November 4, 2011 Manager, Fixed Wireless Planning, DGEPS, Industry Canada, 300 Slater Street, 19th Floor, Ottawa, Ontario K1A 0C8 Email: Spectrum.Engineering@ic.gc.ca RE: Canada Gazette Notice SMSE-012-11, August 2011, entitled Consultation on a Policy and Technical Framework for the Use of Non- Broadcasting Applications in the Television Broadcasting Bands Below 698 MHz Dear Sir/Madam, 6Harmonics Inc. is pleased to submit the enclosed comments to Industry Canada s Gazette Notice SMSE-012-11. 6Harmonics strongly supports Industry Canada in opening the use of the unused TV spectrum, or so called TV White Space (TVWS) for nonbroadcasting applications. Allowing the use of TVWS for such applications will initiate a new wireless revolution that will greatly benefit Canadians through technology innovation, economic development and national competitiveness. 6Harmonics is a leading Canadian wireless innovation, design and development company with significant expertise in broadband cognitive radio and TVWS related technologies. 6Harmonics looks forward to working with Industry Canada and other interested parties to successfully implement the non-broadcasting use of TVWS, while ensuring that the incumbent services are protected. Sincerely Yours, Robert Wu CEO 6Harmonics Inc. 21 Concourse Gate Ottawa, Ontario K2E 7S4 @2010 6Harmonics Inc. All Rights Reserved 1
Contents 6Harmonics 1 Introduction... 3 2 6Harmonics Comments... 4 2.1 6-1 Comments are sought on the benefits that could be expected from making white space available in Canada... 4 2.2 6-2 Comments are sought on the benefits of the above-mentioned innovation to manage interference... 4 2.3 6-3 Comments are sought on the above proposed approach of setting technical standards now with respect to database dependent systems, and developing standards with respect to spectrum sensing devices when that technology has matured... 5 2.4 6-4 Comments are sought on these proposed provisions related to database performance and operation. Would these provisions provide sufficient capability to respond to interference cases or other problems that might occur once the white space devices are in use? Are there any additional provisions that Industry Canada should adopt?... 5 2.5 6-5 Comments are sought on the above categories... 5 2.6 6-6 Comments are sought on these proposals... 6 2.7 6-7 Comments are sought on the above proposal to broadly harmonize technical rules with those in the United States. Considering the potential benefits of such harmonization, are there areas where Canada should consider variations from the U.S. technical rules?... 6 2.8 6-8 Comments are sought on the interference protection criteria for TV broadcasting operations. Are the provisions in Table 6.2 adequate to ensure the protection of over-the-air TV broadcasting services? Should provision be made for white space devices using power control to have additional flexibility in selecting frequencies, as has been proposed in the United Kingdom?... 7 2.9 6-9 Comments are sought on the potential for improvements to the policy and technical framework for RRBS, including the possibility of moving to a license exempt regime, leveraging white space technology... 7 2.10 6-10 Should Industry Canada identify specific spectrum for use by LPA? If so, how much should be identified and should the operation of license-exempt LPA be restricted to this spectrum? 7 2.11 6-11 Comments are sought on the options for the authorization of LPA in Canada. Provide justification for this choice of option... 8 2.12 6-12 If option 1, 2 or 5 is chosen, comments are sought on the proposal to collect time and location of use data based on voluntary registration and the proposal that eligibility to register for such protection be open to all users of LPA. Comments are also sought on the appropriate protection criteria to protect LPA from interference from white space devices... 8 2.13 6-13 Comments are sought on the above proposals. Should provisions for flexible out-ofband masks, similar to the U.K. rules, also be included? Is there a need for additional measures on adjacent channels to protect systems operating at the edge of the TV bands?... 8 2.14 6-14 On balance, do the potential benefits of permitting license-exempt white space devices to operate in Canada outweigh their potential risks to other services?... 8 2.15 7-1 Comments are sought on these proposed modifications to the Canadian Table of Frequency Allocations... 8 2.16 8-1 Comments are sought on whether the measures of the FCC to protect Canadian licensees are adequate and whether Industry Canada s proposed measures are adequate to protect U.S. licensees, including TV broadcasters. Provide supporting arguments for your response... 9 @2010 6Harmonics Inc. All Rights Reserved 2
1 Introduction Canada has an excellent record and reputation in wireless communication innovation and technology development. The unused TV spectrum, or so called TV White Space (TVWS) constitutes a significant amount of prime spectrum that has not been fully exploited to date. This spectrum has some of the best propagation properties and can penetrate walls more efficiently than many other frequency bands. 6Harmonics strongly supports Industry Canada in opening the use of the TVWS for nonbroadcasting applications. Allowing the use of TVWS for such applications will initiate a new wireless revolution that will greatly benefit Canadians through technology innovation, economic development and national competitiveness. Access to this spectrum will enable a wide variety of applications, including significantly enhancing remote education, the smart grid industry, cloud computing, public safety and security, and can be used to bring faster and better internet service to many. A number of years ago, Industry Canada previously opened TV White Space (TVWS) for non-broadcasting applications in for Remote Rural Broadband Systems (RRBS). We understand that a number of successful RRBS deployments have been made using this spectrum in Canada. As noted in section 5.1 of the consultation paper, in September 2010 the FCC moved to open TVWS more broadly throughout the U.S. and established rules to do so while simultaneously protecting incumbent broadcasting services. Given the fact that our TV broadcasting system and radiocommunications environment is technically very similar to the US, and the fact that we have a long common border where both countries adjacently operate TV broadcasting services on a coordinated basis, 6Harmonics submits that it would be logical for the rules adopted by Canada to be either identical or very similar to those promulgated by the FCC in order to properly protect incumbent broadcasting and other services. @2010 6Harmonics Inc. All Right Reserved 3
2 6Harmonics Comments 2.1 6-1 Comments are sought on the benefits that could be expected from making white space available in Canada We believe TVWS can be used for a wide variety of applications, including broadband internet, remote education, telemedicine, smart grid, public safety and security, border control, e-government and innovative mobile data networks, etc. This will inspire more innovation and create more jobs and increase choice in new services and applications for users. We agree with Industry Canada that the use of this spectrum may provide availability for consumers of WiFi with significantly improved range and improved access to the Internet from lower cost wireless broadband equipment and potential future availability of innovative new products and services. We believe that TVWS will also be used to offload some portion of the large volume of mobile multimedia and data traffic that is causing congestion in the major mobile telecommunications networks today. The use of TVWS will be particularly effective assuming we parallel the U.S. fairly closely in order to maximize economies of scale, availability of devices, and export opportunities. 2.2 6-2 Comments are sought on the benefits of the above-mentioned innovation to manage interference We support the use of the registration database approach to protect incumbent services from harmful interference and believe this will result in much improved spectrum efficiency of TVWS spectrum. As Industry Canada has noted, this technique provides some important new abilities to manage the spectrum as well, such as permitting the real-time control of interference via changes to the database, which can be made quickly, and thereby allow issues to be rectified promptly. We note that FCC has authorized multiple TVWS database administrators in the U.S. Such an approach makes it important to ensure effective governance of these databases, and in particular to guarantee efficient database update and synchronization in real-time. @2010 6Harmonics Inc. All Right Reserved 4
2.3 6-3 Comments are sought on the above proposed approach of setting technical standards now with respect to database dependent systems, and developing standards with respect to spectrum sensing devices when that technology has matured The current FCC database model approach is based on TV coverage contours and geolocation rather than signal strength. In practice, this means a database-controlled TVWS device could not be used anywhere within the pre-calculated contour, including basements and well shielded places where signal strength is very low (lower than -114 dbm). However, spectrum sensing devices would continue to be able to operate in such areas. Conversely, outside the contour database TVWS devices would be permitted to operate, whereas the signal strength of the occupied TV channel may still exceed the -114dbm threshold and spectrum sensing devices would be constrained from operation. 2.4 6-4 Comments are sought on these proposed provisions related to database performance and operation. Would these provisions provide sufficient capability to respond to interference cases or other problems that might occur once the white space devices are in use? Are there any additional provisions that Industry Canada should adopt? Generally, we believe the proposed provisions are sufficient and believe that we should minimize complexity to the greatest extent possible in the early days. Experience will show if additional provisions are required down the road. Nevertheless, we believe it would be a good idea for Industry Canada to require fixed deployed TVWS devices and mobile TVWS devices to be differentiated in the database. Mobile TVWS devices will require frequent updating of location data relative to fixed deployed devices, and this may significantly save bandwidth for database inquiry. 2.5 6-5 Comments are sought on the above categories We support these device categories as they are harmonized with the U.S. We also recommend that Industry Canada clarify that fixed deployed TVWS devices and Mode-II TVWS devices can obtain available TV channel information via another fixed deployed device or another Mode-II device. @2010 6Harmonics Inc. All Right Reserved 5
2.6 6-6 Comments are sought on these proposals We support Industry Canada s proposals and harmonizing with the FCC to the greatest extent possible. Specifically, we support restricting TVWS devices from utilizing channel 37 to protect radio astronomy and medical telemetry devices and we support restricting TVWS devices from utilizing channels 3 or 4 in order to protect TV interface devices such as VCRs, DVD players, etc. We also support restricting personal/portable devices from operating below channel 21 and fixed devices operating below channel 21 to RRBS areas. 2.7 6-7 Comments are sought on the above proposal to broadly harmonize technical rules with those in the United States. Considering the potential benefits of such harmonization, are there areas where Canada should consider variations from the U.S. technical rules? We strongly support Industry Canada s proposal to broadly harmonize the technical rules with those of the U.S. We note that FCC has spent a great deal of time and effort on TVWS, including significant technical and engineering resources, to take into consideration a wide range of opinions. Multiple working groups such as IEEE and EMCA have also spent years on technical validation. The current FCC technical requirements are reasonable and technically solid. As mentioned already, this is also logical given the fact that Canada and the U.S. share a long border and our TV contours overlap and are coordinated using the same set of technical parameters. Furthermore, harmonization of our technical requirements will benefit all Canadians through better availability, choice and pricing from the resulting economies of scale and will also allow Canadian products easier access to the U.S. market as well. Because of the greater market size and earlier adoption expected in the U.S., should any unexpected technical issues arise, it is highly probable that they will manifest themselves and be identified in the U.S. first, allowing Canada ample time to determine an optimal course of action. @2010 6Harmonics Inc. All Right Reserved 6
2.8 6-8 Comments are sought on the interference protection criteria for TV broadcasting operations. Are the provisions in Table 6.2 adequate to ensure the protection of over-the-air TV broadcasting services? Should provision be made for white space devices using power control to have additional flexibility in selecting frequencies, as has been proposed in the United Kingdom? We believe the provisions in Table 6.2 are adequate and recommend that power control requirements such as those proposed in the UK, not be imposed. However, we are not opposed to the use of power control on a voluntary basis. 2.9 6-9 Comments are sought on the potential for improvements to the policy and technical framework for RRBS, including the possibility of moving to a license exempt regime, leveraging white space technology TVWS should be regarded as a national strategy for economic growth and international competitiveness. Therefore we support grandfathering of existing RRBS licensees, but believe we should be moving to leverage the white-space database regime and technology. 2.10 6-10 Should Industry Canada identify specific spectrum for use by LPA? If so, how much should be identified and should the operation of license-exempt LPA be restricted to this spectrum? Yes, we support the reservation of two channels nationwide for use by LPA on the same basis as the U.S. in order to maximize overall spectrum efficiency. We also note that in section 2.6 above, we have supported the restricted use of TVWS devices below channel 21 and this spectrum can also be utilized by LPA devices. @2010 6Harmonics Inc. All Right Reserved 7
2.11 6-11 Comments are sought on the options for the authorization of LPA in Canada. Provide justification for this choice of option We believe Option 1 is the best choice for this, as it is provides the most flexibility and choice for LPA users. Option 2 is very similar to Option 1 and we can support it if necessary. However, we do not support Options 3, 4 or 5 as we believe they are either impractical, unnecessary and/or problematic. 2.12 6-12 If option 1, 2 or 5 is chosen, comments are sought on the proposal to collect time and location of use data based on voluntary registration and the proposal that eligibility to register for such protection be open to all users of LPA. Comments are also sought on the appropriate protection criteria to protect LPA from interference from white space devices No comment. 2.13 6-13 Comments are sought on the above proposals. Should provisions for flexible out-of-band masks, similar to the U.K. rules, also be included? Is there a need for additional measures on adjacent channels to protect systems operating at the edge of the TV bands? We believe the use of the FCC mask is sufficient at this time and has proved feasible and practical. 2.14 6-14 On balance, do the potential benefits of permitting license-exempt white space devices to operate in Canada outweigh their potential risks to other services? We believe yes! 2.15 7-1 Comments are sought on these proposed modifications to the Canadian Table of Frequency Allocations We support the proposed changes to the Canadian Table of Frequency Allocations. @2010 6Harmonics Inc. All Right Reserved 8
2.16 8-1 Comments are sought on whether the measures of the FCC to protect Canadian licensees are adequate and whether Industry Canada s proposed measures are adequate to protect U.S. licensees, including TV broadcasters. Provide supporting arguments for your response For geographic and many other reasons noted in our comments, Canada and the U.S. should adopt identical or very similar technical rules for TVWS. One of the many benefits of doing so is to ensure that licensees on both sides of the border are treated symmetrically, and thus receive fair and equal protection. By taking that approach, database administrators on both sides of the border can populate common or similar databases in each country with appropriate information on licensees from the other side of the border, in order to equally protect both Canadian and U.S. licensees. Therefore, we believe that Industry Canada s proposed measures along with the measures adopted by the FCC ought to be adequate to protect both Canadian and U.S. licensees, including broadcasters. @2010 6Harmonics Inc. All Right Reserved 9