Before the Federal Communications Commission ... RDOF...take advantage of the package bidding rules...
Transcript of Before the Federal Communications Commission ... RDOF...take advantage of the package bidding rules...
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A. The Commission Should Not Rely on Outdated Information in its Assumptions About the Capabilities of Providers .................................................. 9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. [email protected] | 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. [email protected] | 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
[email protected] | 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
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 | [email protected] | 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 | [email protected] | ccsl.com
*Product is Pending FCC Certification