Ruckus Wireless response to ACMA - Future use of the 1.5 GHz and 3.6 GHz bands

Consultation Response To

The Australian Communications and Media Authority

IFC 25/2016 - Future use of the 1.5 GHz and 3.6 GHz bands

7th December 2016

Response prepared by

David Wright

Principal, Strategy and Standards

Ruckus Wireless Inc.

Andrew Cook

Business Development Director, ANZ

Ruckus Wireless Inc.

Table of Contents

About Ruckus Wireless

Executive Summary

General responses to ACMA questions and discussion

Responses specific to the 1.5 GHz band:

Responses specific to the 3.6 GHz band:

About Ruckus Wireless

Ruckus Wireless is a leader and innovator in the wireless and mobile broadband space serving over 65,000 enterprise, service provider, government and small business customers worldwide. The Ruckus Wireless business unit at Brocade is focused on technology innovation, partner ecosystems, and customer service—yielding the best possible wireless experience for the most challenging indoor and outdoor environments.

In February 2016 Ruckus Wireless partnered with Federated Wireless, Google, Intel, Nokia, and Qualcomm to develop, market and promote solutions utilizing the U.S. 3.5 GHz Citizens Broadband Radio Service (CBRS). The six companies involved believe that CBRS will be critical to drive innovation, support new business models and spur economic growth within the US. Similar approaches would significantly benefit Australia.

Ruckus is also a key player in several industry forums defining emerging business models, processes and technologies to meet tomorrow’s needs. Notably, this includes the Wireless Broadband Alliance where Ruckus leads several projects including the Coordinated Shared Spectrum (CSS) project to introduce new models for spectrum management that would provide coordinated use of shared spectrum. A key objective of these programs is to provide conditional access to portions of spectrum with varying levels of priority based upon status (e.g. incumbents, priority users, general users).

Thus, Ruckus believe we are well placed to provide consultation to the ACMA regarding the re-planning of the 3.6 GHz band, and the many benefits that would flow from that.

Executive Summary

As a general statement, Ruckus makes no comment on the merits or approaches to the re-planning of the 1.5 GHz bands.

We highly recommend progressing the re-planning of the 3.6 GHz band as a priority to provide additional spectrum for MBB services;

  • That the progression to re-planning stage should be prioritised and undertaken independently of (at least not dependant on) any consideration of the 1.5Ghz band
  • That the re-planning, to the greatest extent possible, should align and be consistent with international usage (and specifically the US CBRS usage);
  • For most efficient utilization of the spectrum, and to achieve its highest use, the entire 3.6 GHz band should be considered for re-farming.
  • If certain portions of the band need to be excluded at certain geographic areas, or incumbent services, a coordinated shared spectrum approach could address those cases.

Several factors support the progression of the 3.6 GHz through ACMA’s process, including:

  • Strong and growing momentum in many areas of the world to deploy TDD-LTE services in the frequency range under consideration
  • The lightly used nature of the incumbent services, in terms of geography and/or bandwidth
  • Technology advances that enable dynamic coordination of spectrum access, while providing interference protection for incumbent operations.

We highly recommend that ACMA explore the development and deployment of Coordinated Spectrum Sharing (CSS) arrangements to significantly improve the utilisation and flexibility for spectrum allocation.

  • In addition to providing for ongoing operations of the existing primary users, we encourage ACMA to consider a spectrum sharing framework that would support new MBB services operated by both traditional mobile network operators as well as alternative service providers.
  • This would provide much greater flexibility and granularity in terms of spectrum licenses, authorisation, and geographic allocation. As an example, CSS would allow ACMA to redefine the granularity of spectrum and license allocation from a state, metro or regional basis as is done today, down to a per-building (or finer) level

General responses to ACMA questions and discussion

  1. Should the 1.5 GHz band and/or the 3.6 GHz band be progressed from the initial investigation stage to the preliminary re-planning stage in the ACMA’s process for consideration of additional spectrum for MBB services? Why/Why not?

The 3.6 GHz band should be progressed to the preliminary re-planning stage for consideration as additional spectrum for MBB services. We do not have an opinion on progressing the 1.5 GHz band.

Several factors support the progression of the 3.6 GHz through ACMA’s process, including:

  • Strong and growing momentum in many areas of the world to deploy TDD-LTE services in the frequency range under consideration
  • The lightly used nature of the incumbent services, in terms of geography and/or bandwidth
  • Technology advances that enable dynamic coordination of spectrum access, while providing interference protection for incumbent operations.
  1. Should either of the 1.5 GHz and 3.6 GHz bands be prioritised through the ACMA’s process for consideration of additional spectrum for MBB services? If so, which band? Why?

Yes, the 3.6 GHz band should be prioritized through the ACMA’s process for consideration as additional spectrum for MBB services.

There is a significant ecosystem which has already formed to deliver coordinated shared spectrum TDD-LTE MBB services for the 3550-3700 MHz CBRS band in the US. Participants include RAN vendors, spectrum management system providers, and mobile client vendors. These companies have come together in at least two industry organizations, the Wireless Innovation Forum and the CBRS Alliance, to develop standards and commercialize the band. As ACMA noted, efforts are also underway within 3GPP to standardize a new band plan specifically for 3550-3700 MHz. This work may be leveraged to accelerate the commercialization of the 3.6 GHz band for MBB in Australia. Additionally, ACMA may be able to influence these organizations to adapt their specifications to the specific requirements of the 3.6 GHz band in Australia. As these efforts are well underway, the sooner ACMA acts, the better.

  1. Are there specific issues, other than those mentioned, that may affect the timeframe in which the 1.5 GHz or 3.6 GHz bands could be made available for MBB?

MBB services rely upon a complete ecosystem of mobile core services, Radio Access Network (RAN) infrastructure. Because of the 3GPP standardization of B42 and B43, and the significant industry momentum towards commercializing the 3.5 GHz CBRS band in the US, all three of the MBB ecosystem areas are rapidly appearing in the market for the 3.6 GHz band. B42 clients are available today in Japan to support the MBB deployments by Softbank, NTT Docomo, and KDDI.

Responses specific to the 1.5 GHz band:

  1. If the 1.5 GHz and 3.6 GHz bands are re-farmed for MBB, would there be benefit in allocating the bands simultaneously?

There would be no obvious benefits to allocating both bands simultaneously.

  1. The ACMA seeks comment on expected future use of the 1.5 GHz band by the fixed, broadcasting and broadcasting-satellite services and by the Department of Defence in Australia.

No comment.

  1. Comment is sought on the potential deletion or modification of footnote AUS3 from the ARSP.

No comment.

  1. If the 1.5 GHz band is re-farmed for MBB services, what frequency arrangement should be adopted? Should a frequency division duplex (FDD), supplemental downlink (SDL) or time division duplex (TDD) arrangement be adopted? Why/why not? What type of arrangement should be adopted (that is, 3GPP bands 11 and/or 21, 3GPP band 32, 3GPP band 45 or another arrangement)?

No comment.

  1. If the 1.5 GHz band is re-farmed for MBB services, what geographical areas should be re-farmed? To what extent are mobile network operators (MNOs) interested in the 1.5 GHz band outside of metropolitan areas?

No comment.

  1. If the 1.5 GHz band is re-farmed for MBB services, should a geographically and/or spectrally staged process be considered, where more heavily utilised parts/areas are re-farmed later than those that are more lightly utilised?

No comment.

  1. What are the alternative spectrum or delivery options for current users of the 1.5 GHz band if the band is re-farmed for MBB services and migration of existing services is required?

No comment.

  1. Could services, in particular fixed services, provided in the 1.5 GHz band be migrated to new or existing mobile networks in areas where the band is re-farmed for MBB services?

No comment.

  1. Should existing users (some or all) be allowed to continue operation within the band either temporarily or on an ongoing basis?

No comment.

  1. What types of sharing arrangements could be put in place to facilitate coexistence between MBB services and existing users of the 1.5 GHz band in both the short and long term?

No comment.

  1. Comment is sought on the ACMA’s proposal to progress the 1.5 GHz band to the preliminary re-planning stage of its process for consideration of additional spectrum for MBB services, as detailed in the ACMA’s mobile broadband strategy.

No comment.

  1. To assist the ACMA in conducting a comprehensive assessment of the highest-value use for the 1.5 GHz band, responses to the following questions are requested:
  1. Do you see demand for fixed broadband/MBB services in the 1.5 GHz band?
  2. What benefits do you envision from using the band for fixed broadband/MBB services?
  3. What are relevant data points (for example, market-based allocation results) for considering the demand for 1.5 GHz band spectrum for use by MBB providers?
  4. Is demand the same or similar across regions (that is, across metropolitan, rural and remote areas), or are some regions more likely to be in demand for MBB providers?
  5. Do incumbent 1.5 GHz band licensees require ongoing access to the band, or are there plans to cease operation at some future point?
  6. Do other options exist for the delivery of point-to-point, point-to-multipoint, fixed receive, aeronautical and radiodetermination incumbent services? How practical are they? What are the costs involved? Will there be a diminution of the service delivered if MBB services are introduced in the band?

No comment.

Responses specific to the 3.6 GHz band:

  1. The ACMA seeks comment on expected future use of the 3.6 GHz band by fixed, fixed-satellite, amateur and radiolocation services in Australia.

No comment.

  1. If the 3.6 GHz band is re-farmed for MBB services:
  1. Do you agree that a time division duplex (TDD) arrangement should be adopted? Why/Why not?
  2. Should all or only part of the band be considered for re-farming?
  3. Should different amounts of spectrum be re-farmed in different areas?
  1. Yes, TDD arrangements for the 3.6 GHz band should be adopted. This will align well with the existing ACMA arrangements in the 3400-3575 MHz frequency range, will align well with the 3GPP Band 42 and Band 43 TDD definitions, and also align with the TDD services that are planned for the 3550-3700 MHz frequency range in the US with CBRS.
  2. For most efficient utilization of the spectrum, and to achieve its highest use, the entire 3.6 GHz band should be considered for re-farming. If certain portions of the band need to be excluded at certain geographic areas, a coordinated shared spectrum approach could address those cases.
  3. As noted above, we believe that the entire band should be re-farmed for MBB services. A coordinated shared spectrum approach could be implemented to address the need to exclude portions of the band in certain areas.
  1. If the 3.6 GHz band is re-farmed for MBB services, what geographical areas should be considered?

In order to support a broadly available and scalable MBB service, the arrangements undertaken for the 3.6 GHz band should apply Australia-wide. It would be especially important given the propagation characteristics in this band, its optimal use for small cell deployments, and the need to support both urban densification and in-building coverage; that all of the urban areas be included under these arrangements. Conversely, if a coordinated spectrum sharing arrangement is implemented, the geographic areas that are authorized for operation (either at a licensed or opportunistic tier) should be as granular as possible under the spectrum management and allocation regime. ACMA may consider granting an implicit right to opportunistic use of all, or some portion, of the band for in-building use by property owners, with the requirement that such operation must not interfere with existing primary users.

  1. If the 3.6 GHz band is re-farmed for MBB services, should existing users (some or all) be allowed to continue operation within the band either temporarily or on an ongoing basis? Should/could sharing arrangements be developed? Should sharing only be considered for some services or specific licences? If yes, what kind of arrangements would be suitable to support the ongoing operation of incumbent services or specific licences? If no, why?

If a coordinated spectrum sharing arrangement were implemented, existing primary users could continue operating within the band while being protected from new MBB operations. ACMA could determine whether existing primary users would be allowed to operate under the existing arrangements on an ongoing basis, or if they would need to adapt to the new coordinated spectrum sharing arrangements by a future transition date (effectively “grandfathering” the existing arrangements for a set duration). Given the nature, number, and location of the existing primary users, the consideration for extended operation within the band should be given to the fixed point-to-point, fixed point-to-multipoint, and fixed-satellite service licensees.

The embargo on new point-to-point fixed services Australia-wide should be maintained. The embargo on new point-to-multipoint fixed service access to capital cities should be maintained and extended to cover all urban centres.

Given the very low number of existing secondary users and their proximity to major cities, ongoing operations within the band should be allowed only temporarily. After a future transition date, these existing secondary users should either confirm to a new coordinated spectrum sharing arrangement or relocate their service.

Coordinated spectrum sharing arrangements can, and are, being developed. In addition to providing for ongoing operations of the existing primary users, we encourage ACMA to consider a spectrum sharing framework that would support new MBB services operated by both traditional mobile network operators as well as alternative service providers. Such a multi-tiered sharing approach - with primary incumbent users, secondary licensed users, and tertiary opportunistic users; accommodates a wide variety of operators, deployments, and business models. Providing for opportunistic use by property owners is especially important to providing in-building coverage as it allows enterprises and venues to deploy neutral-host / multi-operator networks which can support subscribers from multiple mobile operators over a single radio interface.

  1. If the 3.6 GHz band is re-farmed for MBB services, and migration of incumbent services is required, are there alternative spectrum or delivery options?

As noted above, if a coordinated spectrum sharing arrangement were implemented we do not believe that existing primary users would need to be migrated from the band.

  1. In determining whether to re-farm the 3.6 GHz band for MBB, are there any adjacent band issues that should be considered? This includes:
  1. the effect such use may have on adjacent band services
  2. the effect adjacent band services may have on the utility of the 3.6 GHz band for MBB services.

If the MBB arrangements for the 3.6 GHz band are aligned for TDD, we do not see significant adjacent band issues at the lower end of the band. Limits would need to be defined for the upper end of the band in order to protect the FSS and fixed point-to-point services operating in 3700-4200 MHz Given that these FSS services are Earth-receive only and that the fixed point-to-point links are in remote areas, we do not foresee an impact from these services to the utility of the 3.6 GHz band for MBB services.

  1. If the 3.6 GHz band is re-farmed for MBB services, should the ACMA review arrangements in the broader 3400–3700 MHz band? Why/Why not?

While we think it may make sense for ACMA to review the arrangements in the 3400-3575 MHz band in light of re-farming the 3.6 GHz band for MBB, we do not think such a review needs to be undertaken at this time. We strongly support the implementation of a coordinated spectrum sharing arrangement in the 3.6 GHz band, which would differ from the spectrum allocation methodology utilized in 3400-3575 MHz. Once some experience has been gained with coordinated spectrum sharing in the 3.6 GHz band, a broader review could be conducted to ascertain the benefits and costs of extending these arrangements across the broader 3400-3700 MHz band.

  1. Would such a review be facilitated through the alignment of geographical boundaries in the 3.6 GHz band with existing boundaries defined for spectrum and apparatus licensing in the 3400–3575 MHz band (that is, to facilitate trading)?

As noted above, we do not feel that a review of the 3400-3575 MHz band should be undertaken in conjunction with the process of re-farming the 3.6 GHz band for MBB using coordinated spectrum sharing arrangements. However, at the time ACMA does undertake a review of the broader 3400-3700 MHz band, it should seek to align the spectrum allocation methodology, license areas, and other arrangements across the entire band to facilitate trading (i.e. a secondary market for licenses) and better utilization of the band.

  1. Is there anything else that could be considered as part of the 3.6 GHz band process that may facilitate a future review of the broader 3400–3700 MHz frequency range?

No further comment.

  1. Comment is sought on the ACMA’s proposal to progress the 3.6 GHz band to the preliminary re-planning stage of its process for consideration of additional spectrum for MBB services, as detailed in the ACMA’s mobile broadband strategy.

We agree with ACMA’s preliminary assessment that the highest-value use of the 3.6 GHz band may be changing in some areas. In fact, based on our earlier responses to Question 1, 2, and 3, we believe that there is ample evidence that this band is very well suited for MBB services utilizing a small cell / dense coverage approach and that other geographies are rapidly developing and deploying MDD solution in this frequency range. We strongly support ACMA’s proposal to progress the 3.6 GHz band to the preliminary re-planning stage for consideration to support MBB services.