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Rural Signals

Vol. 1 No. 1 Spring 2005

Rural Signals Bennet & Bennet PLLC

Vol. 1

No. 1 A Quarterly Technical e-Publication of Bennet & Bennet PLLC Spring, 2005
In This Issue:

A Note From the Publisher

Lower 700 MHz C-Block Springs to Life: FAQs on Getting Started

Another 700 MHz Question: What Is The Broadcast Service Contour?

FiberTower Proposes "At Your Own Risk" Licensing of Two-foot Antennas in the 11 GHz Band, Seeks FCC Waiver in the Meantime

FCC Restructures MMDS into Educational Broadband Service, Broadband Radio Service . . . and Cellular?

T-Mobile and RTG Join Forces to Bring AWS to Rural America

Taking Temperatures: A Concept For Interference Management

Ironmlive.com to use Wireless to Broadcast Ironman Arizona Race



A Note from the Publisher:

Last year Bennet & Bennet, PLLC brought in a team of skilled technical consultants to help its attorneys better represent its rural telecommunications client base. This new team of radio frequency and electrical engineers has been assisting B&B’s clients and attorneys through their thorough knowledge of radio frequency design, frequency coordination, technical contract review, preparation of vendor requests for proposals, technical support, technical analysis, and regulatory mandates such as E911. Having this new technical team on board at a time when many of our clients are being presented with an ever growing list of wireless opportunities made us stop and think, “How can we best share our newly acquired resources with our clients and colleagues?” After a little brainstorming, we decided that the success we have enjoyed with our legal and regulatory electronic publication, Rural Spectrum Scanner , now in its eleventh year, could be built upon with the launch of a new electronic quarterly e-publication entitled Rural Signals. Rural Signals will be delivered by e-mail four times a year (Spring, Summer, Fall and Winter) and will feature technical discussions on current spectrum related happenings and other technical telecom issues that affect rural America.

In this inaugural issue of Rural Signals , our team of technical consultants tackles a host of issues regarding the 700 MHz band in a friendly Q & A format. A technical side bar on the impact of the incumbent television broadcast licensees’ signal contours on the 700 MHz licensees also introduces the technical rules for getting along with television broadcasters prior to their permanent relocation to their digital-only channels.

In an article on a microwave back haul vendor, Rural Signals Editor, Jim Egyud, examines the pros and cons of the use of smaller microwave antennas in the 11 GHz band and the interference implications of using such devices should the FCC grant the manufacturer, FiberTower, a waiver of its rules.

On the wireless broadband front, Rural Signals features an article on the restructuring of the Multichannel Multipoint Distribution Service and the impact on rural carriers. This is also tied to another article on the technical change in the Advanced Wireless Services band plan. AWS is being hawked as the broadband data solution for cellular and PCS carriers. These two articles are related because a portion of the MMDS spectrum is being reallocated to AWS, and there is an interesting impact from the perspective of those operating in rural America.

With so much spectrum reassignment activity, and with interference control and management playing a significant role, Rural Signals also offers a discussion of the Interference Temperature concept contemplated by the FCC as a means of sharing bandwidth.

On the Fixed Wireless front, Rural Signals contains an invitation to attend a trial featuring the broadcast of live video footage of the inaugural Ironman Arizona triathlon race on April 9 utilizing WipLL products over Ironmanlive.com. Technology from Intel and Airspan will be featured in the trial, and Rural Signals will feature in-depth coverage in its upcoming Summer issue.

Enjoy Rural Signals and, as always, your feedback is priceless.

Bennet & Bennet, PLLC



Lower 700 MHz C-Block Springs to Life FAQs on Getting Started

By Len Garavalia

As activity in the Lower 700 MHz band springs to life, rural license holders are coming forward and asking: "How do I get started?" This band offers a wealth of possibilities, particularly for data offerings, but there is much to ponder when it comes to converting a license to revenue when incumbent broadcasters occupy the spectrum. Fittingly enough, with the first issue of Rural Signals , we have decided to focus on the 700 MHz "lamb" and address a few frequently asked and important questions we have been getting concerning rural deployment in the 700 MHz band.

  1. What is "short-spaced"?

  2. One of the biggest potential impediments to the deployment of service in the Lower 700 MHz band is the possibility of causing interference to incumbent broadcast licensees. The FCC has designated various Private Radio and Broadcast standards within FCC Rule Part 27 for licensees to determine whether they are "short-spaced", that is, whether the applicant's facility is closer than the FCC's minimum distance to an affected TV or DTV station. Following are links to Tables B, D & E within the Private Radio rules, which identify the minimum distances.
    • Table B - Co-channel base station separation distance is based on its maximum Effective Radiated Power (ERP) and its average Height Above Average Terrain (HAAT). Just like in the cellular world, average HAAT is based on average terrain elevations two to ten miles from the base station in eight principal directions.
    • Table D - For co-channel mobiles, the separation distance to the base station associated with mobiles is based on the mobile ERP.
    • Table E - Adjacent-channel base station separation limits are based on maximum ERP and average HAAT for the proposed base station.


  3. Do I need a waiver?
    The FCC has given some guidance, but has reserved the right to make an official decision based on the unique characteristics of each applicant's market conditions. Generally, under the following guidelines, no waiver is required if:
    • The 700 MHz station facilities are not short-spaced. In this case, no FCC Form 601 application is needed (unless otherwise required by conditions such as an Environmental Analysis for new tower construction, etc.).
    • The 700 MHz licensee is short-spaced but meets the Desired-to-Undesired Signal (D/U) ratio for the theoretical coverage contours (that is, the area defined by the FCC as a station's protected coverage area). In this case, an engineering justification must be filed with an FCC Form 601 application.
    • The 700 MHz licensee is short-spaced but has received written consent from the affected co-channel and adjacent-channel TV/DTV Broadcasters. In this case, the consent agreements along with a description of the proposal with as much detail as possible must be filed with an FCC Form 601 application.

    A waiver will be required if:
    • The 700 MHz licensee is short-spaced and does not meet the D/U ratio for the theoretical coverage contours. As is the case for a short-spaced licensee that meets the D/U ratio, an engineering justification must be filed with an FCC Form 601 application.

    For more information on D/U Ratios and broadcast contours, please see the accompanying Technical Note and the accompanying article by David Fritz: Another 700 MHz Question: What Is the Broadcast Service Contour?

    Technical Note: A little more info on D/U Ratios
    D/U Ratios are defined by the FCC for:
    • co-channel DTV stations as a minimum 23 dB D/U ratio required at the co-channel DTV station's 41dBuV/m equivalent Grade B contour.
    • adjacent-channel DTV stations as a minimum -23 dB D/U ratio (i.e., the undesired signal can be stronger) required at the adjacent-channel DTV station's 41dBuV/m equivalent Grade B contour.
    • co-channel Analog TV stations as a minimum 40 dB D/U ratio required at the co-channel TV station's 64dBuV/m hypothetical Grade B contour.
    • adjacent-channel Analog TV stations as a minimum 0 dB D/U ratio required at the adjacent-channel TV station's 64dBuV/m hypothetical Grade B contour.


  4. Who has requested 700 MHz waivers, and what is their status?
    While there are Lower 700 MHz band licensees currently operating under Part 27 of the FCC Rules, here is a sample list of licensees that have requested waiver of those rules or an experimental license in order to operate:
    • Access Spectrum, LLC was granted a waiver last August to operate on its guard-band channels (1 MHz pairs on lower Channels 60 and 65) at a location in Houston, Texas. Access Spectrum proposed adjacent-channel operation with a Channel 61 broadcaster.
    • Aloha Partners was granted a waiver on February 18, 2005 to operate on channels 54 and 59 in Tucson, Arizona. Only Aloha's proposed Channel 59 operation is co-channel with an incumbent broadcaster.
    • OCTO (Office of the Chief Technology Officer) in Washington, DC filed an application for an experimental license to operate in Public Safety Spectrum on Channels 61 and 69 (short-spaced with Channel 62 WFPT). It received its grant in August 2004 and its progress report is due next month (Station WD2XHO).
    • Qualcomm filed a Petition for Declaratory Ruling on January 10, 2005. To date, the FCC has not acted upon it. We will discuss the subject of the petition, interference protection metrics, later in this Q&A session.

    These applications are important because their technical showings can serve as a general guide, assuming the parameters for your deployment are essentially the same as those previously granted.

  5. What if there are TV/DTV translators, boosters, or other low power stations located on the C-Block frequencies in my market?
    • The good news here is that the low power stations have secondary status to the Lower 700 MHz C-Block licensed operations, but the FCC has specific rules outlined for termination of the low power stations.
    • The 700 MHz carrier must be prepared to show that the low power station would interfere with the proposed operation.
    • Termination notices should be provided to the incumbent low power station at least 120 days prior to your scheduled in-service date.
    • Caution: The secondary station could object to the termination, so be prepared for this possibility.


  6. How can I deploy if there are existing broadcasters?
    • Determine if there is one distinct, dominant interfering broadcaster affecting your market or portions of your market. Then consider utilizing a vendor and technology type that supports Time Division Duplexing (TDD) or half-duplexing. This allows you to use either Channel 54 or 59 as both the uplink and the downlink.
    • If both Channels 54 and 59 are affecting your market:
      • Determine to what extent they will interfere with your proposed network and to what extent your facilities will affect the reception of those broadcasters' signals WITHIN THEIR PROTECTED GRADE B CONTOUR(S).
      • Work with the unique terrain and morphology variations within your market, the directionality of antenna systems, and the directionality of the broadcasters' antenna systems.
      • Consider a combination of 700 MHz and unlicensed facilities to work around the broadcasters.
      • Consider the broadcasters' targeted communities of service. Are there station affiliates that serve your market on TV channels outside the 700 MHz band? Once you have your engineering justification in order, coordinate directly with the broadcasters.
      • Consider actual measurements of the TV/DTV environment to justify your design and interference analysis and to document the real-world implications for the broadcasters and for a potential waiver application. Depending on your unique market characteristics, this could be the first step to determine if your 700 MHz network impacts or is impacted by the incumbent TV/DTV broadcasters.
    • In its petition for declaratory ruling, Qualcomm offered yet another solution. Qualcomm believes that the FCC should declare that Office of Engineering and Technology (OET) Bulletin 69 is an acceptable method of determining interference protection for TV/DTV stations and complying with FCC Rule Section 27.60 protection criteria. It believes the Commission should declare that interference to a threshold of 2% of the TV/DTV over-the-air viewing population is an acceptable de minimis standard. (The term "de minimis" comes from the Part 73 Broadcast ruleswhich permit an interfering broadcaster to affect up to 2% of an adjacent or co-channel station.)
    • In some cases, there may be markets that simply cannot be served until the broadcasters complete their transition.


  7. Is 12 MHz of spectrum enough?
    • Typically, paired 6 MHz channels should be enough to begin operation and meet initial demand; however…
      • Check your radio access vendors' specifications for the number of subscribers each RF channel can accommodate AND at what average data rate.
      • Compare the bandwidth limits of each RF channel for that vendor to your spectrum allocation and the technology's spectrum re-use limits.
    • By comparison:
      • Cellular spectrum uses paired 12.5 MHz bands, and carriers are struggling with band-clearing for competing technologies (such as CDMA vs. GSM) in adjacent co-channel markets. Therefore, many markets are being overlaid with 1900 MHz as a means to add capacity.
      • 1900 MHz Broadband PCS ranges from paired 5 MHz blocks (the D, E, and F blocks on a BTA basis) to paired 15 MHz blocks (the A and B blocks on an MTA basis and the C block on a BTA basis).
      • Many broadband carriers are going further and supplementing their spectrum allocations with portions of the other PCS blocks in paired segments as small as 2.5 MHz.
    • For future subscriber capacity growth and for services that will demand higher bandwidths (such as streaming media) or priority access (such as VoIP, VPN, or Public Safety), the 12 MHz licenses may need to be supplemented.

    We suggest that rural carriers work with their attorneys and/or industry associations to petition the FCC to auction additional spectrum in the 700 MHz band that would be licensed on an MSA and RSA basis.

  8. What is my build-out schedule?
    What are the deployment ramifications with regards to the time period of your license? For licensees that elect to commence new broadcast operations prior to January 1, 2007, the renewal deadline will be set at the end of an eight-year term following commencement of such broadcast operations. At the end of the eight-year term, the license will be subject to Section 27.14 of the FCC rules as it relates to Construction requirements. The rule states, in part, "...licensees must make a showing of `substantial service' in their license area within the prescribed license term.…" Initial authorizations for the 698-764 MHz and 776-794 MHz bands will extend until January 1, 2015.

    In other bands, such as PCS, the FCC has stated clear renewal requirements such as coverage to 25, 30 or 60 percent of the market population. The FCC rules for the Lower 700 MHz licensees do not specifically define "substantial service" at this time. However, some flexibility has been built in where portions of your market cannot be built out due to the potential for interference with incumbent TV/DTV broadcasters.

 

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While there is not enough space in our first issue of Rural Signals to address all of the questions we receive concerning the 700 MHz band, this article should have you thinking about some of the technical concerns related to deploying in this band.

Should you have any questions, please do not hesitate to contact Len Garavalia, Director - Technical Consulting Services.

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Another 700 MHz Question: What Is The Broadcast Service Contour?

By David Fritz

Many licensees from Auctions 44 and 49 (the Lower 700 MHz C Band) come from commercial fixed and mobile radio backgrounds (Cellular, Paging, etc.) and are looking to continue their deployments by using 700 MHz with data services. They are not strangers to FCC service contours (i.e., cellular's 39 dBu and 32 dBu; paging interference and service contours; etc.). Such contours are based on mathematical formulas, applied uniformly to all licenses, and clearly outlined in the FCC rules to approximate or define service and/or interference boundaries with other licensees. Now armed with a license in the UHF television band, these new licensees are getting a taste of a different type of service contour: the broadcast Grade B Contour.

For analog TV stations, the service grade contours defined in the FCC rules, as shown in Table 1 below, use field strength values in decibels above one micro-volt per meter ("dBu") and represent the TV stations' theoretical coverage as recognized by the FCC. While the FCC uses the Grade A and City Grade contours to represent coverage, it uses the Grade B contour to represent a boundary for interference protection. To predict the distance from the station to the analog field strength contour, the FCC provides propagation curves that represent the estimated field strength in dBu being exceeded at 50% of the potential receiver locations for at least 50% of the time ("F(50,50)"), based on the transmitting antenna height in meters. With the use of the F(50,50) field strength curve, the full analog TV contour can be geographically produced by calculating the contour distances using the transmitter's antenna Height Above Average Terrain ("HAAT") and Effective Radiated Power ("ERP") for each of 360 evenly spaced radials extending from the transmitter location, and connecting the end points of these distances. Obviously, with the use of linear interpolation, less accurate approximations can be accomplished with fewer radials. Essentially, the contour is a collection of points where the calculated field strength meets or exceeds the FCC's threshold value for that grade of service on that channel.

Table 1 - National Television System Committee (NTSC) Analog Television (Field Strength Threshold):
Channels Grade B
Service Contour
Grade A
Service Contour
City Grade
Service Contour
Channels 2-6 47 dBu 68 dBu 74 dBu
Channels 7-13 56 dBu 71 dBu 77 dBu
Channels 14-69 64 dBu 74 dBu 80 dBu

Digital TV contours have their own set of values as outlined in the FCC Rules (see Table 2 below). Service for Digital TV stations is defined to exist where estimated field strength exceeds the threshold value at 50% of the potential receiver locations for at least 90% of the time, F(50,90). Until recently, the FCC did not produce F(50,90) field strength curves for direct calculation of digital TV contour distances. To calculate the F(50,90) contour distance, the following formula was developed in conjunction with the F(50,50) and F(50,10) field strength curves found in the FCC regulations:

F(50,90)=F(50,50)-[ F(50,10)- F(50,50)]

As done to produce the analog TV contour, calculating and connecting the contour distances for 360 evenly spaced radials around a transmitter location geographically produces the Digital TV contour. For interference protection purposes, the DTV Noise-Limited Service contour in Table 2 is digital TV's functional equivalent to analog's Grade B contour.

Table 2 - Digital Television (Field Strength Threshold):
Channels DTV Noise-Limited Service Minimum Field
Strength Over
Community of License
Prior to Dec. 31, 2004
Minimum Field Strength
Over Community of License After Dec. 31, 2004 (Commercial TV) or After Dec. 31, 2005 (Non-commercial Educational TV)
Channels 2-6 28 dBu 28 dBu 35 dBu
Channels 7-13 36 dBu 36 dBu 43 dBu
Channels 14-69 41 dBu 41 dBu 48 dBu

Certainly, the service contours used by the incumbent analog and digital TV licensees have many different values depending on the channel, service and type of technology. The contours and FCC rules were formulated years ago for the incumbent broadcaster, but were never refined for the new users of the spectrum. This quagmire has left many new 700 MHz licensees knee deep in broadcast rules and service contours to justify their deployment cases in areas where they find themselves close-spaced with incumbent licensees. For others, it's just too much, so the decision is to do nothing with their spectrum until their co-primary neighbors finally vacate.

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For more information on broadcast service contours or deployment challenges in the 700MHz bands, please contact David Fritz.

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FiberTower Proposes "At Your Own Risk" Licensing of Two-foot Antennas in the 11 GHz Band, Seeks FCC Waiver in the Meantime

By Jim Egyud

FiberTower, Inc., a vendor of network backhaul solutions, has filed a Rulemaking Petition and a Waiver Request at the FCC that seeks an amendment of the FCC Rules to permit the use of smaller, less-directional antennas in the 10.7-11.7 GHz Fixed Service Band ("the 11 GHz band"). These filings recommend conditions under which the smaller antennas would be permitted, including interference protection only to the extent that it would be afforded to larger antennas that currently comply with the FCC Rules. FiberTower asserts that the smaller antennas cost less and, because of their smaller size, can be deployed on more structures than their larger counterparts.

What the FCC Rules Say
The FCC Rules require certain electrical characteristics of microwave dishes coordinated and used by applicants and licensees in the 11 GHz band. The idea is to minimize interference potential through the use of narrow, focused radiation patterns along the main direction or axis of transmission, and also through the suppression of secondary pattern lobes away from the main axis (otherwise known as "side-lobe suppression"). The ability to focus the radiation pattern depends on the size, shape, and construction of the antenna. In the 11 GHz band, the FCC's beamwidth, gain, and suppression requirements have not been met by antennas smaller than four feet (1.22 meters) in diameter. It should be noted that the 11 GHz band is also shared by satellite service licensees, whose terrestrial receivers are afforded interference protection. For the terrestrial user, the 11 GHz band represents an intermediate option for paths of a few miles in length.

FiberTower's FCC Wish List
In its Petition and Waiver Request, FiberTower contends that smaller antennas may be easier to deploy in some circumstances, and might be the only option where a supporting structure's capacity or space availability precludes a larger antenna that meets the FCC's requirements. Moreover, the smaller antennas are less expensive and less visually obtrusive, thereby more likely to gain support in zoning and siting proceedings. FiberTower suggests that the ability to use such smaller antennas will promote efficient use of the spectrum by allowing antennas to be placed at locations where antenna placement might not have otherwise been possible.

The downside? Size matters, but it's the radiation pattern that counts. The smaller antennas are more susceptible to interference both into and from co-channel facilities. As a mitigating factor to existing paths, because the smaller antennas inherently have less gain, they are more limited in the amount of power that they can transmit, and would be usable only for the shortest of 11 GHz paths. On the flip side, the receiving end of the path using a smaller antenna is more susceptible to interference for two reasons: its weaker side-lobe suppression can pick up more off-axis interference, and it would be receiving less of the desired signal because of the smaller antenna transmitting to it.

Nonetheless, the Waiver Request offers a number of conditions designed to minimize the potential interference issues inherent to the smaller antennas, the highlights of which are:

  1. Conformance to technical specifications proposed in the Petition for such antennas;
  2. Compliance with the outcome of the Petition proceeding;
  3. Limited conditions under which a licensee or applicant using a two-foot antenna under the waiver may object to a subsequent coordination by another carrier;
  4. Obligations of the licensee or prior applicant using the two-foot antenna to reduce predicted interference resulting from a subsequent coordination from another applicant using a larger (compliant) antenna; and
  5. FiberTower agrees to limit its installations under the waiver to 500 units per year. (Since FiberTower structured the Waiver Request to apply only to facilities that it sells to its customers, others seeking similar relief pending the outcome of the Petition would have to file their own waiver requests.)
Regarding conditions (3) and (4), interference protection would be afforded to the applicant/licensee using the two-foot antenna only to the extent that the interference would still have occurred into a larger, compliant antenna, assuming all else being equal. In condition (3), the coordinating party would then have to protect the smaller antenna user only to the extent that it were protecting the compliant antenna. In condition (4), the coordinating party would only be able to require the two-foot antenna user to reduce predicted interference levels to those that would have occurred from a larger, compliant antenna. To summarize, in the coordination and licensing process, the Waiver Request and Petition would essentially make these smaller, less-directional antennas akin to larger antennas with Category B interference characteristics.

Summarizing the Pros and Cons
For those looking to construct 11 GHz paths, the Waiver Request and underlying Petition would open a door to make deployment of short-haul facilities in tight physical confines more feasible. For those that might be concerned about potential interference between the less-directional antennas and their existing or prior coordinated facilities, the proposed coordination and licensing methodology would appear to afford ample protection on paper. However, the fact remains that the smaller antennas, which do not have the narrower beamwidths and stronger side-lobe suppression of their larger brethren, remain more susceptible to inducing or receiving interference in certain instances. In the field, such interference sources can be difficult to isolate. Therefore, great care must be taken during the coordination process. If the Petition were to be granted, carriers seeking to deploy the smaller antennas would be wise to prepare a backup plan in case interference issues arise after deployment.

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Should you have any questions about the outcome of this Petition or desire more information about this technology, please contact Jim Egyud, Senior Technical Consultant.

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FCC Restructures MMDS into Educational Broadband Service, Broadband Radio Service . . . and Cellular?

By Judy Deng

The FCC has announced a plan to reform the spectrum rules in the 2.5 - 2.7 GHz MMDS/ITFS band in the Report and Order released on June 10, 2004, and there is much to digest. MMDS (Multichannel Multipoint Distribution Service) is presently used in the United States to deliver video program content for entertainment and distance-learning activities. Most systems use analog transmission under the National Television Systems Committee (NTSC) standard to deliver one video program per 6-MHz channel. The Order renames the MMDS service as the Broadband Radio Service (BRS) and renames ITFS (Instructional Television Fixed Service) as the Educational Broadband Service (EBS).

In restructuring these bands, the FCC takes a number of important steps to make more efficient use of the spectrum as shown in the chart found here. The chart compares the current band plan to the post-transition plan as adopted by the FCC.

The Skinny: Wider Band Segments
The Order eliminates the use of smaller, interleaved channels by BRS and EBS licensees and creates a distinct band segment for high power operations flanked by band segments created for low power operations. The three aptly-named segments, the Lower Band Segment (LBS), the Middle Band Segment (MBS), and the Upper Band Segment (UBS), are separated by 4 MHz guard bands. The low power channel blocks in the LBS and UBS segments consist of four 16.5 MHz bands, each with three (3) 5.5 MHz channels. The MBS consists of eight 6 MHz channels. Five of the eight 6 MHz channels are allocated to EBS, and two are allocated to BRS. Again, these channels are consistent with the NTSC channel bandwidth and are allowed to use high power for the delivery of video. (In addition, the FCC reallocated MDS Channels 1 and 2 to BRS 1 and 2, respectively.) Sorting it all out, the FCC has created larger and potentially more usable chunks out of the same spectrum.

While there are several ramifications to the restructuring, three specifically stand out. First, the new band plan reduces the likelihood of interference caused by incompatible technologies vying for the same spectrum. Second, and perhaps more intriguingly, the restructuring creates incentives for the development of low power, cellular-type broadband operations, which were limited by the prior interleaved band plan. Third, existing licensees currently using the band for high-powered video service will likely face additional challenges should they desire to continue to provide video services following the EBS/BRS transition. Obviously, there are many issues that licensees and prospective carriers will have to sort out, including the territorial aspects of interference protection. Look for Rural Signals to address more of this potential treasure trove of rural spectrum opportunities in the next issue.

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If you would like to know more about the restructuring of the MMDS band, please contact Judy Deng, Technical Consultant.

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T-Mobile and RTG Join Forces to Bring AWS to Rural America

By Len Garavalia

T-Mobile USA, Inc. ("T-Mobile") and the Rural Telecommunications Group, Inc. ("RTG"), a trade association made up of small and rural wireless telecom companies ( www.ruraltelecomgroup.org), recently came together to encourage the FCC to revise its band plan for Advanced Wireless Services ("AWS") in the 1.7 GHz and 2.1 GHz Bands. T-Mobile and RTG recommended that the FCC reconfigure its current 30 MHz E Block to add spectrum to the D Block, and create a sixth AWS license block. This would create a total of 20 MHz of paired spectrum for use within the RSAs and MSAs; no license would consist of more than 20 MHz of spectrum; and no less than 20 MHz of spectrum would remain in each of the three market categories: Economic Area (EA), Regional Economic Area Groups (REAG), and Metropolitan Statistical Area/Rural Service Area (MSA/RSA).

T-Mobile's and RTG's plan to reconfigure the AWS band would allow small rural carriers operating in the RSAs to acquire affordable spectrum to augment their existing services and remain competitive with larger regional carriers, while ensuring that national, regional and local licensees would not be forced to acquire more spectrum than needed. Under the joint plan, those carriers seeking to acquire additional spectrum can simply aggregate more licenses.

Specifically, T-Mobile and RTG propose the following band plan:

Block MHz Pairings Area Licenses
A 20 1710-1720 paired with 2110-2120 MHz EA 176
B 20 1720-1730 paired with 2120-2130 MHz REAG 12
C 10 1730-1735 paired with 2130-2135 MHz REAG 12
D 20 1735-1745 paired with 2135-2145 MHz MSA/RSA 734
E 10 1745-1750 paired with 2145-2150 MHz EA 176
F 10 1750-1755 paired with 2150-2155 MHz REAG 12

RTG encouraged the dedication of 20 MHz of paired spectrum for MSAs/RSAs in the D-Block so that rural licensees would have a competitive share of the spectrum comparable to the licensees in the other blocks. In addition, BRS channels 1 & 2 encumber the F-block frequencies from 2150-2162 MHz. This is important because, while there are other unencumbered REAG licenses proposed, there is only one MSA/RSA license block proposed. If the MSA/RSA license were to remain in the F-block, the upper pairing would remain unavailable for rural broadband deployment.

If accepted by the Commission, the joint AWS band plan will promote flexible spectrum policy and competitive opportunities in all areas of the country, bringing AWS to urban areas as well as rural and underserved areas.

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For more information about the joint AWS plan, please contact Len Garavalia, Director, Technical Consulting Services.

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Taking Temperatures: A Concept For Interference Management

By Malick Sohrab

As the United States moves to becoming a wireless society, the FCC has been trying all sorts of ways to free up more spectrum. One controversial school of thought that has gained notoriety is a temperature-based methodology that would allow the monitoring and management of interference between devices that operate within licensed and unlicensed bands. In a Notice of Proposed Rule Making, the FCC floated the idea of an interference measurement and quantification matrix called "Interference Temperature". Measured in Kelvin(s) [K], this quantity is a temperature equivalent of the amount of noise and interference in a specific frequency band, obtained by taking the power in the band measured in Watts [W], and dividing it by the RF bandwidth (in Hz) and the Boltzman constant (in W-sec/K). The result would theoretically quantify in Kelvin (and hence temperature) the noise/interference density per Hz at a location and within a specific frequency band.

The idea is that unlicensed devices that could measure such a "temperature" in a certain licensed band would conceptually power up to within a certain interference threshold, which remains below the minimum operating noise floor requirements of the licensed entities' equipment. Theoretically, the unlicensed device should remain unnoticed by the licensed entity's equipment. The "minimum operating noise floor requirement" is the key here in that the FCC proposes to set a cap on the interference that a licensed entity would experience within its band. This would allow unlicensed users in the same band to operate so long as they do not exceed the cap. This would, in essence, protect the licensed entity while allowing additional use of the same spectrum.

Although the FCC's proposal gets more complicated in proposing numerous methods to aid the real time measurement and management of the interference to the licensed user, the core concept behind the idea is tied to the RF engineering concept that radio devices, especially those in the broadcast environment, are typically engineered to function with respect to certain noise floor requirements. As long as other devices are able to establish that they can operate in the same band without degrading the noise floor requirements of the licensed user, there should conceptually be no interference problems.

As a potential application of this concept, one could consider the 700 MHz TV band, which has been opened up for use to potential broadband data and other wireless services. In concept, operating co-channel with certain TV stations within this band would typically raise the eyebrows of those thinking that the TV receivers in the area would receive additional interference that degrades reception. However, TV station bandwidths are typically 6 MHz wide, and the operating interference thresholds for the TV channels are based on this 6 MHz bandwidth. Existing and evolving wireless broadband data technologies that use bandwidths narrower than 6 MHz (e.g., 1.25 MHz) would conceptually introduce interference to the TV broadcast within a narrower segment of the larger 6 MHz TV carrier. Using the Interference Temperature concept, if judiciously positioned within the TV carrier's channel, the wireless data carrier could raise the TV broadcast noise floor environment only marginally to where the effective noise floor remains below what would adversely affect the TV receiver. Of course, this application also assumes that the incoming broadband technology inserted within the TV channel can itself operate properly with the reciprocal noise/interference from the TV signals.

Spread spectrum technologies such as CDMA and OFDM that would operate with bandwidths (e.g., 1.25 MHz) narrower than a TV channel, and below the noise floor in the environment, may be able to do so when engineered appropriately. However, equipment specifications and technology variations among vendors manufacturing this equipment must be scrutinized to ascertain that the viability of the resulting engineering design is practical and achievable both technically and monetarily.

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Rural Signals will continue to keep an eye on the proposed use of interference temperature for the management of spectrum and let our readership know if anything starts to "heat up". In the interim, please contact Malick Sohrab should you have any questions.

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Ironmlive.com to use Wireless to Broadcast Ironman Arizona Race

By David Fritz

Ironmanlive.com, Intel, Airspan and Bennet & Bennet, PLLC have teamed together to utilize wireless technology to broadcast live video coverage of the inaugural Ironman Arizona triathlon on Saturday, April 9 in Tempe, Arizona.

Airspan, in collaboration with Intel, Ironmanlive.com and Bennet & Bennet, PLLC, will be deploying a demonstration of Airspan's WipLL product line. Airspan's WipLL product is a low-cost, high performance Fixed Wireless Access system that can be used to deliver high-speed data services to remote locations. The WipLL product is available in licensed bands of 700 MHz, 2.5 GHz, 2.7-2.9 GHz and 3.4-3.8 GHz and unlicensed bands of 900 MHz, 2.4 GHz and 5.8 GHz. With burst speeds up to 4 Mbps (3.2 Mbps -net), the WipLL product line has a wide range of potential for rural applications and quick deployments.

The Ironman Arizona demonstration deployment will feature the WipLL product as the air interface between Ironmanlive.com's production facilities and remote full motion video cameras along the swim, bike, and run course. System deployment will be done the day before the race, and tours of the deployment will be done after setup and during race day where access is available. To watch the live broadcast of the race, tune into www.ironmanlive.com beginning at 7:00 am Pacific Time on April 9.

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Rural Signals will report on the outcome of the demonstration in its summer issue. If you are interested in attending the demonstration or would like more information on this wireless technology, please contact David Fritz.

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Questions??? Call Rural Signals Editor Jim Egyud [(202) 371-1500], and refer to Vol. 1, No. 1.

 

About Rural Signals
Rural Signals is a quarterly publication of Bennet & Bennet, PLLC's technical consulting service division. Rural Signals is delivered by e-mail four times a year and features technical discussions on current spectrum related happenings affecting rural America. For subscription information or to inquire about specific rural spectrum issues, please call/fax/e-mail Rural Signals Editor Jim Egyud at 202-371-1500 or 202-371-1558 (fax).

While it is our intention to provide valuable information to readers of Rural Signals , the transmission of this newsletter does not create an attorney-client relationship. You should not act upon any information contained in Rural Signals or at www.bennetlaw.com without first seeking the advice of an attorney.

Copyright 2005 Bennet & Bennet, PLLC