Response to the "Consultation on Repurposing the 600 MHz Band" Canada Gazette, Part I SLPB December, Submitted By: Ontario Limited

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1 Response to the "Consultation on Repurposing the 600 MHz Band" Canada Gazette, Part I SLPB December, 2014 Submitted By: February 26th,

2 DISCLAIMER Although efforts have been made to ensure the accuracy of current spectrum allocations, assignments, services and applications, the authors cannot warrant the quality, accuracy, or completeness of any information, or data in this document and assume no responsibility for any possible errors or omissions. It is the responsibility of all persons who use this report to independently confirm the accuracy of the data, information, or results obtained through its use. In no event will the Authors, its Directors, Employees, and Agents; or its employees, servants or agents have any obligation to the user for any reason including claims arising from contract or tort, or for loss of revenue or profit, or for indirect, special, incidental or consequential damages arising from the use of this information. This report is being submitted with the intent that it be readily available for personal and public noncommercial use. 2

3 Executive Summary There is general support for the policy objectives of Industry Canada that seek to maximize the economic and social benefits that Canadians derive from the use of the radio frequency spectrum. We understand that spectrum management practices, including licensing methods, should respond to changing technology and marketplace demands. In addition, spectrum policy and management should support the efficient functioning of markets by permitting the flexible use of spectrum to the extent possible and by making spectrum available for use in a timely fashion. Industry Canada's "Commercial Mobile Spectrum Outlook" report clearly illustrates the rapid growth of commercial mobile services in Canada, which presents significant economic and social benefits for Canadians. Although this consultation addresses issues related to the repurposing of spectrum in the 600 MHz band to mobile use, there is no mention of an "incentive auction" as proposed by the Federal Communications Commission ("FCC") in the United States. In the absence of such incentives it is likely that incumbent television Broadcasting Distribution Units ("BDUs"), will propose arguments to protect their legacy interests. Current users include over-the-air ("OTA") television broadcasting, remote rural broadband systems (RRBS), low-power apparatus (e.g. wireless microphones and camera systems), television white space (TVWS) devices and wireless medical telemetry systems ("WMTS"). This spectrum is also used for radio astronomy service ("RAS"). Industry Canada is not considering any change to the allocation of spectrum to the RAS (band MHz) at this time. In its April 2014 Notice of Consultation, the CRTC noted that given the high subscription rates to cable and satellite providers in most markets, only a few Canadians rely on television signals over the air. Nevertheless much valuable spectrum continues to be "reserved" for this very small audience, and that needs to change if the value proposition for Canadians is to be respected. The lack of a business case for OTA television transmission was previously demonstrated by the attempt of Industry Canada, over ten years ago, to encourage over-the-air digital television services in the 2600 MHz band, as a successor to analog transmission in the VHF/UHF bands. Companies that invested in this broadcast distribution model included Craig Wireless and LOOK Communications, both of whom subsequently sold their MCS spectrum licenses to Inukshuk, leading the way to re-assignment of that band by Industry Canada to mobile spectrum later in that decade. It can be assumed that the business case for MCS television broadcast transmission remained unproven. A similar reassessment of the spectrum allocated to VHF/UHF television channels is long overdue. 3

4 Question 1: Industry Canada is seeking comments on the overall proposal of repurposing the band to include commercial mobile broadband and the initial step of participating in a joint repacking process with the United States. The excellent radio frequency propagation characteristics of the 600 MHz band make it highly suitable for wide area communication systems for mobile wireless applications providing extensive geographical radio coverage with proportionally fewer cell towers. Although Industry Canada has long licensed 850 MHz spectrum (and more recently 700 MHz spectrum) for these purposes the astounding uptake of smart phones ensures that there are many users in small towns and rural (and remote) areas that can make benefit from such services. For the spectrum to become useful it requires a new generation of smart phones and other devices with 600 MHz transmission and reception capabilities needs to be developed, this will only be possible if the 600 MHz bands are identical between Canada and the USA, therefore Industry Canada should participate in the joint repacking process with the FCC. Question 2: Industry Canada is seeking comments on the future spectrum requirements for OTA TV broadcasting, taking into consideration the overall changes to the broadcasting industry, and noting that the CRTC Let s Talk TV hearing recently closed. As mentioned earlier, it would be helpful to identify the actual number of Canadian homes that rely solely on over-the-air television transmissions in order to be able to answer this question definitively. It is thought that the number is very small, and should not include the even smaller audience that prefer to watch uncompressed digital television video feeds, rather than digital cable or satellite programming. It is important to also consider the newer methods available to broadcasters, such as video streaming on the internet (Netflix, YouTube, CraveTV and Shomi), and the newer wireless technologies such as enhanced Multimedia Broadcast/Multicast Service ("embms") coming soon to wireless carriers in Canada, not to mention satellite television from Shaw and Bell ExpressVu. The future terrestrial spectrum requirements for OTA television services likely will be very small, and legacy services should not continue to be licensed based on the mass television audiences of 60 years ago! 4

5 Question 3: Industry Canada is seeking comments on the Department s proposal to: adopt the U.S. 600 MHz band plan framework; and commit to repurpose the same amount of spectrum as the United States, as determined in the FCC s incentive auction. If Canadians are to benefit from a revised 600 MHz band plan (as proposed by the FCC), it is imperative that the framework for the band plan be aligned with the USA, and ideally the same amount of spectrum should be made available. The Canadian market for consumer goods (like smart phones) is too small to interest large electronics manufacturers in providing a "Canada only" solution, hence the North American market dominates the products made by smart phone suppliers like Apple and Samsung, and Canada needs to be aligned with the USA. Figure 1 FCC 600 MHz Band Plan As shown In Figure 1, there is a duplex guard band 11 MHz wide separating the base station spectrum from the mobile phone spectrum, thus it protects against both 5 and 10 MHz LTE signals. Channel 37 is shown in yellow as it was never allocated for TV by international agreement. So it serves as a guard band, but it is too narrow (6 MHz) to protect against interference from a 10 MHz-wide LTE base station signal, so the FCC added 3 MHz (614 to 617 MHz) above channel 37, widening this guard band to 9 MHz. Guard bands are created only where needed because such spectrum cannot be used nor auctioned. 5

6 Question 4: Industry Canada is seeking comments on the size of the proposed guard band between the TV broadcasting and mobile services. Is the mobile service appropriately protected by the proposed guard band? Is the TV broadcasting service appropriately protected by the proposed guard band? If additional protection measures are needed, what alternatives (such as increasing the size of the guard band, adding a pass band/notch filter at the TV receiver port, etc.) could be used and what alternatives would be practical to deploy? These questions will be addressed as the FCC moves towards the incentive auction, planned for 2016 and it is suggested that Industry Canada both observes and participates in the discussions as they occur. We recommend that these technical questions be addressed by the Radio Advisory Board of Canada, in order to ensure that a balanced view of the co-channel and adjacent channel interference issues are addressed. It is important to note that the proposed mobile band plan is allocated in 5+5 MHz FDD channels, but the TV channel assignments remain in 6 MHz blocks, thus there will always be some interference issues between adjacent services in this band. The most recent FCC Public Notice (FCC ) of December 17th, 2014 (Appendix B) provides additional details of the Inter-Service Interference ("ISIX") and provides a method for calculating service impairment thresholds used to determine constraints to be considered in the US 600 MHz incentive auction planned for Question 5: Industry Canada is seeking comments on the proposed transition policy for the regular power TV stations, including but not limited to the design objectives for the development of the new DTV allotment plan; the methodology and parameters to ensure minimal impact to TV reception; the minimum notification period for the relocation to the new DTV assignments; and the overall timing for the transition to the new DTV allotment plan. No Comment. 6

7 Question 6: Industry Canada is seeking comments on the proposed transition policy for LPTV undertakings in the spectrum to be repurposed to mobile use. No Comment. Question 7: Industry Canada is seeking comments on the proposed transition policy for LPTV undertakings below the 600 MHz band. No Comment. Question 8: Industry Canada is seeking comments on the proposed transition policy for RRBS. Two distinct strategies for utilization for "unused TV channels" have been developed by Industry Canada over the last several years. The purpose was to make spectrum available outside the broadcast areas of TV stations for rural and remote broadband use. The first strategy allowed fixed broadband systems to be licensed under regulations for "Rural and Remote Broadband Systems" such as RSS-196 Issue 1 in March 2010, and SRSP Issue 1. Nomadic or mobile devices are not allowed, These systems operate in the MHz Band and the MHz Band and use one or more 6 MHz channels. There are no equivalent regulations in the USA, and consequently the equipment ecosystem is limited to the small Canadian market. More recently Industry Canada has adopted new rules for use of unused TV channels - also known as TV Whitespace, rules that are very similar to those established by the FCC. The rules have been established as follows: Provide for both fixed and personal/portable devices to operate in the TV white spaces on an unlicensed basis, but the specifics are managed by the TVWS database administrators Devices must include a geo-location capability (either with GPS built in or by connection to another device) and capability to access to a database of protected radio services Devices provide their location to their database, which returns a list of channels on which they may operate (channel lists are specific to the location of the device) Devices must complete the database access process before operating Databases will be established and administered by third parties after selection by Industry Canada through a public notice process that solicited interested parties. 7

8 Additionally there are provisions to mitigate interference Fixed devices must register their locations in the database Fixed and personal/portable devices must provide identifying info to the database Devices cannot transmit without checking database and must recheck periodically (24 hours) All devices must include adaptable power control to use the minimum necessary power and be certified by IC under Radio Standards Specification ("RSS") 222 It remains to be seen how the TV Whitespace equipment ecosystem will develop over the next several years, but the potential market (North America) is very large, and there are new projects related to the "Internet of Thinks" that some observers believe will drive the use of TV Whitespace spectrum. It is therefore suggested that the moratorium for new RRBS licenses be maintained, and this question re-visited in 2017, after the US 600 MHz incentive auction is complete. Question 9: Industry Canada is seeking comments on the proposal to update the Canadian Table of Frequency Allocations by adding co-primary allocations to fixed and mobile services in the MHz and MHz ranges. Industry Canada's suggestion to add co-primary allocations for mobile and fixed services in the MHz band is the correct choice. [END OF DOCUMENT] 8

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