OTTAWA –The responses filed to ISED’s consultations on the 3500 MHz and 3800 MHz band pit incumbent fixed wireless service providers against mobile operators eager to deploy 5G services. The terrestrial operators, however, face opposition from satellite operators eager to protect the C-band. Caught up in the cross-fire are customers and communities who are reliant on existing services – both terrestrial and satellite.
Comments by a number of parties have been posted in response to Gazette Notice SLPB-004-18 — Consultation on Revisions to the 3500 MHz Band to Accommodate Flexible Use and Preliminary Consultation on Changes to the 3800 MHz Band and arguments abound as to the best path forward to advance broadband connectivity.
Is there one path that is best suited for urban, rural and remote customers? Will there be enough spectrum available to accommodate the competing interests? Can the differing services co-exist without interfering with each other? These are difficult questions. Perhaps the most difficult issue will be deciding how much spectrum one operator can control in the band and, potentially, even ordering some incumbent operators to return spectrum.
Yes, it’s complicated.
The primary purpose of the consultation is to consider revisions to the 3500 MHz band to accommodate flexible use of the band, thereby opening it for the deployment of 5G services. Several parties underlined the importance of the 3500 MHz band relative to other bands being considered for 5G. Telus submitted, “while the true culmination of 5G will be achieved through the utilisation of complementary spectrum bands, the 3500 MHz spectrum band is undoubtedly the most critical spectrum to fulfil the promise of 5G in the initial stages of its deployment.”
As Shaw explained, “the 3500 MHz band is of particular importance because it is the lowest frequency band where 5G can be deployed with large channel bandwidths.” Many parties stressed the importance of making 3.5 GHz band available for terrestrial flexible use by 2019, consistent with international developments and the race by countries to be leaders in 5G.
The Innovation Science and Economic Development Ministry is proposing to reallocate 3450-3650 MHz (200 MHz of spectrum) for flexible use. Several parties have their eyes on additional frequencies. Rogers suggested the department should make upwards of 300 MHz of spectrum available, not just 200 MHz. Bell stated, “operators who wish to deploy 5G in this band will require large amounts of contiguous spectrum, and allocating only 200 MHz spectrum will delay deployment and curtail the potential benefits and innovations that 5G technologies promise.”
Bell wants the Department to additionally designate 3400–3450 MHz (50 MHz) and 3700–3800 MHz (100 MHz) as flexible use and auction it as part of the 3500 MHz band in 2020. This would make 350 MHz of spectrum available.
Many of the incumbents in the band are concerned that the Department’s proposal will limit their access to the band in the future.
The 3475–3650 MHz band is primarily being used to provide fixed wireless broadband Internet. Some operators noted that they have recently completed, or are currently completing, Connecting Canadians projects – projects intended to make broadband internet available to approximately rural Canadians and they argued that continued access to the band is essential to continue offering services.
Some communities and customers lent their support to the operators, arguing that reducing the spectrum available for rural broadband networks will negatively impact rural Canadians. Enbridge (the gas company), cited significant investments made to upgrade and extend existing radio communications using the 3500 MHz band “for last mile from remote pipeline facilities to the transport microwave network.”
“Seizing a portion of existing licence holders' spectrum as proposed by the Department is contrary to the Department's own rural broadband objectives and is entirely unnecessary.” – Bell Canada
Xplornet, which considers itself as a pioneer of the use of 3500 MHz spectrum for broadband services, submitted that “[r]ural operators have used and continue to use the 3500 MHz spectrum band to deliver wireless service to hundreds of thousands of homes, and millions of Canadians, who live in low density areas in rural Canada.” It, of course, does not want this interrupted.
The Department has proposed two options that would require existing 3500 MHz licensees to return a portion of their spectrum holdings when flexible use licences are issued. The responses to this are quite polarized. Some parties argued that ISED should reclaim almost all of the spectrum, while others wanted existing licensees to retain all of their current spectrum holdings.
Bell opposed the proposals to reclaim spectrum arguing that “seizing a portion of existing licence holders' spectrum as proposed by the Department is contrary to the Department's own rural broadband objectives and is entirely unnecessary given that the 3500 MHz spectrum band can be expanded to make more spectrum available.” Rogers argued “[i]ncumbents that have met their licence conditions should be able to retain two-thirds of their spectrum, as they have invested hundreds of millions of dollars in the face of ongoing and significant technology uncertainty.”
Xplornet provided an alternative proposal that it suggested would “preserve the gains made to date in rural Canada, and continue the process of improving rural service, while still allowing an auction of additional spectrum to proceed.” Fixed wireless internet service providers serving rural Canadians are eager to retain their spectrum holdings, but it is unclear whether they support the Xplornet proposal.
Fixed wireless service providers are also exploring 5G. As explained by Canwisp, “the majority of Canwisp members are already using 4G LTE equipment, the technology pathway for Wireless Internet Service Providers (WISPs) to 5G in the next few years will be cost efficient.” Xplornet pointed to its recently announced 5G trial program, using 3500 MHz spectrum in rural Canada.
Some of Canada’s newest, or soon-to-be, mobile operators favoured reclaiming spectrum. Cogeco recommended that “for each licence area, existing licensees would be issued flexible use licences for one third of their current spectrum holdings.” Eastlink submitted “ideally, all spectrum would be returned to the Department (with the exception of spectrum being used to serve retail end-users in very remote areas for fixed wireless) in advance of this licensing process.” Shaw supported a substantial reclamation of spectrum in this band.
“There has been no reason for Inukshuk or Xplornet to invest in significant fixed wireless deployments in the province with their 3500 MHz spectrum.” – Eastlink
In addition to the general calls to reclaim spectrum, some parties explicitly questioned the spectrum holdings of Inukshuk Wireless Partnership (a Bell-Rogers joint venture) and Xplornet. Cogeco argued, “[i]t is clear that Inukshuk is the primary holder of 3500 MHz spectrum in these four Tier 2 service areas, while Xplornet holds much of the rest.” Eastlink provided examples indicating that “Inukshuk and Xplornet hold all 3500 MHz spectrum in Nova Scotia, but Nova Scotia is almost entirely served by fibre (and Eastlink operates fixed wireless service in remote areas of the province using alternative spectrum bands).” Eastlink submitted “[t]here has been no reason for Inukshuk or Xplornet to invest in significant fixed wireless deployments in the province with their 3500 MHz spectrum.”
In addition to the 3500 MHz band, the consultation sought comments on how to optimize the use of the 3800 MHz band in the future. The Department noted that several other countries are considering rule changes to allow mobile or flexible use in the 3650–4200 MHz band. In Canada, the 3650–3700 MHz portion of the band is primarily used for fixed point-to-multipoint services. The 3700–4200 MHz portion is primarily used by Fixed Satellite Systems.
Canadian broadcasters rely on the C-band and, as Corus noted, it “is used extensively by American television networks for delivery of programming and news services to Canadian broadcasters.”
CBC/Radio-Canada argued that any financial burden of technical changes related to the reallocation of C-Band should not be the responsibility of the broadcaster. The satellite industry, including Intelsat, Inmarsat, SES and Telesat, either opposed changes to the 3800 MHz band or called on the Department to ensure any potential changes will not disrupt C-band satellite services or undermine the economic value satellite operations in Canada.
Reply comments are due August 10.
