Before the Federal Communications Commission

Washington, DC 20554

In the Matter of ) ) Comment Sought on Competitive Bidding ) AU Docket No. 20-34 Procedures and Certain Program ) WC Docket No. 19-126 Requirements for the Rural Digital ) WC Docket No. 10-90 Opportunity Fund Auction (Auction 904) ) To: The Commission

COMMENTS OF THE WIRELESS INTERNET SERVICE PROVIDERS ASSOCIATION

Louis Peraertz, Vice President of Policy

Stephen E. Coran Lerman Senter PLLC 2001 L Street, NW, Suite 400 Washington, DC 20036 (202) 416-6744 Counsel to the Wireless Internet Service Providers Association March 27, 2020

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Table of Contents

Introduction ..................................................................................................................................... 3 

Discussion ....................................................................................................................................... 3 

I.  THE COMMISSION SHOULD REQUIRE COMPETITIVE BIDDING BY CENSUS BLOCK GROUPS .............................................................................................. 3 

II.  THE COMMISSION SHOULD PROVIDE FURTHER GUIDANCE FOR APPLICANTS PROPOSING TO USE SPECTRUM ........................................................ 5 

III.  THE COMMISSION SHOULD NOT ADOPT ITS PROPOSED RESTRICTION ON APPLICANTS USING FIXED WIRELESS TECHNOLOGY FROM BIDDING AT THE GIGABIT TIER ......................................... 8 

A.  The Commission Should Not Rely on Outdated Information in its Assumptions About the Capabilities of Providers .................................................. 9 

B.  Allowing Fixed Wireless Applicants to Propose Gigabit Speed Would Promote the Commission’s Policy of Using RDOF Support for 5G Networks ............................................................................................................... 14 

IV.  THE COMMISSION SHOULD MAKE ADDITIONAL INFORMATION AVAILABLE TO BIDDERS ........................................................................................... 16 

Conclusion .................................................................................................................................... 17 

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Summary

Phase I of the Rural Digital Opportunity Fund (“RDOF”) holds great promise for millions

of rural Americans that lack access to adequate fixed broadband service. To advance its top

priority of bridging the digital divide, the Commission builds on the success of its Connect

America Fund (“CAF”) Phase II reverse auction to propose similar application and competitive

bidding procedures for the upcoming RDOF auction. That auction should not begin until the

Commission completes its auction for Priority Access Licenses in the Citizens Broadband Radio

Service, which is now scheduled to begin just three months before the RDOF Phase I auction.

The Wireless Internet Service Providers Association (“WISPA”) generally supports many

of the Commission’s proposals, including the use of census block groups as the minimum

biddable geographic unit. Maintaining census block groups, which the Commission used in the

CAF Phase II auction, will encourage flexibility by bidders that will be better able to target areas

suited to their deployment goals. Bidders desiring larger geographic areas can use census block

groups as building blocks in package bids.

WISPA is pleased that the Commission proposes to add spectrum, including millimeter

wave bands, to its non-exhaustive list in Appendix B. Other bands, such as the licensed CBRS

and 2.5 GHz bands and the unlicensed 5.9 GHz band, 6 GHz band and 37 GHz bands should be

permitted to be specified so long as the applicant provides alternatives if the spectrum ultimately

is not available. As it did for the CAF auction, the Commission also should clarify that renewal

of licenses and spectrum leases that expire during the support will be inferred.

WISPA strongly disagrees, however, with the Commission’s proposal to categorically

restrict applicants intending to use fixed wireless technologies from bidding in the Gigabit

performance tier if the applicant has not reported offering Gigabit service in its latest Form 477.

The Commission’s desire to avoid case-by-case review to streamline the processing of short-

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form applications directly contradicts the Commission’s standard of determining whether the

applicant is “reasonably expected to be capable of meeting the relevant public interest

obligations.” The Commission relies on Form 477 data, which will be nearly two years old by

the time the auction starts, to assume that the failure to report offering Gigabit service as of

December 31 2018 means that fixed wireless technology is not capable of providing gigabit

service now and during the 10-year support term. Under FCC Chairman Ajit Pai’s leadership,

this Commission held the Nation’s first-ever auctions involving millimeter wave spectrum. As

the Commission knows, this spectrum is capable of enabling Gigabit speed wireless broadband

service. The Commission’s actions have spurred investment and development of millimeter

wave radios, software, and other key elements to deploy this spectrum to underserved areas. As

examples in these Comments demonstrate, equipment is available today and fixed wireless

providers are offering Gigabit speed broadband services to consumers today. Prohibiting

applicants from proposing to use fixed wireless technologies to bid in the Gigabit performance

tier departs from the Commission’s practice of case-by-case review of short-form applications,

contradicts the Commission’s policy objectives of enabling fixed networks to be used for rural

5G backhaul, and short-changes rural Americans that might otherwise be beneficiaries of cost-

effective, fixed wireless Gigabit service.

WISPA supports the Commission’s proposal to make available to bidders the lowest T+L

weight of any bid where there are two or more bids at the clock percentage. With this additional

transparency, bidders with higher T+L can switch their bids to other areas where they would

have a greater opportunity to be the winning bidder, a result that will ensure that more rural areas

receive RDOF support.

Before the Federal Communications Commission

Washington, DC 20554

In the Matter of ) ) Comment Sought on Competitive Bidding ) AU Docket No. 20-34 Procedures and Certain Program ) WC Docket No. 19-126 Requirements for the Rural Digital ) WC Docket No. 10-90 Opportunity Fund Auction (Auction 904) ) To: The Commission

COMMENTS OF THE WIRELESS INTERNET SERVICE PROVIDERS ASSOCIATION

The Wireless Internet Service Providers Association (“WISPA”), pursuant to Sections

1.415 and 1.419 of the Commission’s Rules,1 hereby comments on certain of the proposals in the

above-captioned Public Notice seeking public comment on proposed requirements and

procedures for Phase I of the upcoming Rural Digital Opportunity (“RDOF”) reverse auction.2

WISPA supports the Commission’s proposed adoption of many of the auction procedures

that made the Connect America Fund (“CAF”) Phase II reverse auction successful, including its

decision to conduct bidding at the census block group level, and also generally supports the few

changes the Commission suggests to streamline application processing and to improve

transparency during the auction. However, WISPA strongly disagrees with the Commission’s

proposal to categorically restrict an applicant proposing to deploy fixed wireless technologies

from bidding in the Gigabit tier if it has not previously reported offering Gigabit service on FCC

Form 477s that are nearly two years old.3 As demonstrated below, circumstances have evolved

 1 See 47 C.F.R. §§ 1.415 & 1.419. 2 See Public Notice, “Comment Sought on Competitive Bidding Procedures and Certain Program Requirements for the Rural Digital Opportunity Fund Auction (Auction 904),” AU Docket No. 20-34 and WC Docket Nos. 19-126 & 10-90 (rel. Mar. 2, 2020) (“Public Notice”). See also 85 FR 15092 (Mar. 17, 2020) (establishing March 27, 2020 deadline for filing initial Comments). 3 See Public Notice at 16 (¶ 51).

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since the CAF auction. Under FCC Chairman Ajit Pai’s leadership, this Commission held the

Nation’s first-ever auctions for millimeter wave spectrum. As the Commission knows, this

spectrum is capable of enabling Gigabit speed fixed wireless broadband service. The

Commission’s actions have spurred investment and development of millimeter wave radios,

software, and other key elements to deploy this spectrum to underserved areas.

Fixed wireless providers are taking advantage of these new spectrum bands and the new

millimeter wave equipment that is being deployed today at Gigabit speeds. Allowing fixed

wireless service providers to demonstrate this, in their individual applications, will show how the

Commission’s actions have enabled this investment and innovation to bridge the digital divide.

Therefore, instead of imposing a categorical restriction based on a desire to streamline staff

review and on Form 477 data that is nearly two years old, the Commission should permit the

staff to review each short form application on its merits to determine whether it is “reasonably

expected to be capable of meeting the relevant public interest obligations.”4

In addition, the short-form deadline for the RDOF Phase I auction should occur after the

conclusion of the Citizens Broadband Radio Service Priority Access License (“PAL”) auction

now scheduled to begin July 23, 2020.5 It is expected that many bidders may seek to rely on

PALs won at auction to help meet their RDOF performance commitments. In some cases,

success in winning PALs will enhance the ability of RDOF applicants to bid at a lower-weighted

speed tier, a result that will direct more RDOF funds to supporting faster broadband speeds to

rural Americans.

 4 Id. at 16 (¶ 51). 5 See Public Notice, “Auction of Priority Access Licenses for the 3550-3650 MHz Band Rescheduled to Begin July 23, 2020,” AU Docket No. 19-244, DA 20-330 (rel. Mar. 25, 2020).

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Introduction

As an active participant in both the CAF and RDOF proceedings, WISPA applauds the

Commission for proposing auction procedures that build on the success of the CAF Phase II

reverse auction. A number of WISPA members were successful in obtaining CAF support, and

are now deploying their supported networks and investing their own capital and labor to bring

fixed broadband service to supported areas. Through the CAF auction experience, WISPA and

its members have garnered perspective on the application process and auction procedures to

inform WISPA’s comments in this proceeding. As a general proposition, there is no evidence

that the CAF processes are not working well to achieve the Commission’s policy objectives.

For this proceeding, WISPA therefore agrees with the maxim “if it ain’t broke don’t fix

it.” At the same time, however, WISPA understands that, given the greater scope of the RDOF

Phase I auction and the experience of Commission staff in reviewing short-form applications,

conducting the auction, vetting long-form applications, and overseeing the CAF program, certain

modest changes may be necessary to improve the process – but not at the expense of those that

should have the opportunity to bid at faster speeds that will benefit Americans residing in

RDOF-eligible areas. WISPA’s comments highlight the benefits of preserving bidding by

census block groups, permitting applicants proposing fixed wireless technologies to demonstrate

eligibility for the Gigabit tier, and providing more information to bidders during the auction to

enhance flexibility and direct support to more unserved areas.

Discussion

I. THE COMMISSION SHOULD REQUIRE COMPETITIVE BIDDING BY CENSUS BLOCK GROUPS

Consistent with its decision in the RDOF Order, the Commission proposes to conduct the

RDOF Phase I reverse auction for areas “no smaller than a census block group” as the minimum

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biddable geographic area.6 The Commission explains that “using census block groups provides

greater flexibility than relatively larger geographic areas, particularly for those bidders that

intend to expand existing networks or construct smaller networks.”7 The Commission also

estimates that there could be twice as many census block groups than were eligible for bidding in

the CAF Phase II auction and seeks comment on whether it should instead use census tracts as

the minimum biddable area.8

For a number of reasons, WISPA believes that the Commission should continue to use

census block groups as the minimum biddable area. First, census block groups will, as the

Commission suggests, encourage flexibility among bidders, who will be better able to bid for

smaller areas tailored to their deployment objectives. Using larger areas such as census tracts

will discourage auction participation because buildout costs will be higher, especially if the

unserved census blocks within the census tracts are geographically separated. In these cases,

bidders may decide to not bid at all, or bid at a higher T+L, or stop bidding at a higher support

level earlier in the auction. Second, those bidders desiring support in larger geographic areas can

take advantage of the package bidding rules the Commission proposes.9 Through package

bidding, bidders can use census block groups as building blocks for larger areas which may, or

may not, conform to census tracts that may artificially limit bidder flexibility. Third, because

many bidders will be focused on regional deployments, WISPA does not foresee “difficulties in

manipulating large bidding files” for 66,000 census block groups because RDOF Phase I bidders,

 6 See Rural Digital Opportunity Fund, Report and Order, WC Docket Nos. 19-126 and 10-90, FCC 20-5 (rel. Feb. 7, 2020) (“RDOF Order”) at 17 (¶ 30) (“We conclude that the minimum geographic area for bidding will be no smaller than a census block group, as identified by the U.S. Census Bureau, containing one or more eligible census blocks”). 7 Public Notice at 5 (¶ 11) (citation omitted). 8 Id. 9 Id. at 25-26 (¶¶ 86-89). 

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just as they were with the CAF Phase II auction, will be focused on a much smaller subset of

census block groups that correspond to achievable buildout commitments.10 Because they are

right-sized for both the RDOF Phase I auction and deployment, the Commission therefore should

adopt census block groups as the minimum biddable geographic area.

II. THE COMMISSION SHOULD PROVIDE FURTHER GUIDANCE FOR APPLICANTS PROPOSING TO USE SPECTRUM

The Commission asks whether the non-exhaustive list of spectrum bands listed in

Appendix B of the Public Notice “provide sufficient uplink or downlink bandwidth to support

the wireless technologies that a provider may use” to meet its performance obligations.11 As was

the case with the CAF Phase II auction, applicants should be permitted to demonstrate in their

short-form applications that the spectrum band or bands they identify can meet their proposed

T+L, and Commission staff should have the opportunity to determine whether “an applicant is

reasonably expected to be capable of meeting the relevant public interest obligations in a state.”12

There is no evidence to suggest that Commission staff will be unable to make this determination,

and its experience with reviewing CAF short-form applications should make its review more

efficient and expeditious.

Likewise, the Commission should implement its proposal to allow an applicant to specify

the use of spectrum bands involving auctions or other spectrum allocations if it indicates its

participation in that licensing process (for auctioned bands) and “provides alternatives for how it

intends to meet its obligations if it were not awarded a license.”13 The Commission also should

extend this option to an applicant that indicates its intent to participate in a future spectrum

 10 Id. at 5 (¶ 11). 11 Id. at 13 (¶ 42). 12 Id. at 17 (¶ 53). 13 Id. at 13 (¶ 43) (citation omitted).

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allocation proceeding, such as the C-band auction or the 2.5 GHz auction, so long as it provides

alternatives if it is not ultimately successful in obtaining a license.14 In addition, if the

Commission adopts its proposal prior to the short-form deadline to make all or a portion of the

5850-5925 MHz or 6 GHz bands available for fixed unlicensed services, applicants should be

permitted to include this spectrum as well.15 The Commission has sufficient knowledge and

experience to assess the applicant’s spectrum selections without making categorical exclusions

that might require a potential bidder to bid at a higher T+L or decide to not participate at all.

Further, although the Commission rightfully expanded the list of spectrum bands from

the CAF II auction to account for flexible use rules in the Spectrum Frontiers proceeding and

recent spectrum auctions conducted under Chairman Pai’s leadership,16 a more complete list

would properly recognize that a variety of Spectrum Frontiers bands currently support next-

generation services. Specifically, in addition to the 24 GHz and 28 GHz bands, Appendix B

should include spectrum from Auction 103 and spectrum in the Lower 37 GHz Band (37-37.6

GHz). With respect to the Lower 37 GHz Band, the Commission has adopted rules that make

the band available on a licensed, coordinated shared basis, and has made several commitments to

finalize those rules in the near term.17 WISPs historically have relied on a variety of licensed and

 14 Id. at 14 (¶ 43). 15 See Use of the 5.850-5.925 GHz Band, Notice of Proposed Rulemaking, 34 FCC Rcd 12603 (2019); Unlicensed Use of the 6 GHz Band; Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz, Notice of Proposed Rulemaking, 33 FCC Rcd 10496 (2018). 16 Public Notice at 13 (¶ 41). 17 Use of Spectrum Bands Above 24 GHz For Mobile Radio Services; Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services, Third Report and Order, Memorandum Opinion and Order, and Third Further Notice of Proposed Rulemaking, 33 FCC Rcd 5576 (2018); Use of Spectrum Bands Above 24 GHz For Mobile Radio Services; Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services, Second Report and Order, Second Further Notice of Proposed Rulemaking, Order on Reconsideration, and Memorandum Opinion and Order, 32 FCC Rcd 10988 (2017) (“Second Spectrum Frontiers R&O”); Use of Spectrum Bands Above 24 GHz For Mobile

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shared spectrum to provide broadband services to their communities. The Lower 37 GHz Band

offers a low-barrier path to accessing up to 600 megahertz of shared millimeter wave spectrum,

which is another opportunity for WISPs to benefit from the Commission’s proactive efforts to

make millimeter wave spectrum available for new 5G services.

Also, as it did for the CAF Phase II auction, the Commission should make clear that “[i]f

a license, lease, or other authorization is set to expire prior to the end of the 10-year support

term, the Commission will infer that the authorization will be able to be renewed when

determining at the short-form application stage whether an applicant has sufficient access to

spectrum.”18 To make a contrary determination would, without any evidence that the CAF

process should be made more restrictive here, remove from consideration those licensees relying

on, say, a Part 101 microwave backhaul license that has eight years remaining, even though it

can be routinely renewed for an additional 10 years. Likewise, EBS spectrum can be leased for

up to 30 years, often at the lessee’s exclusive option. Applicants and the Commission must be

able to infer that licenses and leases can be renewed in determining whether the spectrum will be

available for the 10-year support term. Otherwise, no spectrum-holder would be able to qualify

because the remaining terms of existing licenses will always be less than 10 years from the short-

form filing deadline.

 Radio Services; Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 8014 (2017). 18 See Public Notice, “Connect America Fund Phase II Auction Scheduled for July 24, 2018; Notice and Filing Requirements and Other Procedures for Auction 903,” AU Docket No. 17-182 and WC Docket No. 10-90, 33 FCC Rcd 1428, 1462 (¶ 89) (2018) (“CAF Auction Procedures PN”). WISPA also notes the Commission’s prior acknowledgement that applicants may rely on leased spectrum, and asks that RDOF applicants be afforded similar clarity. 

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III. THE COMMISSION SHOULD NOT ADOPT ITS PROPOSED RESTRICTION ON APPLICANTS USING FIXED WIRELESS TECHNOLOGY FROM BIDDING AT THE GIGABIT TIER

The Commission proposes “adopting prohibitions and presumptions” that would limit

applicants from specifying performance tier and latency combinations “that may be inconsistent

with the technologies they intend to use to meet their Rural Digital Opportunity Fund public

interest obligations.”19 More specifically, the Commission proposes, “consistent with the CAF

Phase II auction” for which auction procedures were adopted more than two years ago, to

preclude “any applicant that intends to use fixed wireless or DSL technologies from bidding in

the Gigabit tier if the applicant has not reported offering Gigabit broadband service in its FCC

Form 477 data.”20 The Commission bases its proposal on “the continued lack of widespread

reported deployment at higher speeds”21 and a desire “[t]o streamline the review of short-form

applications.”22

WISPA strongly opposes this categorical ex ante restriction of certain bidders. Not only

is administrative efficiency an inappropriate basis for limiting the ability of rural Americans to

obtain faster broadband speeds, it is also unnecessary to impose a categorical restriction that

contravenes the Commission’s efforts to direct RDOF support to 5G use, is inconsistent with the

Commission’s inclusion of millimeter wave spectrum bands in Appendix B and corresponding

language in the Public Notice,23 and is not based on current equipment capabilities, availability

and deployments. The Commission should not prejudge as “unreasonable” certain technological

approaches based on a lack of demand for Gigabit service or circumstances that may not be true

 19 Public Notice at 15 (¶ 48) (citation omitted). 20 Id. at 16 (¶ 51). 21 Id. 22 Id. at 15 (¶ 48). 23 Id. at 13 (¶ 41).

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in a given case,24 but should instead evaluate short forms on a case-by-case basis to determine

whether the applicant “is reasonably expected to be capable of meeting the relevant public

interest obligations in a state.”25

A. The Commission Should Not Rely on Outdated Information in its Assumptions About the Capabilities of Providers

The Commission misplaces its reliance on Form 477 data as of December 31, 2018 for

the proposition that 98 percent of fixed wireless and DSL providers have not reported offering

Gigabit speeds.26 First, the Commission does not distinguish between providers of fixed wireless

technology and those that offer broadband via DSL. Instead, it lumps the two technologies

together, apparently believing them to have roughly equivalent capabilities. This implicit

comparison ignores the fact that fixed wireless speed is a function of the available spectrum in a

given area – depending on the spectrum bands that a wireless provider can use, the more capable

it may be of deploying faster speeds. By contrast, DSL is necessarily limited by the throughput

of the wire that is connected to a location, and its capability does not evolve beyond certain

limitations imposed by the laws of physics.27

Second, the Commission ignores recent developments in citing December 2018 Form 477

data and concluding that there is a “continued lack of widespread reported deployment at higher

speeds” for fixed wireless and DSL.28 This data is based on information that is nearly two years

 24 Id. at 16 (¶ 51). 25 Id. at 17 (¶ 53). 26 See id. at 16 (¶ 51). 27 The Public Notice points to the Form 477 reporting by “fixed wireless and DSL providers.” Id. (emphasis added). This statement that ignores the fact that some fixed wireless providers may also be deploying fiber technology in their networks. Instead of looking to the status of the provider, the Commission should instead consider the capabilities of the technologies the provider has deployed. 28 Id. at 16 (¶ 51).

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old, and does not reflect the availability of Gigabit-capable millimeter wave equipment and the

increasing number of Gigabit deployments using fixed wireless technology.

Third, the Commission acknowledges that it has made more spectrum available in the

millimeter wave bands and has included on Appendix B of the Public Notice the 24 GHz, 28

GHz, 37 GHz, 39 GHz and 47 GHz bands that were not on Appendix B in the CAF Auction

Procedures PN.29 The Commission also proposes to include the 70/80/90 GHz licensed bands

and the 57-71 GHz (60 GHz) unlicensed band.30 The Public Notice seeks comment on whether

these bands “provide sufficient uplink or downlink bandwidth to support the wireless

technologies that a provider may use to meet the Rural Digital Opportunity Fund obligations.”31

In addition, the Public Notice seeks comment “on how an applicant can demonstrate that it has

sufficient access to spectrum if it intends to participate in auction proceedings that are occurring

around the same time of the Rural Digital Opportunity Fund short-form application process.”32

Further, the Public Notice proposes that “Commission staff review applications from providers

using nascent technologies on a case-by-case basis to determine whether they can reasonably be

expected to meet the specific requirements of the rural Digital Opportunity Fund. In such cases

– as in all cases – Commission staff would have the authority to determine the specific

performance tier(s) and latency for which an applicant would be qualified, if any.”33

Fourth, whether or not a provider actually offers Gigabit service today is different than

whether or not a provider could provide Gigabit service. As discussed below, fixed wireless

technology is capable of Gigabit speeds, especially when operating in wider bandwidths in

 29 See Public Notice at Appendix B. 30 See id. 31 Id. at 13 (¶ 42). 32 Id. at 13 (¶ 43). 33 Id. at 16-17 n.94.

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millimeter wave spectrum. But in any given market, broadband consumers may not subscribe to

Gigabit service even where it is available or is capable of being delivered to consumers at this

time, but their needs may change over the 10-year support term. Gigabit services are generally

the most expensive services for consumers to purchase, and many customers do not require that

amount of throughput.34

Yet, despite these requests for public input on the capabilities of spectrum and the

Commission’s assurance that performance tiers would be reviewed on a case-by-case basis “as in

all cases,”35 the Public Notice inexplicably proposes to limit ex ante – before any record is

established – the ability of fixed wireless technologies to even try to satisfy the Gigabit tier speed

requirements. Indeed, it is hypocritical for the Commission to seek comment on the inclusion of

certain bands that, alone or in combination with other spectrum bands and other technologies,

would show that meeting Gigabit tier obligations is “reasonably expected,” while categorically

precluding applicants from even making that showing in their short-forms.

In fact, in addition to the availability of thousands of megahertz of recently allocated

spectrum, there have been significant technological developments since the Commission

considered rules for CAF Phase II more than two years ago. A 2017 Maravedis white paper

concluded that “mmWave frequencies allow for fiber-like wireless capacity, enabling gigabit

broadband internet with a fixed wireless infrastructure.”36 The white paper added that “[i]n

addition to the comparatively low cost of fiber-like wireless infrastructure (as opposed to FTTH),

 34 There is a significant difference between a company that does not provide Gigabit service to a particular location but that is capable of deploying that service, and those that have not proven they have sufficient real-world ability to deploy Gigabit service. 35 Public Notice at 16-17 n.94. 36 Maravedis, 5G Fixed Wireless Gigabit Service Today: Industry Overview (Nov. 2017) at 12, available at https://go.siklu.com/hubfs/Content/White%20Papers/Maravedis%20Industry%20Overview:%205G%20Fixed%20Wireless%20Gigabit%20Services%20Today.pdf.

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a further advantage of mmWave fixed gigabit wireless networks is the ease of deployment and

scaling. Networks of this kind, utilizing the lightly licensed 70/80 GHz E-band or unlicensed 60

GHz V-Band for last mile wireless broadband, are an affordable and appealing option for many

wireline and cable service providers” as well as WISPs that are experienced in deploying fixed

wireless solutions across a number of spectrum bands.37

As examples of recent deployments, Attachment 1 hereto includes data sheets from a

number of manufacturers that are producing and distributing inexpensive equipment that can

enable Gigabit service. Following is a brief explanation of each:

Siklu MultiHaul – According to its data sheet, Siklu’s MultiHaul channels in the 60 GHz band are 2160 MHz wide. Its physical line rate is 2300 Mbps and it is rated on the data sheet for an aggregate throughput of 1 Gbps on the terminals and 1.8 Gbps (shared) on the base station.

Adtran Metnet – The Adtran Metnet equipment uses 1760 or 2160 (WiGig) MHz wide

channels and its beamformer seems to be full-circle. It then allows 12 Gbps total capacity per unit, which should easily support full Gigabit user services. The customer premise equipment is rated 1 Gbps as well.

IgniteNet MetroLinq– The IgniteNet MetroLinq tri-band radio (2.4 GHz, 5 GHz and 60 GHz) has a stated “total OTA capacity of 16.393 Gbps,” noting that a fraction of that is 5 GHz and 2.4 GHz, but the radio speed is still about 12 Gbps or more, divided between three 60 GHz sectors. This should enable throughput of more than 4 Gbps per sector.

RADWIN TerraWin – The RADWIN TerraWin is a mesh solution using the 60 GHz band, and the data sheet indicates Ethernet throughput of 3.6 Gbps per user. Product certification is pending before the Commission.

Clearly, the ability to deploy Gigabit service via fixed wireless technology is not an

“experimental technology that is not offering commercial service at all,”38 but a real technology

 37 Id. at 13. 38 Letter from Michael R. Romano, NTCA Vice President, to Marlene H. Dortch, FCC Secretary, AU Docket No. 20-34 and WC Docket Nos. 19-126 and 10-90 (filed Mar. 9, 2020) at 1. WISPA disagrees with NTCA that eligibility should be predicated on the offering of “commercial service today in rural areas on a comparable scale to the bids it would place.” Id. (emphasis added). This would preclude the use of equipment that has recently come to market, is Gigabit-capable, and is being deployed commercially but is not in wide-scale use as of yet. The RDOF program will provide support for 10

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available from multiple vendors today. In particular, Gigabit mesh solutions like those from

Adtran and RADWIN lend themselves naturally to a hybrid solution where a neighborhood is fed

by fiber to a central point, and end-user nodes are then linked together in an inexpensive, quick-

to-deploy resilient and flexible Gigabit network.

Not only is this Gigabit-capable equipment available, but WISPs are deploying it in their

networks today. For example, W.A.T.C.H. TV Company (“Watch”), a rural WISP serving

portions of Ohio, Indiana, Illinois and Kentucky, recently acquired 1.9 Gigahertz of 37 GHz

spectrum across five Partial Economic Areas in Auction 103. Watch plans to use this spectrum

to provide fixed wireless services at Gigabit speeds in areas where it intends to seek RDOF

funding. Watch also plans to utilize Terragraph-based solutions to offer the same speed in areas

where it did not acquire licensed 37 GHz spectrum.39 JAB Wireless, Inc., the country’s largest

privately held WISP with operations in 16 states, is using equipment manufactured by IgniteNet

to deploy networks in the unlicensed 57-71 GHz band that are capable of offering Gigabit

services. In Puerto Rico, Aeronet has launched a Terragraph pilot program using 60 GHz

equipment to offer the people of Puerto Rico a high-gigabit internet experience while bringing

 years, during which time more Gigabit-capable equipment is expected to be widely deployed. Limiting bidders “to bid only in the tiers in which they operate on a generally available basis” would short-change rural Americans from the benefits of cost-efficient Gigabit service deployed over fixed wireless technology, a result that is entirely inconsistent with the public interest and trends showing consumer demand for increasing throughput. Id. at 2. 39 Terragraph is a multi-node, wireless, mesh technology designed to meet growing demand for reliable, high speed internet access. It can be rapidly deployed on street furniture or rooftops in urban, suburban, and rural areas to create a millimeter wave wireless distribution network capable of delivering fiber-like connectivity at a fraction of the cost of fiber; faster deployment times and time to revenue; with more flexible network planning and rollouts. Most pertinent here, Terragraph can achieve Gigabit speeds with a measured latency of approximately 1 ms per hop as demonstrated in field trials.

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innovative technology to a historical site in Puerto Rico40 Common Networks has announced

plans to offer fixed wireless Gigabit service in the San Francisco Bay Area later this year.41

Third, the Commission relies on circular reasoning in stating that “[n]o service provider

proposing to use either fixed wireless or DSL qualified to bid in the Gigabit tier for the CAF

Phase II auction”42 because, as the Commission itself acknowledges, the Commission precluded

CAF Phase II applicants proposing fixed wireless technology from specifying the Gigabit tier.43

Had the Commission actually permitted applicants proposing fixed wireless technology to

specify the Gigabit tier for CAF Phase II, it may have determined that such capability in fact

existed at that time, as it does today.

In this case, the Commission is inappropriately assuming that, because an applicant may

not actually be offering Gigabit service, it is, therefore, not “reasonably expected to be capable”

of offering Gigabit service over a 10-year support term. A WISP may choose to not offer a

Gigabit service tier because there is no demand within the WISP’s market and customer base.

But clearly the capability of equipment to provide and fixed wireless providers to deploy Gigabit

service cannot be questioned.

B. Allowing Fixed Wireless Applicants to Propose Gigabit Speed Would Promote the Commission’s Policy of Using RDOF Support for 5G Networks

In the RDOF Order, the Commission adopted a clearing round bid processing approach

that will allow only bidders proposing the lowest T+L to advance beyond the round at which the

 40 See Hybrid Gigabit Deployments available at https://www.bbcmag.com/pub/doc/2019Presentation_Bertsch_Alan.pdf. 41 News Release, Common Networks Rolls out Peregrine, New Rooftop Hardware That Paves the Way for 1 Gbps Fixed Wireless Home Internet (Feb. 18,2020) available at https://www.common.net/press/peregrine-roll-out-021820. 42 Public Notice at 16-17 n.94. 43 See id. at 16 (¶ 51) (stating “consistent with the CAF Phase II auction, we propose precluding…”).

15  

RDOF budget clears.44 The Commission adopted this procedure in support of “our goal to close

the digital divide is balanced against our goal to support the deployment of future-proof networks

by this auction.”45 In establishing weights for bidding tiers, the Commission stated that “[w]e

also anticipate that terrestrial fixed networks will likely result in significant fiber deployment that

can serve as a backhaul for rural 5G networks.”46

As the Commission itself has acknowledged, fixed wireless technology also can be used

for backhaul in rural areas.47 In fact, in many rural areas, point-to-point fixed wireless may be

the only way to deliver 5G services in an expeditious manner given the long distance between

rural communities and the internet backbone where fiber may simply be unavailable. And,

certainly, there will be applicants proposing hybrid networks that combine fiber and fixed

wireless technologies to help bring the promise of 5G to rural areas more quickly and cost-

effectively. These links can now achieve Gigabit speeds on conventional long-range microwave

bands, whether for backhaul or customer access.

The Commission’s proposed ex ante restrictions on using fixed wireless to bid in the

Gigabit performance tier contravenes this policy objective. Restricting fixed wireless from being

used to support 5G networks will limit the pool of bidders, especially in more sparsely populated

rural areas that might not draw bids from fiber-based applicants given the greater cost of fiber

relative to fixed wireless technologies. Also, fixed wireless bidders will have incentive to deploy

quickly to take advantage of the benefits of reducing letter of credit obligations. In the end, if the

 44 See RDOF Order at 11 (¶ 21). See also Public Notice at 32-33 (¶¶ 123-124). 45 RDOF Order at 11 (¶ 21). 46 Id. at 20 (¶ 38). 47 See, e.g., Second Spectrum Frontiers R&O at 11054 (“It is important not only to protect existing links but also to provide an opportunity for future growth of fixed service in these bands as demand for backhaul and other related services increases”).

16  

Commission adopts its preclusive proposal, consumers would be denied the potential for higher

speeds that can both bridge the digital divide and support 5G networks.

IV. THE COMMISSION SHOULD MAKE ADDITIONAL INFORMATION AVAILABLE TO BIDDERS

In addition to the Commission’s proposal to make the same information to bidders as it

did for the CAF Phase II auction, the Commission seeks comment on whether it should make

available to bidders “the lowest T+L weight of any bid for each area in which there were 2 or

more bids at the round’s clock percentage.”48 According to the Commission, “[t]his information

could encourage bidders with relatively higher T+L weights to move some bids to areas where

they may be more likely to win support, thereby increasing the number of areas receiving

winning bids.”49

WISPA agrees that the Commission should make this information available to bidders.

Given the Commission’s decision in the RDOF Order to only allow the lowest-weighted T+L

tier bids to go forward after the clearing round,50 it is critical that bidders have access to the

lowest T+L tier so they have the flexibility to switch bids to other areas where they would have a

better chance of winning support. In turn, more areas would be funded – there would be no

effect on the areas where the bidder with the lowest T+L weight would prevail in any case, but

bidders that would otherwise be precluded from bidding in certain areas after the clearing round

would be able to bid for other areas where that would not be the case. The result of this

increased transparency would support the overall objectives of the RDOF Phase I auction by

 48 Public Notice at 34 (¶ 131). 49 Id., citing Letter from Louis Peraertz, WISPA Vice President of Policy, to Marlene H. Dortch, FCC Secretary, WC Docket No. 19-126, et al. (filed Jan. 21, 2020) at 3. 50 See RDOF Order at 11 (¶ 21).

17  

increasing competitive bidding in areas that might not receive support and drive support to more

areas.

Increasing transparency by making available to bidders the lowest T+L weight of any bid

for each area in which there were multiple bids should have no impact on the risk of collusion.51

The Commission’s prohibited communication rule is a sufficient deterrent to collusion among

bidders. If anything, providing more information to bidders will reduce the incentive for bidders

to share information regarding bids and bidding strategies.

Conclusion

By adopting the recommendations described above, the Commission can conduct a fair,

technologically neutral RDOF Phase I auction that ensures meaningful participation from large

and small broadband providers and fidelity to its public interest obligations, without

compromising the integrity of the Commission’s rules or the auction itself. Through these

recommendations, unserved rural Americans will benefit from robust competitive bidding that

will enable broadband deployment to help bridge the digital divide.

Respectfully submitted,

WIRELESS INTERNET SERVICE PROVIDERS ASSOCIATION

By: /s/ Louis Peraertz Louis Peraertz, Vice President of Policy

Stephen E. Coran Lerman Senter PLLC 2001 L Street, NW, Suite 400 Washington, DC 20036 (202) 416-6744 Counsel to the Wireless Internet Service Providers Association March 27, 2020

 51 See Public Notice at 34 (¶ 131).

Attachment 1

 

Multi-Gigabit Throughput in an Always-On Point-to-Multipoint Radio

Ready Set Go

Always-On Mission Critical Networks

Secure and Physically Immune Narrow Beams

An Ocean of Spectrum

Fiber Quality with Wireless Flexibility

Very Large Scale Planning and Optimization

The plug and play system is designed for an easy single person installation. The patent-pending scanning antenna automatically aligns with the Base Units. For buildings with difficult roof-top access, a single base unit needs to be installed on a roof to serve multiple locations. The Base Unit (BU) supports advanced auto-provisioning: Terminal Units (TU) configuration files are stored in the BU to enable early and advanced provisioning. The TU can be located on building sides with no need for internal re-wiring of buildings to achieve net gigabit throughput.

When you can’t afford to lose a video stream, critical safe city sensor data or any other mission critical data, you need to use a wireless network that’s as reliable and secure as fiber. With maximal immunity to interference and hacker-proof links with embedded AES encryption, MultiHaul™ delivers a network you can count on.

MultiHaul™ radios operate over the millimeter wave spectrum using narrow beams. This confers several advantages including complete immunity to interference and network jamming, as well as high security. In contrast to wide-beam wireless systems that need to use multiple strategies to perform in dense areas, and are not successful 100% of the time, MultiHaul™ is inherently interference-free and secure under any circumstances thanks to a unique combination of narrow beams and high frequencies. Multiple subscribers and services can be connected with complete isolation based on physical port, VLAN ID and/or a Terminal Unit.

The MultiHaul™ takes advantage of large millimeter wave spectrum and wide channels in order to bring multi-gigabit 60GHz capacity to a PTMP system with a single Base Unit and up to 8 Terminal Units. With its extremely high reuse factor, the wide spectrum is available anywhere, even in dense urban areas and challenging deployment scenarios.

Siklu’s millimeter wave radios successfully combine the capacity of fiber with the flexibility, speed of deployment and low TCO of wireless networks. That’s what makes them the world’s best-selling millimeter wave radios every year since 2011. They provide rock solid performance, even under severe weather conditions, in thousands of networks around the globe.

MultiHaul™ is available with robust network planning and optimization tools that help system integrators and large operators scale their networks fast and with low overhead.

MultiHaul™ PTMP 60GHz Radio

Datasheet

© Copyright 2017 Siklu Communication Ltd. All Rights Reserved. hello@siklu.com | www.siklu.com

LinkedInTwitter

A Wide Range of ApplicationsSecurity / Safe City NetworksGigabit to the Home Smart CityBusiness ServicesWi-Fi Backhaul

MultiHaul™ is a PTMP multi-gigabit radio operating over millimeter waves. It brings the advantages of mmW – multi-gigabit capacity, immunity to interference and always-on reliability - to a cost effective small form factor PTMP solution. MultiHaul™ is a plug & play system designed to easily scale, taking advantage of patent-pending scanning antennas that auto-align links, and enables connectivity for up 8 Terminal Units at up to 400 meters range, as well as robust planning and management tools.

MultiHaul™ Specifications

Line Rate (PHY)

Weight

1 Actual throughput varies with traffic patterns to/from the Terminal Units

Ethernet Features

Security

Dimensions (HxWxD)

PoE-Out

Rev

A3p

Terminal Units (TU)

Typical Reach

Power Supply

Conformance

Channels & Width

Modulation & Coding

Aggregate Throughput (1)

Frequency & Duplexing

Topologies

Management & Provisioning

Environmental

Built-in Antenna

Interfaces

System Gain (link budget)

TU MH- T200-CCC

BU MH- B100-CCS

23002300

10001800

(SFP)

2300

1000

TU MH- T200-CNN

3 1-

--

-

--

-

2 non-overlapping channels, 2160MHz wide

9 level of adaptive coding and modulation

Max capacity (Mbps), license dependent

57-64GHz

IEEE 802.1d transparent bridgingProvider bridge - VLAN & VLAN stackingJumbo frames; Port isolation; TU isolation; LLDP

AES 128-bits

7.5 x 5.2 x 3.5 in.

ETH2: 26W, 802.3at

ETH3: 13W, 802.3af

Up to 8 Terminal Units

900-1300ft. (280-400m). Detailed performance calculations - see Siklu’s online link budget calculator: siklu.com/toolsetherhaul_lbc/

PoE, 10W (IEEE 802.3af) without PoE-Out, 55W with PoE-Out (IEEE 802.3at+)

Radio: US FCC 47 CFR Part 15.255; Japan Radio Equipment Certification Ordinance 2-1-19-4-2. EMC: US FCC 47 CFR Part 15; EN 301 489Safety: UL 60950

Line rate up to (Mbps)

3 lbs. (including mounting kit)

Point to Multi-pointPoint to Point

TU auto-provisioning; In-band, out-of-band managementWeb GUI (one-click configuration of local and remote units) & Embedded CLI; SNMPv2/3, TACACS+, RADIUS

Operating Temperature: -22°F ÷ 131°F (-30°C ÷ 55°C); Optional -49°F ÷ 131°F(-45°C ÷ 55°C) Ingress Protection Rating: IP65 (optional IP67)

Horizontal scanning: 90°Vertical beam-width: 20°

Up to 3x RJ-45 100/1000 Base-T

2x RJ-45 100/1000Base-T + 1x SFP (supports 1GbE & 2.5GbE)

128.5dB (including antenna gain)

© Copyright 2017 Siklu Communication Ltd. All Rights Reserved. hello@siklu.com | www.siklu.com LinkedInTwitter

The main specifications of the MultiHaul™ Base Units (BU) and Terminal Units (TU) are outlined in the following table. Some specific details are part number dependent, and identified at the part number level in the ordering documents. Part numbers: MH-B100-CCS-PoE-MWB; MH-T200-CNN-PoE-MWB; MH-T200-CCC-PoE-MWB

Full Range and Throughput of the MultiHaul™ TU in a Form Factor 85% Smaller

Ready Set Go

Always-On Mission Critical NetworksSmall but Powerful – Virtually Invisible

Secure and Physically Immune Narrow Beams

Fiber Quality with Wireless Flexibility

Self-Installation

The plug and play system is designed for an easy single person installation with a goal of self-installation. The patent-pending scanning antenna automatically aligns with the Base Units. For buildings with difficult roof-top access, a single base unit needs to be installed on a roof to serve multiple locations. The Base Unit (BU) supports advanced auto-provisioning: Terminal Units (TU and cTU) configuration files are stored in the BU to enable early and advanced provisioning, optionally with no IP address on the TU/cTU. The TU/cTU can be located on building sides with no need for internal re-wiring of building to achieve net gigabit throughput.

When you can’t afford to lose a video stream, critical safe city sensor data or any other mission critical data, you need a wireless network that’s as reliable and secure as fiber. With maximal immunity to interference and hacker-proof links with embedded AES encryption, MultiHaul™ delivers a network you can count on.

There can be no doubt that the smaller the TU is, the more options customers have for deployment. Typically, in wireleless systems, going smaller means sacrificing performance in either throughput or range. With the cTU Siklu has broken new ground delivering the exact same performance as the TU but in a form factor that is dramatically smaller.In addition to the technology that goes into enabling identical performance in an ultra-small package comes the ability to choose from a selection of colours to further reduce the sight lines of deployed cTUs.

The MultiHaul™ cTU operates over the millimeter wave spectrum using narrow beams. This confers several advantages including complete immunity to interference and network jamming, as well as high security. In contrast to wide-beam wireless systems that need to use multiple strategies to perform in dense areas, and are not successful 100% of the time, the MultiHaul™ cTU is inherently interference-free and secure under any circumstances thanks to a unique combination of narrow beams and high frequencies, same as they are implemented on the standard TU. Multiple subscribers and services can be connected with complete isolation based on physical port, VLAN ID and/or a Terminal Unit.

Siklu’s millimeter wave radios successfully combine the capacity of fiber with the flexibility, speed of deployment and low TCO of wireless networks. That’s what makes them the world’s best-selling millimeter wave radios every year since 2011. They provide rock solid performance, even in very dense networks or under severe weather conditions, in thousands of networks around the globe.

When operators and Smart Cities are considering deployments of mmWave networks, the total cost of ownership is reviewed, just like with any new product. At Siklu we understand the large role in a business case that installation can play with costs anywhere from $100 to upwards of $500 or more. The cTU represents the first of several advances Siklu will be introducing over the next 12 months enabling a true, outdoor self-install system for our customers

A Wide Range of ApplicationsSecurity / Safe City NetworksGigabit to the Home Smart CityBusiness ServicesWi-Fi Backhaul

The MultiHaul™ system consists of a Base Unit (BU) operating over millimeter waves and connecting Terminal Units (TU) and now the new ultra small compact TU (cTU). MultiHaul™ brings the advantages of mmWave spectrum – multi-gigabit capacity, immunity to interference and massive amounts of available spectrum - to a cost effective small form factor PtMP solution. With the cTU, the customer premise side of the system has been reduced over 85% in total volume when compared to the standard TU with no loss in performance, features, range or throughput. A size only 6.5”x3.1”x1” and a selection of colours will blend the cTU into existing surroundings, making it even easier to deploy.

MultiHaul™ cTU - Small PtMP 60GHz Radio Datasheet

Copyright © 2019 Siklu Communication Ltd. All Rights Reserved

Line Rate (PHY)

Weight

1 Actual throughput varies with traffic patterns to/from the Terminal Units

Ethernet Features

Security

Dimensions (HxWxD)

Rev

1.20

19

Typical Reach

Power Supply

Conformance

Channels & Width

Modulation & Coding

Aggregate Throughput (1)

Frequency & Duplexing

Topologies

Management & Provisioning

Environmental

Built-in Antenna

Interfaces

System Gain (link budget)

2 non-overlapping channels, 2160MHz wide

9 level of adaptive coding and modulation

Max capacity 1000 (Mbps), license dependent

57-64GHz TDD

IEEE 802.1d transparent bridgingProvider bridge - VLAN & VLAN stackingJumbo frames; LLDP

AES 128-bits

6.5 x 3.1 x 1 in. / 165 x 80 x 25 mm.

900-1300ft. (280-400m). Detailed performance calculations - see Siklu’s online link budget calculator: siklu.com/toolsetherhaul_lbc/

PoE, 10W (IEEE 802.3af)

Radio: US FCC 47 CFR Part 15.255; EN 302 567; Japan Radio Equipment Certification Ordinance 2-1-19-4-2.EMC: US FCC 47 CFR Part 15; EN 301 489Safety: UL 60950

Line rate up to 2300 (Mbps)

1/2 lbs. (250 gm), including the Anymount mounting kit.

Point to Multi-pointPoint to Point

TU auto-provisioning from BU, no IP address required on TU; In-band, Out-of-band management Web GUI (one-click configuration of local and remote units) & Embedded CLI SNMPv2/3, TACACS+, RADIUS

Operating Temperature: -22°F÷131°F(-30°C÷55°C); Ingress Protection Rating: IP65

Horizontal scanning: 90°Vertical beam-width: 20°

1x RJ-45 100/1000 Base-T

128.5dB (including antenna gain)

The main specifications of the MultiHaul™ compact Terminal Units (cTU) are outlined in the following table.

MultiHaul™ cTU - Small PtMP 60GHz Radio Specifications

Copyright © 2019 Siklu Communication Ltd. All Rights Reserved

hello@siklu.com | www.siklu.com

Unlicensed, unlimited: Metnet 60G Exploring how Metnet 12Gbps 60GHz 3D SONTM mmWave access

and backhaul liberates operators and new players to harness the

unlicensed opportunity

Enabling 5G

The mobile ecosystem is in a constant process of innovation. The market is clearly

focused on the move to 5G and, while 5G is currently moving from concept to

fully commercialised technology, its impact is being felt today as anticipation builds

towards the promised ultra-fast speeds and ultra-high quality of service.

Towards multi-gigabit and 5G

Introduction

Although – right now – we cannot definitively say what 5G

will ultimately become, a number of the key performance

requirements are already known, specifically:

• Very high capacity of up to 10Gbps

• Requirement for much more spectrum with a new

focus on microwave and millimetric wave frequency

bands

• Very low latency for control of real-time applications

as well as inter base station synchronisation

• Extremely robust communication paths for critical

services

• Small cell-centric, with ease of installation and

planning key

The long-term capacity requirements for both fixed and

mobile access and backhaul networks will clearly be multi-

gigabit. This will need to be delivered with low latency,

high QOS, robust synchronisation and reliability in an

interference-limited environment and be capable of being

deployed with simple installation at low cost.

Although the anticipated schedule for the commercial

deployment of 5G is post-2020, the increased requirement

for spectrum is impacting the current decisions of both

regulators and mobile operators. In July 2016, the FCC – in

ruling FCC 16-89 – opened up a vast swathe of mmWave

spectrum for use across a wide range of applications. This

order successfully positioned the US as the first country

in the world to identify and allocate a large amount of

high frequency spectrum for 5G applications, both fixed

and mobile. Dependent upon the frequency of spectrum

allocation, the identified frequency bands are available

under wide-area licensed, unlicensed and shared bases.

This new framework – referred to as the Upper Microwave

Flexible Use Licensing (UMFUL) – serves as the blueprint for

how the FCC will pursue flexible use licensing in additional

millimetric wave bands in the future.

Band identifier Frequency range Bandwidth Channelisation Licensed

28GHz 27.50GHz-28.35GHz 850MHz 2x425MHz unpaired blocks Yes

37GHz 37.00GHz-38.60GHz 1,600MHz 8x200MHz unpaired blocks Yes

39GHz 38.60GHz-40.00GHz 1,400MHz 7x200MHz unpaired blocks Yes

64GHz-71GHz 64.00GHz-71.00GHz 7,040MHz 4x1760MHz unpaired blocks No

Riding the mmWave: the key drivers

With 60GHz formally identified by the FCC as a 5G band,

there now exists a regulatory framework supporting

the outdoor deployment of 60GHz units – removing

significant license barriers and offering greater

opportunities for both established mobile operators

and new, disruptive players looking to deploy backhaul

or access networks and enter the market with competing

services. The proposed 5G frequency bands include

the most recognised bands above 24GHz and below

90GHz, with decisions on these bands due to be made

at World Radiocommunication Conference in 2019.

As a result of the clarification of the 5G spectrum

allocation in the US, the market has developed world-

wide. Organisations today are increasingly considering

the benefits of mmWave technology for Fixed Wireless

Access, wireless backhaul, and smart city connectivity.

mmWave technology can now prove a cost-effective

solution to meet the exponential increases in data

demand – offering a much cheaper and more practical

solution than deploying fibre to every premises, and

delivering far higher capacity than sub-6GHz or existing

microwave technology.

CCS Metnet System

CCS Metnet self-organising mmWave access and backhaul

system provides many of the key requirements of 5G

plus an upgrade path to true 5G, encompassing attributes

including:

• Zero alignment installation process

• Zero requirement for frequency planning

• Topology that is self-organising, self-healing,

self-optimising and robust

• Discreet form factor suitable for deployment at street

level in a dense urban environment

• Node to node range of ~300m-250m at full data

rate with the possibility of increased range at reduced

data rate

• Low latency

• Distributed GPS timing protocol with ability to provide

both SyncE and 1588

• Flexible network architecture with SDN features

for automated provisioning and management

Metnet 60G is the first element in CCS’s new Software-

Defined Network architecture, with multiple Metnet 60G

nodes combining to function as a remotely managed

SDN-capable networking switch.

Operating in the unlicensed mmWave spectrum band

from 57GHz to 71GHz, ultra-high capacity 12Gbps

multipoint Metnet is optimised for performance today,

while providing a clear path to much higher multi-gigabit

capacity. Metnet 3D-SONTM delivers advanced proprietary

interference avoidance utilising time, frequency

and space switching agility to manage co-ordination and

co-existence with other 60GHz systems. With a wide 300°

field of view, Metnet 60G nodes connect autonomously

to form flexible MPtMP (mesh) self-organising, self-

healing networks that dynamically reconfigure to optimise

performance and spectral efficiency as the physical

environment or traffic levels change. Applications include

small cell, 5G FWA and enterprise access and backhaul,

Wi-Fi and CCTV backhaul, and fibre and G-Fast extension.

The CCS Metnet 60G unlicensed 60GHz mmWave system

enables flexible deployments which can easily be adapted

to match customers changing requirements. Low-cost high

range Metnet 60GHz CPEs can be automatically included

in the mesh to support high capacity and low-cost FWA

subscribers.

Metnet currently supports Wi-Gig and will support future

5G standards for both access and backhaul. Harnessing

high-capacity phased array transceivers, Metnet’s next

generation roadmap will provide 10’s of Gbps of switching

capacity. The next-generation mmWave platform can

support 24GHz-42GHz, while other bands such as E-band,

W-band can be supported as required. Metnet’s core

3D SONTM capability drives unparalleled end-to-end QOS,

interference control, synchronisation and scalability

– for ultimate 5G performance and next-generation future-

proofing.

CCS Metnet 12Gbps unlicensed 60GHz

mmWave backhaul system has been

developed for both existing mobile

operators and new entrants looking to

harness the potential of the unlicensed

spectrum opportunity.

Now introducing: CCS Metnet 60G

Advantage over contention-based systems

Metnet uses distributed co-ordination and dynamic

interference avoidance over multiple radio links to provide

end-to-end quality of service level to the end user under

these conditions.

In unlicensed radio system deployments, the challenges

are immeasurably worse than planning in a licensed band.

While it’s difficult and costly to plan in a licensed band

such as 28GHz, requiring people at both ends and much

upfront analysis, it is at least theoretically possible. With

60GHz unlicensed WiGig based implementations, external

interference from other networks becomes a critical

and unpredictable factor, requiring a scalable and dynamic

solution for managing the system.

Metnet 60G has been developed with a distributed

awareness of the local and global interference environment,

resolving issues via a co-ordinated system and schedule

that overcomes the interference problems seen in other

Wi-Gig-based systems. Metnet leverages proven, low-cost

Commercial Off The Shelf (COTS) hardware technology,

matching a Wi-Gig system from a cost perspective, but

provides carrier-level quality through the distributed SON

algorithms. Through this approach, the Metnet platform

enables the delivery of end-to-end throughput guarantees

and end-to-end QoS levels on a network-wide basis.

While traditional Wi-Gig is designed to support point-to-

point or point-to-multipoint deployments, these topologies

are unsuited to the dense urban deployment being targeted

in unlicensed applications for small cell backhaul and access.

The traditional necessity for multiple radios on a lamppost,

difficulty of installation, and additional overheads in terms

of alignment and frequency planning mean that traditional

Wi-Gig systems simply do not offer a long-term, scalable

solution. These issues are resolved through Metnet’s self-

organising mesh capabilities. A further advantage of the

Metnet architecture is that the same equipment can be used

for both backhaul and access, which is highly desirable for

operators.

Metnet’s discreet, de minimis form factor and single unit

per lamppost satisfies most urban planning requirements.

Metnet 60G nodes are uniquely self-organising, with

a wide 300-degree field of view that enables plug-and-

play installation in under 15 minutes, with no need for radio

planning or manual alignment. Metnet’s unique multipoint-

to-multipoint architecture with self-healing topology offers

high availability and resilience, and the system is easy

to scale as existing nodes automatically re-organise

and re-align as the network is expanded.

Alternative 60GHz Wi-Gig systems

are designed to operate in an ad-hoc

environment and will have similar

characteristics to Wi-Fi (at much

higher capacities). Detailed frequency

planning could mitigate some of the

disadvantages, but in an unlicensed

band the interference environment

is inherently unpredictable.

Metnet 3D SON™

This distributed space, time and frequency agility creates

a system that is highly robust in terms of managing

interference – with now three dimensions of control that

can be adapted to solve the problem. By encompassing

a three-dimensional solution – time, frequency and spatial

(transmitting in different directions or routes around

the network in a mesh) – Metnet offers interference

management capabilities, and a unique ability to adapt

to external interference and environment.

With Metnet 60G 3D SONTM, operators gain the ability

to deploy quickly and cost-effectively, benefitting from

high-quality of service, end-to-end backhaul and access,

robustness and resilience, with the ability to scale and grow

the network flexibly to densify or change elements

as required.

Another important advantage of Metnet 60G is distance

covered. By using silicon germanium based (SiGe)

technology, Metnet is able to achieve high EIRP (radiated

power) with its phased array antennas, giving a longer

range than conventional Si based transceivers

for equivalent throughputs. Moreover, the Metnet 60GHz

system couples its high capacity with very low latency

– significantly better latency and jitter than with a 60GHz

Wi-Gig system, and actually exceeding the requirements

for next-generation radio and 5G.

Metnet SON derives its strength from interference monitoring and dynamic

scheduling and routing to manage the interference environment. Metnet 60G

3D SONTM enhances the existing Metnet spatial TDMA capabilities – a space/time

switching schedule that enables multiple nodes to transmit without generating

interference – and enables the use of dynamically assigned frequency channels.

Metnet 3D SON™

Metnet 60G

Frequency band 60GHz mmWave unlicensed

Full 57GHz to 71GHz band

Topologies MultiPoint-to-MultiPoint (MPtMP) mesh

Point-to-MultiPoint (PtMP)

Point-to-Point (PtP)

Capacity 12Gbps per Node

Radio access Metnet SON utilizing S-TDMA

Dynamic TDD

Self-organising zero frequency planning, interference aware with time and frequency switching agility

Beamwidth Wide 300° field of view

Antennas Beamforming Phase array

16x2 element arrangement

20dBi gain per antenna

Channels Multiple 2160MHz wide channels

802.11ad Wi-Gig compliant

Modulation and coding 13 levels of adaptive encoding

Transmitter 20dBm SiGE based

Effective radiated power 40dBm per sector

Range 300m at MCS10 (3Gbps)

Interfaces Up to 4 Ethernet interfaces

2 x fixed RJ45 100/1000 Base-T

2 x optional 10Gbps SFP (Optical or Electrical)

Ethernet services Native Ethernet

802.1Q (VLAN tagging)

802.1p (Class of service)

Differentiated Services Code Point (DSCP)

802.1ad (QinQ)

Power 100V - 240V AC / 50 - 60Hz

48V DC and PoE (1 x PD interface IEEE 802.3bt)

Dimensions Height: 265mm, Diameter : 150mm (Max)

Weight 3.5 kg

CCS Metnet 60G datasheet

Software-Defined Networking

Metnet’s SDN architecture enables the intelligence

of the network to be abstracted, centralised and

standardised. The network elements are configured

automatically – often via the cloud – according

to the network plan that has been built. This eases

the deployment of complex network architectures,

as all learning and configuration is removed from

local switches and instantiated in the network from

a coherent, centralised plan as part of the operators

existing management platform. There is no requirement

for network provisioning of individual network elements

in the Metnet system as each node is immediately

provisioned via the SDN.

Although providing a coherent standards-based network

management interface, multiple Metnet radios are

connected in a true mesh, with traffic that can be routed

through different radio paths, and the ability to use

multi-path routing within the mesh for load-balancing

and resiliency. This innovation provides significant

improvements.

As the industry progresses towards 5G, the Metnet system

and software-defined network architecture seamlessly

support the move to large-scale software-defined networks.

Metnet 60G mmWave is the first product release within CCS’s new Software-Defined

Network architecture, and part of the evolutionary roadmap towards next-generation

radio. Multiple distributed Metnet 60G nodes combine to provide an SDN-capable

networking switch, which can be managed either through the Metnet Element

Management System (EMS) or a third-party management system acting as an

OpenFlow SDN controller.

Applications: unlicensed spectrum,

unlimited opportunity

CCS Metnet 60G access and backhaul offers a compelling

solution across a variety of unlicensed deployment

opportunities for:

• Traditional mobile network operators

• Disruptive new entrants to the MNO market via

the 3.5GHz CBB shared spectrum market

• Enterprise or residential access and backhaul

providers

• First responder operators

• Smart City, CCTV backhaul, and IOT network

operators

+44 (0)1223 314 197

info@ccsl.com

www.ccsl.com

Summary

Metnet 60G is the first product release within

the CCS Software-Defined Network architecture, and part

of our evolutionary roadmap towards 5G next-generation

radio.

With this new product, CCS is leveraging the low cost base

of proven component technology and combining it with

the unique Metnet self-organising mesh architecture, to

deliver a vastly superior solution that guarantees end-to-

end capacity and quality of service and resolves the issues

around point-to-point network alternatives.

Metnet’s co-ordinated, 3D SONTM interference-aware

technology and ability to organically scale makes it

a truly ideal solution for new entrants looking to take

advantage of the exciting unlicensed 60GHz and 3.5GHz

shared spectrum opportunity. For existing mobile

operators, Metnet 60G provides a robust and future

-proof platform for network densification via small cells

and, ultimately, the widescale roll-out of 5G.

Steve Greaves

CEO, CCS

November 2018

Speak to our team To arrange a free consultation with our dedicated experts, please get in touch.

Self-organising mmWave access and backhaul

Enabling 5G

Metnet 60G 12Gbps unlicensed 60GHz mmWave

CCS Metnet 60G 12Gbps unlicensed 60GHz mmWave

backhaul system has been developed for both existing

mobile operators and new entrants looking to harness

the potential of the unlicensed spectrum opportunity.

Metnet 60G 12Gbps is the first element in CCS’s new

Software-Defined Network architecture, with multiple

Metnet 60GHz nodes combining to function as a

remotely managed SDN-capable networking switch.

Applications include:

Small cell backhaul

Pre-5G FWA and enterprise

Wi-Fi backhaul

Fibre extension and G-Fast/DLSAM backhaul

CCTV backhaul

Operating in the unlicensed mmWave spectrum band from 57GHz to 71GHz, ultra-high capacity 12Gbps multipoint Metnet 60G is optimised for performance edge today, while providing a clear

path to much higher multi-gigabit capacity.

Metnet 3D-SONTM delivers advanced proprietary interference

avoidance utilising time, frequency and space switching agility

to manage co-ordination and co-existence with other 60GHz

systems. With a wide 300° field of view, Metnet 12Gbps nodes

connect autonomously to form flexible MPtMP (mesh) self-

organising, self-healing networks that dynamically reconfigure

to optimise performance and spectral efficiency as the

physical environment or traffic levels change. Applications

include small cell backhaul, 5G FWA and enterprise access

and backhaul, Wi-Fi backhaul, fibre and G-Fast extension,

and CCTV backhaul.

The CCS Metnet 12Gbps unlicensed 60GHz mmWave system

enables flexible deployments which can easily be adapted

to match customers changing requirements. Low-cost high

range Metnet 60GHz CPEs can be automatically included

in the mesh to support high capacity and low-cost FWA

subscribers.

Metnet currently supports Wi-Gig and will support future

5G standards for both access and backhaul. Harnessing high-

capacity phased array transceivers, Metnet’s NG roadmap

will provide 10’s of Gbps of switching capacity.

The next-generation mmWave platform can support

24GHz-42GHz, other bands such as E-band, W-band can be

supported as required. Metnet’s core 3D-SONTM capability

drives unparalleled end-to-end QOS, interference control,

synchronisation and scalability – for ultimate 5G performance

and next-generation future-proofing.

November 2018

Cambridge Communication Systems Ltd,

Cambridge, UK

+44 1223 314197 | info@ccsl.com | ccsl.com

All specifications are draft and subject to change.

Metnet 12Gbps

Frequency band 60GHz mmWave unlicensed

Full 57GHz to 71GHz band

Topologies MultiPoint-to-MultiPoint (MPtMP) mesh

Point-to-MultiPoint (PtMP)

Point-to-Point (PtP)

Capacity 12Gbps per node

Radio access Metnet SON utilizing S-TDMA

Dynamic TDD

Self-organising zero frequency planning, interference aware with time and frequency switching agility

Beamwidth Wide 300° field of view

Antennas Beamforming Phase array

16x2 element arrangement

20dBi gain per antenna

Channels Multiple 2160MHz wide channels

802.11ad Wi-Gig compliant

Modulation and coding 13 levels of adaptive encoding

Transmitter 20dBm SiGE based

Effective radiated power 40dBm per sector

Range 300m at MCS10 (3Gbps)

Interfaces Up to 4 Ethernet interfaces

2 x fixed RJ45 100/1000 Base-T

2 x optional 10Gbps SFP (Optical or Electrical)

Ethernet services Native Ethernet

802.1Q (VLAN tagging)

802.1p (Class of service)

Differentiated Services Code Point (DSCP)

802.1ad (QinQ)

Power 100V - 240V AC / 50 - 60Hz

48V DC and PoE (1 x PD interface IEEE 802.3bt)

Dimensions Height: 269mm, Diameter: 150mm (Max)

Weight 3.5kg

Metnet 60G

Unlicensed mmWave CPE

Enabling 5GSelf-organising mmWave

access and backhaul

Metnet 60G mmWave FWA technology

now enables operators and service

providers to rapidly deliver Gigabit services

to residential and enterprise customers.

Enterprise FWA Residential FWA

CCS Metnet 60G self-organizing 12 Gbps mesh

backhaul nodes can now be extended to

deliver FWA services using Metnet 60G CPEs.

The Metnet60G CPE connects automatically to

the Multipoint mesh network providing fibre-

like connectivity in an easy to deploy, small

form factor, and low-cost device.

Operating in the unlicensed 60GHz band between 57

and 71GHz, Metnet CPEs deliver up to 1Gbps connectivity into home or businesses. Wall or pole mount options together with PoE ensure Metnet CPEs

can be flexibly installed at any location.

Electronic beamforming antennas automatically scan and connect to the optimal mesh nodes

resulting in rapid and simple deployment in less than 15 mins.

Metnet SON delivers advanced interference

avoidance utilizing time, frequency and space diversity to continuously optimize spectral efficiency, traffic routing, performance and radio

co-existence. Metnet 12Gbps Nodes connect autonomously to form flexible Multi-point to Multi-point (mesh) self-organizing, self-healing

networks that deliver higher reliability than Point-to-Multipoint networks.

Metnet 60G CPE

Frequency Band 60GHz mmWave unlicensed Full 57GHz to 71GHz band

Topologies Point to MultiPoint MultiPoint to MultiPoint (Mesh)

Capacity 1Gbps per CPE

Radio Access Metnet SON utilizing TDMA Dynamic TDD

Beam angle Horizontal 90° electronic plus 45° mechanical Vertical 20° electronic plus 20° mechanical

Antenna Beamforming Phase array 21dBi gain

Channels Multiple 2160MHz wide channels 802.11ad WiGig Channels 1 to 6

Modulation and encoding 13 levels of adaptive encoding MCS 0 - 12

Transmitter and EIRP 19dBm SiGe based 40dBm EIRP

Range Up to 500m.

Interfaces 1 x Fixed RJ45 100/1000 Base-T Optional WiFi for local maintenance and troubleshooting

Max connections 32 CPE’s per mesh node

Ethernet Services

Native Ethernet 802.1Q (VLAN Tagging) 802.1p (Class of service) Differentiated Services Code Point (DSCP) 802.1ad QinQ

Power PoE 1 x PD interface 802.3bt 25W

Dimensions Height: 245mm Width: 120mm Depth: 65mm

Weight 1.5KG approx

All specifications are draft and subject to change

February 2019

Cambridge Communication Systems Ltd,

Cambridge, UK

+44 1223 314197 | info@ccsl.com | ccsl.com

*Product is Pending FCC Certification