Regulatory Matters

Capacity Planning for Next Generation Utility Networks (Part 2)

Capacity planning guidelines for utility transport networks

In PART 1 of this blog, we provided an analysis of utility applications and expected capacity demands. Applications, especially security and surveillance, are rapidly increasing capacity requirements for utility networks. In this blog, we will outline an approach for performing capacity planning for a sample utility network in light of the applications traffic requirements.

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- September 19, 2017
FCC Rule Changes and the Future for Unlicensed 5.8Ghz PTP Backhaul Links

The tragedy of the commons happens when people sharing a common resource are inclined to overuse it, degrading it so much that becomes useless. An example is a field open to all in which cattle, have grazed for generations. At some point, a cattleman increases the number of animals of his herd to maximize profit.

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- August 16, 2017
AT&T, T-Mobile Agree on the Future of Small Cell

AT&T and T-Mobile recently filed comments with the FCC that will enable small cell backhaul in urban cores for greater subscriber connectivity.

In the last few weeks, the future prospects of small cell antennas got brighter and shrank at the same time. AT&T and T-Mobile both filed comments with the Federal Communications Commission (FCC) in support of an industry-wide waiver of rules against flat-panel antennas for backhaul radios in the 70-80GHz bands. Currently, out-of-date FCC regulations about antenna radiation patterns hold back development and deployment of this type of equipment that urban dwellers will find acceptable in big city cores.

The current rules effectively call for the use of parabolic antennas that will be unsightly and would violate the aesthetics considerations and zoning regulations in many city core locations—precisely the type of environment that 70-80GHz radios exist to service. While the FCC regulations seem to necessitate parabolic antennas to keep radio beams focused and from interfering with equipment in the vicinity that uses the same wavelengths, mobile subscribers prefer more visually friendly solutions.

How to get from here to there
For the last few years, Aviat Networks has been working with the Fixed Wireless Communications Coalition and others to get the FCC to update its regulations in the 70-80GHz bands. The problem: when the FCC promulgated these rules, the idea had never occurred to anyone that these bands would ever service small cell applications. And the applications that the FCC’s 70-80GHz rules were designed to support never materialized, with only 5,500 links registered in this spectrum since 2005, according to T-Mobile.

However, with this breakthrough in support from Tier 1 operators like AT&T and T-Mobile, the FCC should feel reassured that granting the waiver to the antenna rules for 70-80GHz bands is in the best interest of all the wireless industry service providers. And with OEMs in addition to Aviat asking for the waiver, no specific vendor will be favored. We urge other wireless service providers, communications equipment OEMs, subscribers and anyone else interested in moving forward as fast as the technology can go to also contact the FCC about granting this industry-wide waiver.

In the meantime, to learn more about urbanized small cell backhaul in the 70-80GHz bands, download this white paper.

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- December 18, 2015
Telecom Industry Participants call on FCC for E-band Action

While U.S. regulators decide on flat-panel antenna rules for E-band, operators and subscribers walk a tightrope of red tape.

Back in April the telecom experts over at CommLawBlog weighed in on a simmering issue in the 70-80GHz radio space. Since October 2012, the Federal Communications Commission (FCC) has mulled over a motion by the Fixed Wireless Communications Coalition (FWCC) to relax rules for flat panel antennas as well as a 2013 waiver to the existing rules while it considers a new rulemaking.

Lack of taking any action on any of these filings has left the backhaul industry in a quandary. With viable radio solutions ready to deploy in the 70-80 GHz frequency ranges, the only holdup has been a technical requirement that FCC rules place on the radiation pattern of the very thinnest of flat panel antennas. These rules were originally formulated for an era where microwave radios were used for links that spanned 1 to 5 kilometers.

In the new urban reality for small cells, the distances between mobile base stations will be measured in hundreds of meters. At these lengths, the radiation patterns of flat panel antennas will not materially increase interference, to paraphrase language the FCC itself has used previously when approving use of smaller antennas in the 6, 18 and 23 GHz bands, circa 2012.

With small cell wireless in close-in city settings, both mobile and non-mobile subscribers have a heightened sense of awareness, and they will take extra notice of backhaul radios with prominent parabolic dishes that stick out like sore thumbs. With their figurative and literal low profiles, flat panel antennas provide the critical missing link in ameliorating the aesthetics concerns that many feel toward old, bulky microwave installs. While these hulking communications devices were fine on towers at long haul sites way out by the interstate freeway or high atop skyscrapers in the heart of the business district, when they are situated on the side of a residential building the modern-day urbanite will not tolerate these telecom equipment eyesores.

In reality, there is very little for the FCC to decide upon. While the telecom regulator here in the United States has its own rules, regulators in much of the rest of the world use the ETSI standards. Actually, the standard in effect is of little consequence. The point of fact is that the flat panel antennas in question before the FCC have been approved for use in all these ETSI countries without any significant drawbacks being reported in nearly three years of use. Even the FCC’s companion agency to the north, Industry Canada, has given tentative go-ahead to flat panel antennas for use with 70-80GHz backhaul radios, with the implicit understanding that they will receive formal approval if no unforeseen snags occur in final rule drafting.

So while the rest of the small cell community enjoys a flat panel world, the U.S. is walking a tightrope of red tape in hopes that some decision is made—soon.

Full disclosure: Aviat Networks is the filer of the 2013 waiver request and is a member of the Fixed Wireless Communications Coalition. Aviat Networks is legally represented by Fletcher, Heald & Hildreth, PLC, the host of CommLawBlog.

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- May 22, 2015
Could the Fixed Microwave Community Live without the L6GHz Band?

Photo credit: Broo_am (Andy B) / Foter / CC BY-ND

The fate of the L6GHz band for fixed microwave services could be decided when the World Radio Conference (WRC) meets in Geneva in 2015. Because these meetings at ITU headquarters only occur every three or four years, 2015 will be pivotal. Procedurally, at these conferences, delegates from member states review and—if necessary—revise the Radio Regulations, the international treaty governing the use of radio-frequency spectrum and geostationary- and non-geostationary-satellite orbits. They make revisions based on an agenda determined by the ITU Council, which takes into account recommendations made by previous world radiocommunication conferences.

Generally, the scope of world radiocommunication conference agendas is established four to six years in advance, with the final agenda set two years before the conference by the ITU Council, with concurrence of a majority of member states.

As WRC-15 approaches, many national regulatory authorities are busy harmonizing their national positions this year ahead of the actual conference in 2015. This conference is likely to see one of the biggest—if not the biggest—reallocations of spectrum ever undertaken. Much of this is currently being addressed under agenda item 1.1:

To consider additional spectrum allocations to the mobile service on a primary basis and identification of additional frequency bands for International Mobile Telecommunications (IMT) and related regulatory provisions, to facilitate the development of terrestrial mobile broadband applications, in accordance with Resolution 233 (WRC-12)

This will present the microwave community with a number of challenges and opportunities moving forward, one of which will be how we will address increased demand for capacity arising from mobile operators gaining huge swaths of additional access spectrum, enabling them to offer more and more high-demand, high-bandwidth services. This will require the regulatory environment governing fixed microwave to evolve at least in step or ideally ahead of this demand to ensure microwave remains an attractive and viable means for backhauling this access demand. The second challenge that the microwave community will face with WRC-15 agenda item 1.1 is more urgent: the proposal from Russia to open up the L6GHz band to mobile access.

The L6GHz fixed microwave band between 5925MHz and 6425MHz is available worldwide and with its propagation characteristics provides spectrum that is used for critical long-haul infrastructure links. The very nature of these links means that they are likely to be operational for many years and thus explains why many national regulators report stable and/or low growth in the number of licences issued in this band. In fact, with only a small number of channels available, in some locations congestion is becoming a problem. One scenario where use of this band cannot be replaced is when links have to cross open water, such as the Great Lakes in North America or the English Channel, the Oresund and the Aegean Sea in Europe. Here we see greatly increased activity from those building trans-national low latency networks linking together the various financial centers.

Now that we know the band’s use, why highlight it today?
Admittedly, while the Russian proposal under agenda item 1.1 is for shared access between microwave and mobile access, many industry insiders realize that the two services cannot realistically live side by side in the same geography. It’s not possible because mobile access requires nearly blanket area coverage to be viable. Add the fact that user terminals can be anywhere means sharing is difficult if not impossible to achieve. Some have proposed that mobile access at this frequency will only be attractive in urban areas, leaving rural areas to microwave. This is fine until you need to cross or terminate your L6GHz microwave link in an urban area. In reality, this approach is more of a migration solution than a sharing solution and is not in the best interests of the microwave community.

What to do?
The way WRC-15 works is that each member state has the same weighted vote as every other member. Consequently, any proposal for spectrum reallocation needs to be taken seriously. If there are concerns about a proposal then only by convincing a majority of national regulatory authorities of the validity of your argument can your position prevail. Aviat Networks has been working on several fronts in recent months to achieve a sufficiently large counter vote to the Russian proposals so that the status quo is maintained.

Lobbying national regulatory authorities
Specifically, Aviat Networks and other members of the U.S. microwave community have been working to formulate an American position. At present, this looks promising in terms of our L6GHz stance. Aviat Networks is also active in many African countries helping formulate national positions to oppose the Russians. The position of the African countries is key in this debate because there is not the fallback of long distance fiber. With the distances involved copper has never been a viable option for high capacity services. The current cloud over all this is Europe. Even with Europe’s very strong bent toward supporting growth of cellular services, many countries are still undecided, a situation further complicated by Russia’s CEPT membership. For example, Ofcom (U.K.) despite industry efforts is still unwilling to commit to a definitive strategy—or view—although the regulator admits a position must be agreed upon prior to the conference.

The message above is simple: if you use or want to use the L6GHz band for fixed microwave services find out what your national regulator’s position will be under WRC-15 agenda item 1.1. Remember, there are many bands up for discussion under this agenda item so ensure that you get your answer for the 5925-6425MHz band. Moreover, check whether it is a definitive position then lobby for the status quo to remain and oppose the Russian proposal.

Ian Marshall
Regulatory Manager
Aviat Networks

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- February 14, 2014
E-band Wireless Comms: UK Announces New Approach

On Dec. 16 2013, Ofcom—the UK telecom regulator—announced a new approach for the use of E-band wireless communications in the United Kingdom. This new approach results from an earlier Ofcom consultation exercise in which Aviat Networks participated.

To summarize, the new approach, which is available for licensing after Dec. 17, 2013, splits the band into two segments. Ofcom will coordinate the lower segment of 2GHz, while the upper segment of 2.5GHz will remain self-coordinated as per the prior policy.

The segment Ofcom coordinates will follow the usual regulatory processes for all the other fixed link bands it oversees. Moreover, Ofcom has already updated all the relevant documents and forms to accommodate E-band. While we (i.e., Aviat Networks, other telecom vendors) would have preferred the larger portion of spectrum to have been granted to the Ofcom-coordinated process, we welcome this new arrangement because it provides an option for greater security and peace of mind to operators in terms of protection from interference than was envisaged for the previous all self-coordinated spectrum regime.

For a more detailed look at the new E-band arrangement, Figure 1 shows the Ofcom-coordinated section sitting in the lower half of both the 71-76GHz and 81-86GHz bands thus allowing for the deployment of FDD systems in line with ECC/REC(05)07.

Figure 1: Segmented Plan for Mixed Management Approach (click on figures to enlarge)

In terms of channelization within the Ofcom-coordinated block, the regulator announced that it would permit 8 x 250MHz channels, 4 x 500MHz channels, 1 x 750MHz channel and 1 x 1000MHz channel as per ECC/REC(05)07. Ofcom also stated that 62.5MHz and 125MHz channels will be implemented as soon as the relevant technical standards, etc., from ETSI are published. Figure 2 shows the Ofcom channel plan:

Figure 2: Ofcom Permitted E-band Channelizations

Regarding equipment requirements, Ofcom stated that it will allow equipment that meets the appropriate sections of EN 302 217-2-2 and EN 302 217-4-2. This includes the antenna classes (e.g., classes 2-4) that will allow the deployment of solutions with flat panel antennas. Aviat Networks welcomes this approach and hopes that other regulators—notably the FCC in terms of antenna requirements—currently considering opening up and/or revising their rules for E-band adopt similar approaches.

The license fees for the self-coordinated segment remains at £50 per link per annum, whereas in the Ofcom-coordinated segment the fees are bandwidth based as reflected in Figure 3:

Figure 3: Ofcom Bandwidth-based Fees

Notwithstanding the current fees consultation process that Ofcom is undertaking, these “interim fees” will remain in place for five years, after which time the results of the fees review may mean that they will be amended.

Also because of responses received during the consultation process, within the self-coordinated block, Ofcom will now require the following additional information for the self-coordination database: antenna polarization (horizontal, vertical or dual), ETSI Spectrum Efficiency Class and whether the link is TDD or FDD.

Ian Marshall
Regulatory Manager
Aviat Networks

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- UK Smartphone Adoption Rises to 39% – Ofcom (misco.co.uk)
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- December 19, 2013
60GHz Band: a Solution for Small Cell Backhaul?

Small cell will enable mobile usage in dense urban environments but will need a backhaul solution to make it possible. Photo credit: Ed Yourdon / Foter / CC BY-SA

The Case for Small Cell Backhaul
As the search for frequency bands with suitable capacity for small-cell backhaul continues, frequency bands above 50GHz start to appear attractive because they offer both high-bandwidth availability and short range owing to their inherent propagation characteristics. The white paper available at the bottom of this blog examines spectrum in the 57-64GHz range to see whether it can be of use for small cell backhaul.

In many countries, the frequency range 57-66GHz is split into a number of discrete bands with differing requirements and conditions of use and/or licensing. These differences will be highlighted where applicable.

From a global point of view, the use of this spectrum by Fixed Services (FS) is being addressed by the ITU-R in its draft report on Fixed Service use trends in WP5C, which is currently under development and states:

57 GHz to 64 GHz
The radio-frequency channel and block arrangements of these bands for FS are defined in Recommendation ITU-R F.1497.
In 2011, around 700 links were in use in this band in a few administrations. The majority of the links are used for fixed and mobile infrastructure.
The air absorption around 60 GHz is over 10 dB/km. This condition restricts the hop length; on the other hand, the spectrum reuse efficiency is high. This feature makes the band suitable for small cell mobile backhaul.

Clearly, a global reported usage of 700 links would suggest a great deal of underutilization, although with unlicensed use in many countries it is difficult to know whether these figures are accurate or not. Regardless, there are reasons as to why this could be the case, while noting that the ITU-R believes this band has potential for small cell backhaul.

One factor is that this spectrum is not allocated solely to the Fixed Service. In fact, in many countries the Fixed Services have no access to this spectrum at all. A more detailed country-by-country breakdown follows. Please sign up below to receive the entire white paper.
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Ian Marshall
Regulatory Manager
Aviat Networks

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- Ofcom Consultation: 71-76 GHz and 81-86 GHz bands (southgatearc.org)
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- October 8, 2013
Rules of the Game: Low Latency Microwave in a Multi-Regulatory Environment

[潛伏Latency] Charcoal, watercolor, fire on paper, 2011. Photo credit: RedPapaya (栩) / Foter / CC BY-NC-ND
Over the course of the last 18 months, a new application has grown by leaps and bounds for microwave networks: low latency. Low-latency microwave networks find most of their applicability in financial transactions, such as for executing trading instructions between major stock exchanges and trading houses in other cities.

Typically, low-latency microwave is used to “replace” traditional-fiber based networks linking financial centers. The business driver for microwave-instead-of-fiber in low latency is the time it takes to transmit trading instructions. With microwave, latency is reduced by a few milliseconds as compared to fiber. Nevertheless, those few milliseconds can translate into a trading edge over rival investors, which means big bucks. Low latency investors will pay a premium for this edge resulting in increased revenue for low-latency microwave network operators.

However, as with most financial functions, low latency is subject to a set of stringent regulations. The scenario is doubly difficult when low-latency microwave networks transmit across international boundaries. This compares to linking financial centers within a single country, which is relatively straightforward from a regulatory perspective because there is only one set of rules. The fact is when connecting financial centers in different nations and the operator’s network has to traverse other countries’ borders, the process becomes orders of magnitude more complex. Download the complete article for a fuller examination of some of these issues and why there should be widespread support for greater international harmonization of microwave regulation.

Ian Marshall
Regulatory Manager
Aviat Networks

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- September 20, 2013
Telecom Department to Seek Trai’s Views on Allowing Spectrum Trading

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- August 30, 2013
Should National Telecom Regulators Impose Buildout Requirements on Operators?

Photo credit: fingle / Foter / CC BY-NC-SA

In the mobile operator space in many countries, the national regulators are imposing so-called “buildout requirements” as a license condition on many wireless providers. In some countries, these requirements are restricted to licenses awarded by the auction process (e.g., cellular access spectrum) or block allocations while in others these conditions are attached to the majority of licenses.

Where buildout requirements are employed, a license typically has a clause that requires the licensee to build out a network/link or specified portion of a network within a certain period of time, with penalties imposed for failure to do so.

The rationale behind imposing these requirements is to ensure that after spectrum is assigned it is put to its intended use without delay. By doing this, or so the theory goes, bidders are discouraged from acquiring spectrum with the sole intent of blocking competitors’ activities without themselves offering service. Of course, the ultimate goal is the protection of spectrum—a finite and precious resource. There is no reason buildout requirements cannot be attached to any license grant, assuming that the detail of the requirements recognizes any constraints of the application for which the spectrum is sought.

Nevertheless, Aviat Networks is strongly against auctions and block allocations, but where these are a necessity then buildout requirements must be part of any award, with strong enforcement rules. The problem is that with strong enforcement operators and regulators can be at loggerheads and get tied up in court with lawsuits and countersuits for years. For example, in the U.S. you have the case of Fibertower. The FCC claims that Fibertower deliberately underbuilt its network and so moved to revoke its spectrum licenses. With the regulator moving against the operator, it came under insurmountable financial pressure and filed for bankruptcy. But even now, the operator’s creditors are fighting the FCC in order to recoup frequencies valued at more than US$100 million. So it is questionable whether this actually works in practice.

Microwave is the point
Focusing on point-to-point microwave, let’s examine the approach taken in two different countries. In the United States, for traditional link-by-link allocation, the FCC imposes an 18-month deadline by which time the link in question needs to be in service. However, in the United Kingdom, Ofcom imposes no such deadline. For certain applications, certain routes and sites are critical and can quickly become “full.” If these key locations are being filled by license applications that are not being translated into operational services, then this spectrum is effectively wasted as no one else can use it, nor is there any service being offered. Spectrum wasted in this manner reduces overall spectrum efficiency, and all spectrum authorities are motivated to ensure that spectrum is used in the most efficient way possible.

Of course having these rules is fine, but what happens when the rules are breached? In some cases, an operator will apply for an extension prior to the expiration of the original deadline; this may or may not be granted. However, the real test is what happens when the deadline passes. Ideally, what should happen is that the license(s) in question would be revoked and the associated spectrum made available for reallocation. Furthermore, if the spectrum in question was originally made available by block allocation or auction, then again, ideally, this spectrum should be returned to the pool of spectrum available for link-by-link licensing.

Additionally in shared bands, i.e., spectrum shared by the Fixed Service (FS) and the Fixed Satellite Service (FSS) should be governed by the same requirements in this instance. Therefore, unused/defunct FSS allocations/licenses should also be revoked with the spectrum being made available for reuse. In the case of FSS locations, this can have a significant effect owing to the geographic full-arc protection area that is usually associated with earth stations.

Counterpoint
The alternative viewpoint is that the current buildout requirements are counterproductive, in their aim to foster efficient use of spectrum. One reason cited for this view is that it takes time for an equipment supply ecosystem to develop, which will serve the spectrum users. However, when we examine this claim more carefully, it seems that this is often used where the spectrum has been awarded to a single user either by block allocation or by auction. We have written before about how auctions and block allocations are unsuitable for point-to-point microwave, and the claim above is a direct result of this process, which negatively impacts the number of operators. In turn, that reduces the ranks of equipment vendors, leading to thinner competition and, therefore, decreased incentive for innovation. This situation is made worse if the operator in question chooses a band plan that is nonstandard in terms of either existing U.S. or international arrangements.

Signal termination
In the final analysis, it does not serve any stakeholders’ goals to have valuable spectrum allocated but unutilized. Thus, having buildout requirements would appear to be a good idea. But along with that, an effective mechanism for reclaiming and making available to others spectrum that runs afoul of these rules is paramount to making the process work for the Greater Good. In Aviat’s view, buildout requirements are a valuable tool in ensuring spectrum efficiency and as such, their use should be seriously considered in all countries.

Ian Marshall
Regulatory Manager
Aviat Networks

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- August 23, 2013