unlicensed use of 6 ghz - spectrum managementrlan proponents file rkf study on docket •study to...

Unlicensed use of 6 GHz

May 15, 2019

Background and Key Issues

PRIVATE AND CONFIDENTIAL © 2019 CommScope, Inc.2 PRIVATE AND CONFIDENTIAL © 2019 CommScope, Inc.2

Agenda

Regulatory Background

Background on Unlicensed Proponents & Some Use Cases

Background on Microwave Incumbents

Key Issues

Upper 6 GHz Relocation Proposal

Regulatory Background


FCC Activity to Date

Aug 2017

FCC Notice of Inquiry (17-183)

• Asked questions about possible new uses of 6 GHz band

• Ask specifically about unlicensed use

• Break band into two segments:

• 5925-6425 MHz

• 6425-7125 MHz

• 88 comments and 6 replies

Jan 2018

RLAN Proponents File RKF Study on Docket

• Study to determine whether RLAN devices can coexist with incumbent microwave

• Provides 2025 estimate of RLAN deployment

• Concludes that LPI devices will not interfere with microwave systems

• Study has been substantially disputed on the docket

Oct 2018

FCC NPRM on Unlicensed use of 6 GHz Band (18-295)

• Proposes new rules for unlicensed sharing with 6 GHz incumbents

• Proposes Automatic Frequency Coordination (AFC) idea

• Asks several technical questions on issues such as:

• Propagation models

• Interference protection criteria

• Building & clutter loss

• 108 comments and 63 replies filed

Apr 2019

Post-comment Period

• Flurry of ex-parte filings & meetings

• Additional analyses performed and offered on the record



Aug 2017





• 5925-6425 MHz

• 6425-7125 MHz


Jan 2018






Oct 2018









Apr 2019

Post-comment Period





Aug 2017


•Asked questions about possible new uses of 6 GHz band

•Ask specifically about unlicensed use

•Break band into two segments:

•5925-6425 MHz

•6425-7125 MHz

•88 comments and 6 replies



Aug 2017





• 5925-6425 MHz

• 6425-7125 MHz


Jan 2018






Oct 2018









Apr 2019

Post-comment Period





Jan 2018


•Study to determine whether RLAN devices can coexist with incumbent microwave

•Provides 2025 estimate of RLAN deployment

•Concludes that LPI devices will not interfere with microwave systems

•Study has been substantially disputed on the docket



Aug 2017





• 5925-6425 MHz

• 6425-7125 MHz


Jan 2018






Oct 2018









Apr 2019

Post-comment Period





Oct 2018


•Proposes new rules for unlicensed sharing with 6 GHz incumbents

•Proposes Automatic Frequency Coordination (AFC) idea

•Asks several technical questions on issues such as:

•Propagation models

•Interference protection criteria

•Building & clutter loss

•108 comments and 63 replies filed



Aug 2017





• 5925-6425 MHz

• 6425-7125 MHz


Jan 2018






Oct 2018









Apr 2019

Post-comment Period





Apr 2019

Post-comment Period

•Flurry of ex-parte filings & meetings

•Additional analyses performed and offered on the record

PRIVATE AND CONFIDENTIAL © 2019 CommScope, Inc.13

Proposes 2 types of unlicensed devices tailored to protect incumbent

services that operate in distinct parts of the 6 GHz band:

5.925-6.425 GHz and 6.525-6.875 GHz sub-bands

– Unlicensed devices would only be allowed to transmit under the control of an

Automated Frequency Coordination (AFC) system.

– AFC system would identify frequencies on which unlicensed devices could

operate without causing harmful interference to fixed point-to-point

microwave receivers.

6.425-6.525 GHz and 6.875-7.125 GHz sub-bands

– Unlicensed devices would be restricted to indoor use and would operate at

lower power, without an AFC system.

– These frequencies are used for mobile services, such as the Broadcast

Auxiliary Service and Cable Television Relay Service, as well as fixed and fixed

satellite services. The itinerant nature of the mobile services makes the use of

an AFC system impractical.

– The combination of lower power and indoor operations would protect

licensed services operating on these frequencies from harmful interference.

Basics of the NPRM

Propose to allow unlicensed

devices to operate under the

Part 15 only in locations and

frequencies where they would

not cause harmful

interference to the licensed

services in the band.

1

2


8500

6 GHz | Bands

5925

6425

6525

6700

6725

6875

6975

7025

7075

7125

Mobile

Fixed

EESS/SRSand RAS

Fixed SatelliteService (FSS)

C-band FSS Uplink

Common Carrier (CC), Operational FS (OFS)

Local Television Transmission Service (LTTS)

Private Operational Fixed Point-to-Point Microwave

Television Broadcast Auxiliary Service

Cable Television Relay Service

Extended C-band FSS Uplink C-band FSS Uplink (Planned Band)

SiriusXM Feederlink Uplink

CC, OFS CC, OFS

OFS

LTTS

BAS

CARS

LTTS

BAS

CARS

Excluded

§ 101.147

Freq plan

Radio Astronomy Service (6650-6675.2 MHz) Passive SensorRAS

Passive Sensor (Measurements over Oceans)

NGSO Feeder Downlink of MSS

Lower 6 GHz

U-NII-5 U-NII-6 U-NII-7 U-NII-8

Upper 6 GHz

5150

U-NII-1 to 4 Federal

Local Television Transmission Service

20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20

40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40

80

160

80 80 80

160

80

160

80 80

160

80

160

80 80 80

160

80 80

160

80

2059 x 20 MHz

29 x 40 MHz

14 x 80 MHz

7 x 160 MHz

Wi-Fi Channels


6 GHz Unlicensed Device Classes | NPRM Proposal

Band

(MHz)

Primary

AllocationsU-NII Devices Max Power AFC

5.925-6.425 Fixed Service

FSS U-NII-5 Standard-Power AP

4W (36 dBm)

30 dbm/6 dBi ant gain

(U-NII-1 & 3)

Yes

6.425-6.525 Mobile Service

FSS U-NII-6

Low-Power AP

(indoor)

1W (30 dBm)


(U-NII-2a)

No

6.525-6.875 Fixed Service

FSS U-NII-7 Standard-Power AP

4W (36 dBm)


(U-NII-1 & 3)

Yes

6.875-7.125

Fixed Service

Mobile Service

FSS*

U-NII-8Low-Power AP

(indoor)

1W (30 dBm)


(U-NII-2a)

No

* There is no FSS allocation in the 7.075-7.125 GHz portion of the band.

Background on Unlicensed Proponents


Motivations for Unlicensed Industries

Unlicensed bands are workhorses for our increasingly wireless world:

• Unlicensed bands carry half of all internet traffic in the U.S., a figure that is growing each year.

• ~70% of mobile device data traffic is carried over unlicensed (almost all Wi-Fi today, but also LTE-LAA and NR-U going forward)

• 4 billion Wi-Fi devices will ship in 2019, growing the installed base to 13 billion

• Unlicensed spectrum is also the backbone for new IoT networks (Ericsson forecast that 90%+ of IoT connections in 2022 would be over unlicensed)

But there have been no new allocations for mid-band unlicensed since 2003, 2.4 GHz has significant usage

constraints, and in 5 GHz - DFS and the failure to open U-NII-2b limit the # of wide channels (> 80 MHz)

Next generation unlicensed RATs (802.11ax, NR-U, .11be) assume 80, 160, and even 320 MHz channels to

achieve throughputs up to 10 Gbps+

Qualcomm and Quotient studies have demonstrated an enormous unlicensed spectrum shortfall in the mid-

band. The 6 GHz band is essential to addressing this pressing need.


6 GHz Unlicensed | Sharing Proponents aka 6USC (6 GHz Unlicensed Services Coalition) or the RLAN Group


Timelines (Best Case)

2020201920182017

FCC “Mid-Band” NOI(5925-7125 MHz)

EC Mandate(5925-6425 MHz)

ETSI BRAN SRDocApproved

IEEE Revises 802.11ax draft to include < 7125 MHz

SE45 & FM57 Work Begins

FCC NPRM Approved on Unlicensed in 5925-7125 MHz

Draft EC Report “A” from ECC/CEPT*

ETSI BRAN beginsHarmonized Standard**

FCC 6 GHz Report & Order Approved**

Final EC Report “B” from ECC/CEPT**

802.11ax 6 GHz Products Available

in Market**

802.11ax 6 GHz Products Available

in Market**

* Expected based on Established Schedule

** General Estimate

SE45 Technical Study released for Public Comment

NPRM Comment & Reply Comments Complete


Standards Work

802.11ax Draft 4.0 (distributed in February 2019) had the first substantial requirements for use of the 6

GHz band.• Optimizations developed by Wi-Fi Alliance for 2.4/5 GHz (Agile Multiband, Optimized Connectivity, etc.) will be

mandatory for the 6 GHz band

• Major changes to network discovery by clients, to remove as much “wasted probing” as possible from the band.

Allows much more efficient discovery in the 6 GHz band, and also allows (and prefers) discovery of 6 GHz access

using the 2.4/5 GHz bands for the discovery overhead.

Release 16/17 SI for NR-U included the 6GHz extensions (to 5 GHz) under early discussion (not yet

agreed) picking back up @RAN #84 JUN 2019 (USA 5925 - 7125 MHz, Europe 5925 - 6425 MHz)

IEEE / 3GPP Workshop on 6 GHz coexistence planned for July (Vienna)

After ~6 months of debate, 6 GHz certification work in WFA getting started • Part of 802.11ax certification, as follow-on to “11ax Wave 1” certification launch

• Early planning is for 6 GHz certification launch in January 2021 (coincide with CES)

• The current plan largely ignores AFC-based access

System Reference Document (SRDoc) for 6 GHz RLAN completed in March 2019 (led by Ian Marshall)

ETSI BRAN Technical Report on 6725-7125 MHz being developed to counter advocacy by some parties to

license this band in Europe

Example of In-Home Use Case


Backbone and Video

• Can be driven now by

Service Providers

• Multi AP perfect

application for 6GHz

backbone

• IP video and QoS

guarantees for 4K @

20Mbps and even 8K @

50-100Mbps – 6GHz

capable STB enables it

GW

Extender

6GHz Backbone

Extender

6GHz Backbone

STB

6GHz Video STB

STB

6GHz Video STB

Hub and Spoke at 250mW


Low Latency Services• Scheduled 6GHz OFDMA can

drive new applications

• Low latency Gaming over

OFDMA enabled by Wi-Fi 6

STA

• Wireless NAS solution that

works fast and not

connected to PC

• Wireless WAN to flexible

location of Femto Cell and

support for scheduled timing

• VR and AR HMD applications

GW

6GHz Backbone

6GHz Backbone

6GHz Low Latency Gaming

Services that typically have had to have a hardline

ethernet cable can potentially run on 6GHz

scheduled services

160 MHz 6GHz STA Dongle

160 MHz 6GHz STA Dongle

Or Integrated NAS Drive

6GHz enabled Femto Cell

CBRS


Efficient AP locations

• 6GHz bandwidth allows

potential for Ceiling

mount apps

• Allows 2 Box architecture

to untether from the 2ft

ethernet connection

between ONT and AP or

EMTA and APEMTAONT with 6GHz

6GHz Backbone

6GHz Backbone

6GHz Backbone

Services that typically have had to have a hardline

ethernet cable can potentially run on 6GHz

scheduled services

Center of Home single Wi-Fi AP

Ceiling mounted Gbps Residential AP

Background on Microwave Incumbents


6 GHz | Microwave System Incumbents

Licensed, Applied and Proposed

Lower 6 GHz Microwave Paths

Licensed, Applied and Proposed

Upper 6 GHz Microwave Paths

Paths Transmit Frequencies

27,212 74,273

Paths Transmit Frequencies

14,929 31,166


6 GHz | FCC Filing & Coordination Activity

2013 2014 2015 2016 2017 2018Average

Month/Day

Filing 8815 7620 6848 7604 7245 7200 630 / 21

Coordination 6649 6033 5469 5459 5520 5150 476 / 16

0

1000

2000

3000

4000

5000

6000

7000

2013 2014 2015 2016 2017 2018

Nu

mb

er

of

Lin

ks

Year

Coordination Activity

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

2013 2014 2015 2016 2017 2018

Nu

mb

er

of

Sit

es

Year

Filing Activity


Concerns of Microwave Industry

Adequate protection of critical microwave systems

Ability to freely deploy and operate microwave systems

Interference identification and mitigation

No burden placed on microwave incumbents

De facto reallocation of 6 GHz band

Key Issues


Should Low-Power indoor devices (non-AFC)

be allowed at a certain power level?

General AFC approach

Role of multi-stakeholder group(s)

Continuing participation in existing coalitions

and informal alliances?

Reallocate 6525-7125 MHz band to mobile

Key Issues

How should AFC work (TVWS, SAS,

other…)

Should RLAN devices register

Data update interval

Security

Number of AFC operators (and

selection criteria)

What data to use (ULS, other…)

Interference protection criteria

Adjacent-channel protection

Fade margin protection

Propagation models

Location reporting methods

(height reporting)

How to handle client devices

Interference identification,

reporting and mitigation

AFC certification process

Automated Frequency Control (AFC)


6 GHz | Comsearch Sharing Analysis

Spectrum availability in Dallas, TX for low-power indoor devices based on 80 MHz channels

• Monte-Carlo simulation of indoor RLAN

distribution

• Analysis of interference if RLAN into

microwave receivers

• Results show potential for interference

into microwave receivers


8500

6 GHz | Possible Reallocation

5925

6425

6525

6700

6725

6875

6975

7025

7075

7125

Mobile

Fixed

EESS/SRSand RAS

Fixed SatelliteService (FSS)

C-band FSS Uplink

Common Carrier (CC), Operational FS (OFS)

Local Television Transmission Service (LTTS)

Private Operational Fixed Point-to-Point Microwave

Television Broadcast Auxiliary Service

Cable Television Relay Service

Extended C-band FSS Uplink C-band FSS Uplink (Planned Band)

SiriusXM Feederlink Uplink

CC, OFS CC, OFS

OFS

LTTS

BAS

CARS

LTTS

BAS

CARS

Excluded

§ 101.147

Freq plan

Radio Astronomy Service (6650-6675.2 MHz) Passive SensorRAS

Passive Sensor (Measurements over Oceans)

NGSO Feeder Downlink of MSS

Lower 6 GHz

U-NII-5 U-NII-6 U-NII-7 U-NII-8

Upper 6 GHz

5150

U-NII-1 to 4 Federal

Local Television Transmission Service

20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20

40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40 40

80

160

80 80 80

160

80

160

80 80

160

80

160

80 80 80

160

80 80

160

80

2059 x 20 MHz

29 x 40 MHz

14 x 80 MHz

7 x 160 MHz

Wi-Fi Channels

Reallocate to Mobile Exclusive

Open 5925-6525 and 7125-8500 for bi-directional

sharing

Relocate incumbents to 7125-8500

MHz band (currently Federal exclusive)

Thank You!


Sharing

Methodology

Database contains pre-calculated exclusion zone data for every

microwave path

• Exclusion data should be updated at least daily if not more frequently

Every RLAN device registers with database

• Initial registration and query are made outside the 6 GHz bands

• Must allow for cases where the master may be safely outside all exclusion zones but the client is within an exclusion zone

RLAN device queries database with:

• Location

• Device type

• Identifying information

Database determines proximity of device to exclusion zone(s)

• Spectrum availability determination must consider device location inaccuracies

Database returns list of available frequencies to RLAN device

RLAN devices returns to database frequency(ies) selected to

operate

RLAN sends heartbeat message to ensure data is current and

that device is active

RLAN deregisters if:

• Moves more than 50m

• Fails to heartbeat in 24 hours

No Airborne RLAN operation

Location Uncertainty Circle

Calculations assume device at closest distance (di) to exclusion zone

di

Fn

duDevice reportedlocation

unlicensed use of 6 ghz - spectrum managementrlan proponents file rkf study on docket •study to...

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