What’s Driving Innovation in
Rural Broadband?
Steve Coran – Lerman Senter PLLC
Jimmy Carr – All Points Broadband
Ted Osborn – WISP Partners
Matt Larsen – Vistabeam
Rick Harnish – Baicells
2
Disclaimer
 This presentation is not intended to create an attorney-client relationship. The
information contained in this presentation is general and is not offered as legal
advice.
 You are strongly encouraged to consult with an attorney if you have specific
questions.
 Any reliance on the information in this presentation is taken at your own risk.
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Abstract - Converging Developments
How will the convergence of the Connect America Fund, Citizens Broadband Radio Service, and Long
Term Evolution innovate broadband access for rural America?

The FCC has adopted the highly-innovative shared use model for putting under-utilized spectrum to
work for Broadband Wireless Access (BWA) applications.

In the Citizens Broadband Radio Service (CBRS), affordable spectrum assets are becoming
available to a wide range of existing and new entrants that serve broadband access in rural
markets.

A new Spectrum Access System (SAS) is driving innovation in radio technology using standardsbased (LTE) equipment that promises to deliver 100 Mbps performance to Internet users soon.

Notably, the Connect America Fund (CAF) Phase II Reverse Auction promises to make available $2
billion in Federal support to serve up to 1.5 million rural locations.
Capital, spectrum, and technology coming together in 2018 will change
how rural Americans become connected with true broadband access.
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Converging Developments
 FCC is readying the Connect America Fund Phase II auction
 FCC has made 100 megahertz of new commercial spectrum available in the
Citizens Broadband Radio Service (3550-3650 MHz band) for fixed and mobile
broadband services
 Three-tier dynamic Spectrum Access System to protect incumbents, enable
geographic licensing in small areas and allow “license by rule” and opportunistic
“use it or share it” spectrum access
 Trials ongoing, standards under development, equipment investment and
innovation
 LTE is being developed for fixed-wireless applications.
5
Converging Developments
 Together, more spectrum, new standards-based technology and federal subsidies
will be game changing
 These three developments will significantly improve broadband for rural Americans
CAF Phase II
7
CAF Reverse Auction – Brief History
 In August 2015, price cap carriers either accepted or declined “statewide
commitment” to provide voice and broadband in their study areas
 Of the $1.675 billion per year available, carriers elected to receive $1.5 billion
 Performance standards initially include 10/1 speed, 100ms latency and 100 GB
usage
 No technology restrictions
 Remainder available for Phase II competitive bidding
 Price cap carriers permitted to participate in auction
8
CAF Phase II Auction – Overview
 On May 25, 2016, FCC unanimously adopted a Report and Order adopting
framework for auction and Further Notice of Proposed Rulemaking seeking
comment on distinct issues
 Order includes significant changes from September 2015 draft which would
have favored fiber and limited participation by small providers
 Order represents substantial input from WISP and cable industries
 Grant proceeds amount to $198M per year over 10 years, or ~$2B
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Where Support is Available
Source: FCC August, 2016 (preliminary map showing gold areas have remaining subsidy – actual locations WILL vary)
State
10
AL
AR
AZ
CA
CT
CO
DC
DE
FL
GA
HI
IA
ID
Il
IN
KS
KY
LA
MA
MD
ME
MI
MN
MO
MS
US
Subsidy
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Locations
7,582,914
18,310,903
15,380,985
72,342,251
378,833
25,689,065
31,692
1,201,949
9,656,758
11,464,020
1,168,445
32,136,300
25,500,335
92,204,012
19,145,236
32,266,415
4,486,634
6,332,018
4,281,935
7,275,381
4,351,142
13,772,931
28,611,828
73,460,689
9,969,373
15,282
26,550
11,139
88,096
862
28,802
114
4,275
21,139
22,428
805
34,672
31,780
105,460
48,414
30,526
11,320
8,705
12060
20,108
3698
35,115
30,724
112,836
18,116
Total Annual
Reserve Price
Total
Locations
$ 956,648,681
1,415,584
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Reserve /
Location
496
690
1,381
821
439
892
278
281
457
511
1,451
927
802
874
395
1,057
396
727
355
362
1,177
392
931
651
550
State
MT
NC
ND
NE
NH
NJ
NM
NV
NY
OH
OK
OR
PA
RI
SC
SD
TN
TX
UT
VA
VT
WA
WI
WV
WY
Subsidy
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Locations
9,307,580
2,351,516
3,694,185
21,319,496
762,821
1,716,172
16,033,097
17,079,055
29,956,175
14,610,674
66,686,357
23,423,828
37,399,786
182,569
2,143,998
4,366,399
4,701,381
64,780,798
6,045,243
33,878,672
519,953
26,465,143
14,198,179
31,896,473
23,127,086
7,312
7,234
3,477
16,808
1360
3,675
18,502
20,706
76,580
33,152
112,511
24,204
88,898
573
3,584
4,589
13,010
100,050
5,505
98,736
1,128
32,595
17,373
52,736
24,840
Total Annual
CAF Budget
Budget /
Reserve
$ 198,000,000
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Reserve /
Location
1,273
325
1,062
1,268
561
467
867
825
391
441
593
968
421
319
598
951
361
647
1,098
343
461
812
817
605
931
20.70%
Source: FCC Public Notice, August 2016 (Preliminary List – actual amounts WILL vary)
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Source: FCC Public Notice, August 2016 (Preliminary List – actual amounts WILL vary)
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CAF Phase II Auction –
Performance Standards
Performance
Tier
Speed
Monthly Usage
Allowance
Bid Weight Rule
Minimum
≥ 10/1 Mbps
≥150 GB
65
Baseline
≥25/3 Mbps
≥150 GB or U.S. median,
whichever is higher
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Above
Baseline
≥100/20 Mbps
2 TB
15
Gigabit
≥1 Gbps/500
Mbps
2 TB
0
13
CAF Phase II Auction –
Performance Standards
Latency
Requirement
Bid Weight
High
≤ 100 ms
0
Low
≤ 750ms & MOS ≥ 4
25
14
CAF Phase II Auction –
Build-Out Requirements
Year 1
**%
Year 2
**%
Year 3
40%
Year 4
60%
Year 5
80%
Year 6
100%
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CAF Summary
Citizens Broadband Radio
Service
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Why Should I Care
 100 megahertz of “new” spectrum adjacent to “known”
band
 Ability of existing 3650-3700 MHz licensees to register new
locations
 Glide path to new spectrum is driving LTE development, and
LTE development is driving network expansions in 3650-3700
MHz band
 Novel spectrum sharing paradigm sets the stage for similar
approaches in other bands
 Potential for subsidized deployment through upcoming
Connect America Fund reverse auction
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Stakeholders

WISPs that want additional spectrum for fixed broadband, but do not want
disruption to 3650-3700 MHz band Mobile wireless interests that want
spectrum for “small cells”

Utilities that want additional spectrum for mission critical communications,
but do not want disruption to 3650-3700 MHz band

Satellite interests that want to ensure interference protection to earth
stations

Government interests that want to ensure that military uses are protected
from harmful interference

New entrants and public interest advocates that champion unlicensed
spectrum
Spectrum Management
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
Foundation of rules is a three-tiered database-controlled Spectrum Access System (SAS)


Incumbent Access

Navy radar systems along coastlines and ground-based military radar to be protected by
Environmental Sensing Capability (ESC), which senses noise/interference or operating presence
within a defined area where there may be interfere with the operation of an Incumbent

Licensed fixed satellite earth stations to be protected geographically
Priority Access – licensed use, but protects incumbents


Licenses to be awarded by competitive bidding
General Authorized Access (GAA) – “license by rule” for designated spectrum and opportunistic use

Not unlicensed

But like unlicensed, no explicit grant of license required; just operate per SAS instructions

SAS is required to “facilitate coordination” among GAA users as well as protect Incumbent and
Priority Access users
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Band Plan
3550-3650 MHz
3650-3700 MHz
Incumbent Access – Military and FSS Earth Stations
Coastal Areas, Military Bases, Fixed Earth Station Sites
PAL Limit = 70 MHz
GAA = 30 MHz or more
No PALs
GAA = 50 MHz
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Licensing

Priority Access Licenses (PALs)
 Assigned by census tracts through competitive bidding
 10-MHz channels assigned dynamically
 40-MHz cap for any one PAL holder in a census tract
 Three-year license term with no renewal right
 Can acquire two three-year licenses in first
application window
 No build-out requirements
 “Use it or share it” obligations
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Licensing
General Authorized Access





Available in every census tract and assigned where there are no
PALs
 At least 80 megahertz (≥30 MHz in 3550-3650 MHz, 50 MHz in
3650-3700 MHz)
 However, in a few places existing FSS operation down to 3600
MHz must be protected
Assigned opportunistically where and when PALs are not “in use”
 Where – anywhere within default contour protection of -96
dBm/10 MHz around each PAL CBSD as determined by SAS
 When – PAL CBSD discontinues service for more than seven
days
Must defer to Incumbent and PAL use under the control of SAS
SAS may or may not identify and resolve interference among
GAA users
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Diversity of Technologies in CBRS



CBRS requires some CBSD specific functionality, and FCC
equipment approval, but the air-interface and choices for
technology can be diverse.
Rules reflect FCC belief that opening access will invite more
vendors and diversity of uses
Diversity of Technologies

LTE (Different Variations)

Proprietary (Waveform) Air Interfaces

New Technologies to be Added by Database and FCC
Approval
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Spectrum Use

Categories of CBSDs
Category A (small cells)
 Lower power
 Need only report EIRP to SAS

Category B
 Higher EIRP
 Outdoor only with professional installation required
 More detailed information reported to SAS
 Permissible only when Environmental Sensing Capability (ESC)
system has been deployed near the military radar facilities


End User Devices


Operate under power control of CBSD
Not required to communicate directly to SAS, but must be able to
receive and decode instructions from CBSD such as frequencies and
power limits
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Uses and Restrictions
CBSD
Category
End User
Device
Category
A
Category B
Maximum
EIRP
CBSD Installations
(dBm/10
MHz)
Operations in
3550-3650 MHz
Operations in
3650-3700 MHz
Everywhere Outside DoD
Protection Zone
Everywhere Outside FSS
and DoD Protection Zone
Outside DoD Protection
Zone & requires ESC
approval
Everywhere Outside FSS
and DoD Protection Zone
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30
47
- Indoor
- Outdoor max
6m HAAT
- Outdoor only
- Professional
Installation
Fixed Wireless LTE
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NLOS (NON-LINE-OF-SIGHT) CHALLENGES
 POWER
 In the USA & Canada, regulatory regions require wireless technology to operate at
greatly reduced power relative to those operators like mobile carriers who hold
expensive licensed bands. Despite this, wireless technologists have created
workarounds to service difficult-to-reach populations.
 DISTANCE
 Wireless signals weaken over distance – a process called “attenuation.” This occurs in
a step-like manner, where enough attenuation means the signal drops to progressively
lower and lower levels, with each level down reducing the ability of the signal to
deliver data. With trees in the way, blocking lines-of-sight, low power signals are both
scattered and absorbed by leaves, modulating the signal down to useless levels.
Those who can beat NLOS and the associated attenuation by using LTE, win in the
marketplace.
 DESIGN
 Unlike Wi-Fi, LTE was designed for outdoor wireless, not indoor wireless local networks.
This means LTE signals are able to hold higher modulation levels in the face of more
foliage, and do a better job of collecting all the various reflections off leaves to
make sense of the signal. LTE does such a better job in fact that it holds about a 7 dB
advantage over Wi-Fi on a per modulation basis, a massive benefit of LTE.
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BENEFITS OF A STANDARD
 PRICE
 We are all carrying LTE-enabled devices in our purses and pockets. LTE, in just a few short years, has
displaced all other mobile technologies. The global drive for all carriers to use LTE for its
technological advantages also means the entire globe is unifying around a single standard, and
with such mass comes higher profits and lower costs. It also results in more vendor choices,
preventing companies from the deadly risk of vendor lock where one vendor holds an operator
hostage at the mercy of one company’s limited R&D and customer service.
 INNOVATION
 The influx of LTE devices has resulted in massive continuing investments by all parties to bring new
services and build new devices. It’s an explosion in innovation and we are only at the beginning of
the LTE revolution. Those who get on board now with LTE will be able to take advantage of untold
new efficiencies, products, and services that emerge. Over $1 billion is invested annually in LTE R&D,
and being standard, every new leap will be backward compatible – meaning no single vendor can
put your entire CAPEX investment at risk of obsolescence or by its failings in the marketplace.
 SPECTRUM
 New spectrum opened by regulators in the U.S. called the Citizens Broadband Radio Service (CBRS)
band (3.55 GHz- 3.7 GHz) will enable small operators to build their own private networks that can
have frequency protection similar to what mobile carriers now enjoy in their licensed spectrum. The
new CBRS band lets cities and towns and oil field operators, etc. the ability to shed these onerous
carrier contracts for the first time by allowing them to build their own private, frequency-protected
networks. What technology will dominate this space? LTE. LTE will be the pervasive choice in CBRS
because of its technical advantages outdoors, its vendor flexibility, its growing set of devices, its
backward compatibility, and its low cost.
An Operator’s
Perspective
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Discussion
How will CAF, CBRS, and LTE change broadband in rural America?
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Thanks!