By Richard Bernhardt, Senior Director, Spectrum and Industry, WISPA – Broadband Without Boundaries
Standards provide a foundation for reliable and common operation in almost every industry. Put another way, spectrum standards help avoid chaos inside the operations of networked systems. In the greater U.S. spectrum environment, standards further guide just exactly how the ecosystem of a particular spectrum band should best operate to maximize the public interest, protect incumbents, meet the regulatory rules, and to enhance what might best be described as a functioning ecosystem that is “consistent and reliable.”
Introduction: Two Great FWA Examples
Within the U.S.’s spectrum management scheme – the one that is especially critical in the daily operation of Fixed Wireless Access (FWA) operations — there are currently two prime examples of where the creation of standards leads to that aforementioned industry goal of “consistent reliable functionality.” One is the Citizens’ Broadband Radio Service (CBRS in the 3550-3700 Megahertz (MHz) band); the other is the pending 6 Gigahertz (GHz) unlicensed band.
These two shared bands exemplify the use of the same ranges of spectrum by two or more different sets of user-operators.
First, CBRS typically involves incumbent primary users. Usually, these are mixed between users in the categories of industry, government, and Generally Authorized Access (GAA) Licensed by Rule users, as well as competitive bid auction users called Priority Access Licensees (PALs).
Second, 6 GHz involves users operating in the spectrum positioned between licensed point-to-point fixed commercial occupants (primary users) and that of licensed exempt Part 15 operators (AKA: secondary users).
Standards in these shared bands of CBRS and 6 Ghz guide user-to-user and user-to-coordination-facility compatibility. If there were only the FCC rules to guide ecosystem operation, with no additional industry guidance (in the form of the joint creation of spectrum standards), then inevitably all parties interested in operating in a band would likely do first what they felt best for themselves without regard for ecosystem compatibility and commonality. This can cause the entire ecosystem to disintegrate.
These “standardless” users would not likely mind nor seriously consider other users, including incumbents, and would potentially take actions beyond the regulators’ intentions and scope. That would likely hurt the industry and hinder the in-band performance. Further, in the shared spectrum arena, where different types of operators must co-exist and primary users must be protected, standards provide a more singular template to best achieve those goals.
CBRS: Requirements and Best Practices
A truly diverse and multi-stakeholder group known as the Wireless Innovation Forum (http://www.winnforum.org) has created and delivered the CBRS baseline standards for this band. WInnForum is composed of a diverse team of different types of network operators, potential and later actual Spectrum Access System Administrators (SAS), incumbent operators, actual and would-be manufacturers and service providers, and experts from inside and outside of the CBRS ecosystem.
Together, WInnForum appears to have painstakingly mapped the requirements set forth in the FCC’s Reports and Orders, considering all points of view. From those mandates, WInnForum created industry-based functional requirements, protocols, operations and installation parameters, and security specifications, as well as parameters for proper operations and appropriate testing and certification.
These interlocking baseline standards now relate to one another and to technical best practices, to standardize (or specify) similar approaches and operations for all ecosystem members. Yet, “free will” is involved, in that each segment of stakeholder must choose to adopt and comply with the standards. That acceptance and use is voluntary.
Why would they choose to adopt, you might ask? Adherents align because if they do not, then they must fully comply with the regulator on their own — and often face confusion and even sanctions for not meeting the regulator’s requirements. Adopting the standard helps them meet those obligations and to more fully and accurately fit into the ecosystem with other stakeholders.
In CBRS, the SAS serves as the band controller and monitor; while the Citizens Broadband Radio Device (CBSD) is the basic unit of operating and SAS-compliant radio. The CBRS band, deemed by the FCC to be technology neutral, allows the interaction of the operator via the CBSD and the SAS, accounting for many different and distinct uses and technology approaches. The CBRS band encourages diverse and innovative operations, but its users must all follow the FCC rules, and are generally best served by opting into the band specifications.
In short, this process of using standards provides better protection for the incumbents, while helping to assure smooth operation among all users and suppliers, as well as types of uses, existing and new. And as a quick aside here, these standards usually help lower the costs of the equipment that goes into a user’s system infrastructure. For WISPs, using standards also provides the best process to work alongside even competitive uses.
6 GHz: Standards Allow More Use in the Same Band
In what is termed the new 6 GHz Part 15 operations band, the incumbents are mostly commercial point-to-point licensed backhaul networks. Each frequently brings a broadband signal to many specific destinations across the nation, wide-and-far. Some are the backbone for critical national infrastructure. On a more granular level, still others deliver broadband backhaul to specific individual neighborhoods and entities. Others are designed for a plethora of uses, each measured and impactful.
As have many regulatory authorities throughout a growing number of countries, the FCC has determined that U.S. Wi-Fi bands have become very congested, and use demand continues to be very high and growing.
Thus, a similar type of functionality for spectrum allocation to that of CBRS was needed in the shared 6 GHz band. The 6 GHz band provides the opportunity for users to share spectrum among as much as 1200 MHz of band (for indoor); while 850 MHz of that same band serves Standard Power outdoor purposes. Since the current incumbents provide important functions, some critical, protection is vital. In the 6 GHz Standard Power Outdoor Part 15 band, incumbents are protected by Standard Power operator’s adherence to use according to the Automatic Frequency Control Systems (AFC) which are operated by FCC certified AFC System Administrators.
AFC Systems guide Standard Power (radio) Devices toward use the same band as the incumbents, but in areas where harmful interference will not occur. This occurs by registering devices with an AFC System, and inquiring every 24 hours about the status of the use of the band by incumbents. The AFC System thus provides guidance as to which frequency ranges in the band are available and at which power those ranges can be used, in order to avoid harmful interference with incumbents.
Another standards group, a collaborative group of private stakeholders that includes the WInnForum (http://www.winnforum.org), Wi-Fi Alliance (http://www.wi-fi.org), and the 6 GHz Multi-Stakeholder Group (MSG), has worked in parallel to develop what will be the collective baseline standards for this 6 GHz band. Their work includes the functional specifications and security for the AFC System and 6 GHz Standard Power outdoor devices, as well as the test, certification, and validation approaches and best practices for each, alongside the operations of the incumbent 6 GHz licensed band. The goal of these private industry stakeholders is to create industry voluntary cooperative standards, each of which meet FCC and other regulatory requirements for the band.
They also provide all other users with the guidance to co-exist with incumbents in the band. These new standards are thus focused on AFC Systems operators, equipment manufactures, and service providers; and eventually network user-operators. Even though some operators are license exempt and others are licensed, the two will operate together. Without these new standards, just as in CBRS, operators, manufacturers, and AFC Systems would blindly try to independently meet FCC objectives; with no coherent plan to follow. Again, chaos or less-than-optimum infrastructure would likely be the result, which would likely make sharing untenable.
Summary: Applying Standards to Shared Spectrum
Overall, through much hard work, the melding of regulatory rule-making, honed by real guidance from the affected industry stakeholders, yields remarkably reliable standards. The voluntary adopters are thus able to function more efficiently, using a uniform and well defined approach. This makes for a more dynamic and innovative ecosystem that achieves a far greater common good. In the end, the standards guide the way toward that goal of a functioning ecosystem, one that is “consistent and reliable.”
Richard Bernhardt is the Senior Director, Spectrum and Industry, WISPA; Working Group Chair and BOD, WInnForum; and, CEO, Bernhardt Communications Company