FiberTower urges the Commission to:

1)      Harmonize the wide-area, exclusively licensed millimeter wave (mmW) bands at 24 GHz, 28 GHz, and 39 GHz for flexible use[2];

2)      Make clear that flexible use licenses will allow the licensees to use TDD, FDD, or other technologies as equipment development and market demands dictate;

3)      Expand the established wide-area, exclusively licensed bands at 24 GHz, 28 GHz and 39 GHz into larger channel blocks.

4)      Avoid any delay from the creation of larger channel blocks to the ongoing flexible use of existing wide-area licenses in the 24 and 39 GHz bands.  Those bands already support gigabit and multi-gigabit fixed services under the current channel block scheme and can be used today for more robust portable and mobile applications;

5)      Allow incumbent and new licensees to work with each other to migrate, partition or disaggregate spectrum so that the market can dictate the most efficient  license sizes;

6)      Maintain the established, effective protections for terrestrial licenses from satellite interference to ensure that flexible use licensees are able to exploit the full reach of their licenses;

7)      Promote mmW backhaul as a policy priority so that 5G and broadband access services are able todensify at a rate that responds to market developments;

8)      Mandate long-established core network security protocols that have been neither widely nor uniformly implemented; and

9)      Finalize license area sizes, confirming that counties will be either the license size or the building blocks upon which larger license areas are based. 

Ample support exists in the record for all the above positions and the Commissions should adopt them quickly to provide the United States with a platform for establishing global leadership in the fast developing, inextricably intertwined, and economically critical mmW and 5G industries.

To read the entire comment filed February 26th 2016 Click HERE

 

[1] Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, et al., GN Docket No. 14-177, et al., Notice of Proposed Rulemaking, 81 Fed. Reg. 1802 (2015) (NPRM).  All citations contained herein are to the January 13, 2016 Federal Register publication of the NPRM.

[2] The Upper Microwave Flexible Use Service (UMFUS or flexible use) has been identified as a license authorization that allows the terrestrial licensee to operate fixed, portable and/or mobile services within the service area.

FiberTower Comments on the Above 24 GHz Spectrum Bands Notice of Proposed Rulemaking

COMMENTS OF FIBERTOWER SPECTRUM HOLDINGS, LLC

 

FiberTower Spectrum Holdings, LLC (FiberTower) hereby submits comments in response to the Notice of Proposed Rulemaking of the Federal Communications Commission (Commission) in the above-captioned proceeding.[1]  FiberTower firmly supports the Commission’s “aim to facilitate access to spectrum, develop a flexible spectrum policy, and encourage wireless innovation.”[2]  Flexible use in the millimeter wave (mmWave) bands will drive innovation and is paramount to U.S. competiveness as momentum grows toward the launch of 5G services, particularly on the high-frequency bands at issue in this proceeding.  Providing incumbent mmWave licensees with the ability to flexibly develop backhaul and broadband wireless access solutions will enhance global competitiveness and provide U.S. consumers with a key platform for ultimately receiving 5G services. 

It is thus imperative that the Commission use this proceeding to accord Upper Microwave Flexible Use Service (UMFUS) licensees the flexibility to respond to developments in technology, industry standards, and business cases for 5G in order that the U.S. wireless industry maintain its leadership role in the global market.  To accomplish this goal, the Commission should:  (1) Adopt its proposal to launch the UMFUS and allow for innovative, flexible use in the mmWave bands; (2) include the 24 GHz band in the UMFUS, as it is empirically proven as more than capable of supporting vital 5G services and would leverage the global development work already undertaken and available in that band, which can be applied to 5G; (3) adopt UMFUS service rules that appropriately balance the protection needs of incumbent licensees with the flexibility needed to continue development and innovation of mmWave technologies and services; and (4) take steps necessary to ensure the security, resiliency, and marketability of services in the UMFUS.

To read the entire comment filed January 27th 2016, click HERE.

 

[1] Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, et al., GN Docket No. 14-177, et al., Notice of Proposed Rulemaking, 81 Fed. Reg. 1802 (2015) (NPRM).  All citations contained herein are to the January 13, 2016 Federal Register publication of the NPRM.

[2] Id. at para. 3.

FiberTower Ex Parte Letter in the Use of Spectrum Bands Above 24 GHz for Mobile Radio Services Proceeding

Notice of Ex Parte Letter - Use of Spectrum Bands Above 24GHz for Mobile Radio Services, GN Docket No. 14-177 filed October 15, 2015.

FiberTower Spectrum Holdings, LLC (“FiberTower”) hereby submits this ex parte letter in the above-captioned proceeding to provide the Federal Communications Commission (“Commission”) with additional information on the capabilities of incumbent millimeter wave (“mmWave”) licensees, the degree to which these incumbents are positioned to meet demand for mobile services in the mmWave bands, and urges the Commission to consider these factors in adopting new service rules.

As detailed more fully below and in the attached presentation, base stations and corresponding remote fixed and portable terminals (and future handsets) in wide-area licensed mmWave bands exhibit certain essentially identical behaviors.  Future mmWave base stations will provide both mobile and fixed/portable services, and incumbent licensees are often already equipped with the technical ability to provide backhaul, transport or access for fixed, portable or mobile services in the 24 GHz, LMDS and 39 GHz bands.  Thus, should the Commission elect to revise the mmWave band service rules, these licensees should be permitted to offer mobile services throughout the geographic area of the incumbent’s license as customer demand and equipment development dictates.  Placing a new mobile licensee on top of the incumbent’s existing geographic area and channel would result in dual base stations saturating the same sector and cause harmful interference.


In addition, 24 GHz, LMDS, and 39 GHz point-to-multipoint (“PMP”) base stations already act to cover entire sectors.  For example, as noted in active operations, a properly placed 24 GHz PMP base station with a 90-degree sector antenna will blanket that sector with a serviceable signal for any remote terminal—whether fixed, portable or mobile—that is within line-of-sight and within a serviceable distance.  In fact, a remote terminal can, in many situations, also receive a non-line-of-sight signal.

As incumbent licensees well know, point-to-point (“PTP”) and multiple-point-to-point (“MPTP”) base stations must be carefully deployed and managed by the licensee with other PTP, MPTP and PMP operations that the licensee seeks to operate within the license area.  The operational rules for 24 GHz, LMDS and 39 GHz already provide incumbent licensees with the ability to actively deploy, manage and move base stations and remote terminals in accordance with customer needs, including the swift installation, de-installation, relocation and active movement of systems for event services, emergency management, video backhaul, data and voice backhaul, small cell and large cell services.  In other words, these systems already deploy in an essentially “mobile-like” manner, and the incumbent licensees have consequently developed expertise in meeting the requirements of “mobile-like” deployments.  The base station services a customer location that moves over time, and incumbent mmWave licensees are thus well-positioned to meet demand for mobile services in the band should the Commission alter the mmWave service rules to allow for provision of these services.

Additionally, the existing border interference standards, border coordination requirements, and power flux density limits have effectively ensured that these “mobile-like” fixed and portable services do not interfere with neighboring licensees.  Critically, however, creating a separate mobile license for operations within an incumbent 24 GHz or 39 GHz licensee’s geographic service area would cause harmful interference and unnecessary complications for both licensees.  It is both more spectrally efficient and simpler to provide the incumbent licensee with the ability to provide the mobile services as the market demands, given their expertise and capabilities, as detailed herein and in the attached.  These incumbent licensees are leading the way on developing mobile mmWave systems in cooperation with manufacturers and customers, and are thus in the best position to quickly and effectively meet demand for mobile services in the mmWave bands if and when the Commission elects to change the service rules for these bands.

Finally, 1Gbps deployments at 24GHz have been proven to need less than 150MHz of spectrum.  Last month’s CTIA Super Mobility 2015 conference, exhibitors displayed 4096 QAM systems which could further compress spectrum channel width needs for 1Gbps throughput. Thus a 200MHz wide block is indeed more than sufficient for some existing and future 1Gbps technologies.  

To read the entire Ex Parte Letter, complete with Macro Cell and Small Cell Diagrams, click HERE

FiberTower Releases "Wireless Fiber" Fact Sheet for Montgomery County ultraGig Partnership

Wireless Fiber Fact Sheet for ultraGig Partnership with Atlantech Online and Montgomery County, Maryland.

 

UltraGig: Gigabit ‘Wireless Fiber’

FiberTower Corporation and Atlantech Online have partnered to deliver the first exclusively licensed 24GHz full duplex 1 Gbps ‘wireless fiber’ link deployed in the Washington region, directly to the Silver Spring Innovation Center (SSIC).  This highly secure, exclusively licensed system is designed to federal physical-diversity standards.  It delivers a super-fast Gigabit connection to the SSIC conference rooms and tenants back to the Atlantech fiber network hub in downtown Silver Spring.

Broadband Video, Voice & Data: Boosting Local Business Development and Growth

  • Business growth depends upon the availability and convergence of high quality broadband for video, voice and data use.  
  • These connections offer high definition and high capacity interactive video and voice conferencing, as well as data intensive uploading and downloading.

Last Mile Connections to Underserved Buildings, Towers and Poles 

  •  By deploying “wireless fiber” high capacity links the county can enjoy last mile connections where such capacity is currently unavailable due to technical or economic challenges.  High-definition video editing and transfer, data-base connectivity and downloads and uploads, high-quality voice services and more are all possible over this technology.
  • 24GHz fully licensed fixed wireless connections can function as ‘wireless fiber extension cords’, extending the reach of existing fiber optic infrastructure and connecting additional customers, under-served office buildings and community anchor institutions.  This broadband extension cord service can be delivered through partnerships with local fiber companies and the county’s FiberNet fiber-optic network,
  • Small cell service can be delivered to buildings, light poles and other structures to provide the backhaul infrastructure for mobile networks, public safety networks and WiFi networks.  This means that broadband internet services can be supplied indoors or outdoors at under-served locations.

Physically Diverse Network (PDN) Connections – Avoid Outages

  •  A key way to avoid broadband outages is to bring Physically Diverse Networks (PDN) connections to a building or structure.  
  • PDN architectures require physical separation from the incumbent network at every point, including diverse ingress to and egress from the service premises, use of separate rights-of-way throughout the service area, and utilization of separate switching centers where the broadband connections terminate. [Sources: Bechtel Telecommunications Journal: Physically Diverse Networks Using Microwave; Pub. Law 108-447, Section 414]. 
  • Deployment example: The current Gigabit link installed between SSIC at 8070 Georgia Ave and Atlantech Online’s fiber hub at 1010 Wayne Avenue contains battery-based uninterruptable power systems in the event of a power outage and also can be individually powered through a generator system.  A secondary Verizon fiber connection to SSIC completes the physical diversity architecture. 


Fully Licensed 24GHz Spectrum Band

FiberTower is the sole holder of exclusively-licensed, wide-area 24GHz spectrum authorizations in the National Capital Region.   The choice of fixed wireless 24GHz spectrum for use in high capacity connections allows for:

  • Carrier-grade signal availability as high as 99.999 percent.
  • Fully licensed secure connections with built-in hardware security configurations and optional software encryption overlays that provide inherent privacy protections.
  • Macro cell and small cell backhaul connectivity to underserved poles, towers and buildings, typically 0-to-3 miles away via line-of-sight links.
  • Environmentally efficient solutions that often involve less disruption to road and earth surfaces.  Large numbers of broadband connections within dense urban campus areas, or a broadband supply line to a rural structure.
  • Spectrum usage authorizations within a short time period (weeks or months).
  • Economically viable broadband solutions for customers.
  • Reach unserved and under-served urban or rural locations: Service to a location where wireline, fiber, or another technology may not be technically or economically available. Examples, (i) bringing WiFi and broadband to an overlooked building or lightpole in an urban area; (ii) reaching across a railway or a river, where trenching or other obstacles exist. 

5G Mobile Access and Future Use

  • The wide-area licensed 24GHz band has also been validated for future broadband mobile access by numerous standards bodies, including technical studies and trials published by the IEEE Microwave Theory and Techniques Society.  5G networks using millimeter wave bands may offer 1Gbps to mobile handsets by 2020 [Sources: IEEE, Samsung, FCC].  
  • FiberTower Labs conducted the nation’s first successful 24GHz mobile and non-line-of-sight tests in early 2015 and published the findings in the ongoing Above 24GHz Mobile Broadband Notice of Inquiry (NOI) before the Federal Communications Commission.

Download our ultraGig SlideShow HERE

 About FiberTower

FiberTower Corporation (www.fibertower.com) is a privately-held company that provides broadband ‘wireless fiber’ connections between buildings and/or poles and towers.  It uses exclusively licensed spectrum to deploy its services, and also offers such spectrum for lease.  FiberTower is the leader in developing millimeter and microwave technology solutions.  

 

FiberTower Notice of Ex Parte regarding Use of Spectrum Bands Above 24GHz for Mobile Radio Services

Notice of Ex Parte - Use of Spectrum Bands Above 24GHz for Mobile Radio Services, GN Docket No. 14-177


On April 22, 2015, Joseph Sandri of FiberTower Spectrum Holdings, LLC (“FiberTower”), and FiberTower’s counsel, the undersigned and Benjamin Bartlett, met with the following Commission staff: John Leibovitz, Blaise Scinto, John Schauble, Stephen Buenzow (via telephone), Brian Regan, Charles Oliver, Tim Hilfiger, and Matthew Pearl from the Wireless Telecommunications Bureau; Michael Ha and Bahman Badipour from the Office of Engineering and Technology; and Howard Griboff and Robert Nelson (both via telephone) from the International Bureau. The discussions focused on the Commission’s Notice of Inquiry (“NOI”) exploring the use of spectrum bands above 24 GHz for mobile radio services. (1)


FiberTower discussed the points raised in its initial and reply comments in this proceeding, and also addressed a number of related questions from Commission staff.(2) In particular, FiberTower expressed its support for the NOI and the Commission’s focus on driving innovation and the development of next-generation mobile services in bands above 24 GHz. FiberTower urged the Commission to move expeditiously to permit mobile use of these bands, which will be critical to driving the research and development, and the resulting technological innovation, needed to fuel the creation of next-generation mobile services in the U.S.

(1)See Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, GN Docket No. 14-177, Notice of Inquiry, 29 FCC Rcd 13020 (2014).

(2) See Comments of FiberTower Spectrum Holdings, LLC, GN Docket No. 14-177 (filed Jan. 16, 2015); Reply Comments of FiberTower Spectrum Holdings, LLC, GN Docket No. 14-177 (filed Feb. 18, 2015).

To read the entire Notice of Ex Parte, click (HERE)

Reply Comments of FiberTower in 24GHz Advanced Mobile Service NOI

Reply Comments of FiberTower Spectrum Holdings LLC In the Matter of Use of Spectrum Bands Above 24GHz for Mobile Radio Service GN Docket No. 14-177

FiberTower Spectrum Holdings, LLC (“FiberTower”) appreciates the opportunity to submit reply comments in this important proceeding.  Initial comments filed by industry stakeholders and other interested parties reflect broad support for the Commission’s examination of the use of spectrum bands above 24 GHz for mobile radio services, while preserving and expanding existing fixed service deployments.  The next-generation mobile and fixed service initiatives are collaborative and inextricably intertwined.  For example, fixed service industry players have led the way in demonstrating that fixed service millimeter wave (“mmWave”) equipment can achieve broadband connectivity in both mobile and non-line-of-sight configurations.  By taking steps to permit mobile uses of these bands, the Commission has the opportunity to drive the critical investment, research and development, and innovation necessary to fuel the creation of Fifth Generation (“5G”) mobile services and meet the growing consumer demand for high-speed broadband.

Commenters agree with FiberTower that maintaining existing fixed wireless services – and providing existing and future wide-area mmWave licensees the ability to flexibly deploy fixed, portable, and mobile systems as market forces dictate (while observing border interference standards) – will be essential to enabling the successful development and deployment of advanced mobile solutions in the bands above 24 GHz.  Furthermore, development of existing fixed wireless technologies will be integral to expanding high-speed broadband service to currently underserved areas.  Accordingly, in addition to permitting mobile uses in bands above 24 GHz, it is essential to mobile development that the Commission adopt rules that protect, and encourage the further development of, existing fixed wireless technologies in these bands.  By so doing, the Commission will facilitate greater access to high-speed broadband services across the country, and ensure the U.S. remains a global leader in the development of next-generation mobile services in 5G and small cell markets.

To read the entire comment filed February 17th 2015 Click HERE 

 

 

Comments of FiberTower in 24GHz Advanced Mobile Services NOI

Comments of FiberTower Spectrum Holdings LLC In the Matter of Use of Spectrum Bands Above 24GHz for Mobile Radio Service GN Docket No. 14-177

FiberTower applauds the Commission for opening this proceeding to examine the use of spectrum bands above 24 GHz for mobile radio services.  Permitting mobile uses of these bands is critical to driving research and development, and the resulting technological innovation, which will fuel the creation of Fifth Generation (“5G”) mobile services in the United States.  There are key roles for designated licensed and unlicensed spectrum blocks.  As discussed in detail below, global leadership in 5G has yet to be fully determined, and much is at stake for the regions seeking to win the 5G mantle.  The conditions optimizing industry leadership in advancing innovative, market-demanded solutions in the millimeter wave spectrum bands are known, and they involve encouraging significant investment, research and development, and real-world product launches.  


To foster and accelerate this innovation and investment by FiberTower and other industry-leading stakeholders, the Commission should (i) permit mobile services in the wide-area, exclusively licensed bands (in particular, the 24 GHz through 39 GHz bands) using as guidance the same power flux density limit and border coordination standards already in place for the ongoing fixed wireless service operations in those bands; and (ii) adopt a regulatory framework that provides the flexibility necessary to facilitate and accommodate future innovations, as well as the regulatory predictability necessary to encourage industry investment.  This includes instituting license renewal policies that recognize significant investments in research and development, and innovative solutions for making millimeter wave services and spectrum widely available on a market-demand basis.  By so doing, the Commission can accelerate innovation and investment in the millimeter wave spectrum, and ensure that the United States remains the global leader in the development of cutting-edge broadband that supports next-generation mobile services and the infrastructure undergirding such services.    

 

To read the entire Comment filed January 15, 2015 Click HERE