MDS, ITFS OPERATORS FLOAT NEW BAND PLAN, RULES CHANGES TO FCC

Groups said 2nd-generation technology that didn’t rely on line-of-sight pathway for 2-way data operations was hampered by “broadcast-like interference analysis, application and licensing process [that] puts a substantial burden on licensees.” ITFS and MDS White Paper called for new band plan for 2.5 GHz that would protect one-way, high- power operations that some ITFS licensees would continue to use while allowing 2-way advanced services to operate without causing interference. Proposal also would do away with 40- year-old interleaving channelization plan.

One impetus for streamlining stressed by groups is that 2nd-generation broadband technology for MDS/ITFS systems would require vastly larger number of applications because it would use more highly cellularized network architecture. Proposal follows FCC order last year that added mobile allocation to 2500-2690 MHz band and spared incumbent licensees from relocation threat posed by 3G (CD Sept 25 p1). Requested changes also come after several operators had put on hold plans to further deploy 2G systems as they waited for less expensive systems from vendors, including ones that could be purchased at retail by customers and installed by themselves. Separately, outgoing WorldCom CEO John Sidgmore had said earlier this year that all of company’s wireless assets were on sales block, including mobile reseller operations and MMDS properties.

Proposal submitted to Wireless Bureau called for “radical reworking of the MDS and ITFS regulatory structure” if advanced wireless services were to be viable at 2.1 GHz and 2.5 GHz. At WCA show in July, Wireless Bureau Chief Thomas Sugrue urged industry to provided proposal on rule changes by Sept. Plan calls on Commission to eliminate “unnecessary regulatory burdens” imposed by site-by-site licensing of all MDS and ITFS facilities. Rules, adopted in 1980s, are akin to those for TV and required prior Commission approval on site-by-site basis before almost any new or altered facilities could be deployed. Rules also imposed “highly conservative interference protection rules,” mandated complex interference analyses demonstrating compliance and created substantial gap between submission of application and grant of FCC approval, groups. Two-way licensing decision by FCC 4 years ago allowed “routine licensing” of MDS and ITFS stations for 2-way broadband video, voice and data services. But White Paper said FCC still required applicant to undertake highly restrictive interference analyses. They are “based on so many worst-case assumptions that it has proved virtually impossible for system operators to provide ubiquitous coverage within their territories,” proposal said.

White Paper calls on FCC to: (1) Do away with “unnecessary regulatory burdens” imposed by site-by-site licensing. (2) Change interference protection rules that groups say have had unintended effect of barring operators from providing ubiquitous 2-way wireless service throughout licensed area. (3) Create flexible band plan to accommodate one-way high-power, high-site operations while allowing advanced 2-way cellularized operations to roll out. Paper sought technical rules that would assure each type of service that it could operate without interference from other. (4) Eliminate 40-year-old interleaving channelization plan that barred “efficient utilization of spectrum.”

Proposal said existing first generation technology used approach that required line-of-sight between high-power base station and subscriber antenna. Among other limitations, that has meant pizza-box-sized receivers at customer locations that must be installed professionally. Groups said 2nd-generation equipment could operate at such low power levels that it could be attached to portable devices such as laptop PCs and personal digital assistants. Paper said first-generation supercell systems typically required 6-12 applications apiece to get off ground. “Because 2nd- generation technology utilizes a more highly cellularized network architecture, it will take orders of magnitude more applications to license a single densely populated market for 2nd-generation service under the current system,” proposal said. Groups said it could take 2,000 applications under existing rules to fully license 2.5 GHz for 2G system in one major market. By comparison, FCC’s first filing window for 2-way services brought in 2,267 applications.

Proposed band plan addresses similar type of interleaving spectrum issue as is at stake in Nextel rebanding proposal at 800 MHz, which involves public safety operations interleaved with specialized mobile radio operations. “The new band plan has been designed to provide every licensee with the same quantity of spectrum it currently has under the interleaved band plan, but to distribute that spectrum in a contiguous manner among different segments of the new band plan,” White Paper said. Band plan includes lower segment with twelve 5.5-MHz channels at 2500-2566 MHz and middle segment with seven 6-MHz channels from 2572-2614 MHz. Plan also has upper segment with twelve 5.5-MHz wide channels from 2620-2686 MHz. Plan anticipates “active secondary market,” with operators that want additional spectrum in lower and upper band able to swap capacity in middle segment for additional channels. Alternately, operators that are focused on high-power, high- site operations for advanced services could swap lower and upper band channels for additional spectrum in middle, groups said.

White Paper recognizes that “interweaving of high power, high site one-way operations with cellular [2-way] services just doesn’t work and that the interference protection issues impose a terrible burden on people doing more cellular services,” said Paul Sinderbrand, outside counsel for WCA. “Our objective was to provide a mechanism by which high- power, high-site operations can continue without imposing tremendous burdens on people looking to do cellularized services.” In some cases, ITFS operators are interested in continuing to provide high-power, high-site video and data distribution services to perform tasks such as providing classroom services on video basis. In other cases, ITFS operators are looking to cellularized systems to provide more advanced data services, Sinderbrand said.

Plan also said it would give commercial and education system operators ability to use frequency division duplex (FDD) or time division duplex (TDD) services, referring to common mobile wireless technologies that would be allowed under flexibility that FCC permitted among operations at 2.5 GHz. “Given the desire of WCA, NIA and CTN to allow the marketplace to decide how the 2.5 GHz band should be allocated among FDD and TDD technologies, the challenge has been to… identify the band plan that achieves the best balance,” White Paper said. As result, proposal remains technology agnostic and doesn’t favor one technology, such as FDD or TDD, over another.