Description of Research Project

0844-EX-ST-2019 Text Documents

CCO Fiberlink, LLC

2019-05-10ELS_229689

                         DESCRIPTION OF RESEARCH PROJECT

Pursuant to Sections 5.3(j) and Section 5.61 of the Federal Communications Commission’s rules,
47 C.F.R. §§ 5.3(j) and 5.61, CCO Fiberlink, LLC (“Charter”), a limited liability company and
subsidiary of Charter Communications, Inc., seeks Special Temporary Authority (“STA”) for 180
days, beginning June 5, 2019, to test and evaluate coverage, capacity, and propagation
characteristics in the 3550-3700 MHz band. The proposed operations will advance Charter’s
understanding of technology and network potential in the 3550-3700 MHz band and will advance
the potential deployment of fixed and mobile wireless services.

For the testing, Charter will use multiple models of fixed equipment and several models of mobile
End User Equipment. The technical information below describes the greatest bandwidth and
power levels to be used for each piece of prototype equipment, in most cases, implemented
bandwidth and power levels will be lower.

Location of Testing

Charter will conduct outdoor and indoor fixed and mobile testing within 10 miles (16.1 km) of
the provided fixed location of 39° 35' 17.50" N, 104° 50' 46.09” W in Centennial, Colorado.

Description of Testing

Charter will deploy both experimental fixed and mobile equipment in various configurations in
support of several wireless initiatives in mobile and fixed service models. Depending on the testing
scenario, devices will be deployed on existing structures or poles, in both indoor and outdoor
environments.

Specifically, Charter will use the following base station deployment approaches:

    1. Outdoor:
           a. Building deployment: Category A or B radios,1 up to 50 m height AGL, either
              rooftop or wall mounted, with no device extending more than 2 m above the
              existing structure.
           b. Pole mount: Category A or B radios, up to 15 m AGL, with no device extending
              more than 2 m above the existing structure.
    2. Indoors: Category A radios, up to 50 m AGL in height (up to 12th floor indoor).
    3. In our wireless laboratory environment.
Charter will use other equipment to interact with the base station devices, in both receiving and
transmitting modes (“End User Devices” or “EUDs”). These devices will conform to the Part 96
limits for End User Devices, and will evaluate propagation characteristics, conduct connectivity
and throughput testing, and include assessment of inter-cell interference, mobility characteristics,
Spectrum Access System (“SAS”) compatibility and individual performance of multiple vendors’
devices.

1
 Category A and B radios are defined in Sections 96.3 and 96.41 of the FCC’s rules. See 47
C.F.R. §§ 96.3 and 96.41.
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      Charter intends to install approximately 100 fixed transmitters and employ approximately 500
      fixed and mobile EUDs during the testing. The number of devices is largely driven by the
      operational environment Charter intends to trial, that of an Enterprise Campus deployment of
      private LTE. As such, much like Enterprise WiFi, the 100 base stations will be overwhelmingly
      (95%) comprised of indoor Category A devices, deployed in Charter occupied buildings, whose
      already low emissions should barely penetrate the building exteriors, and therefore contribute
      nearly nothing to the aggregate noise floor outdoors. Additionally, the End User Devices, also
      already limited on power, while mobile, will also be primarily operated indoors, and only during
      specific limited test periods will be operated concurrently in an attempt to evaluate the network’s
      response to loading. Normally, as in a real world deployment, each End User Device will transfer
      data in bursts, versus streams, further limiting aggregate noise. These End User Devices will be
      operated by Charter employees during working hours, so Charter will be monitoring all use and
      any interference concerns at all times during the testing. In this carefully controlled environment,
      Charter seeks to test how these devices will operate under real world situations.

      Radio Equipment Description

      Base Station Equipment (fixed - multiple models):


                            Tx                 ERP       Mean                                     Modulation
                                      EIRP                          Emission      Frequency
Equipment    Category     Power               (watts)     or
                                     (dBm)                          Designator    Tolerance
                          (mW)                           Peak
Indoor           A         1000       33.0      1.26     Peak      20M0W7D        0.0005%     256/64/16 QAM;
prototypes                                                                                    QPSK; BPSK
Outdoor          B        6777        54.8     184.1        Peak   60M0W7D        0.00001%    256/64/16 QAM;
prototypes                                                                                    QPSK; BPSK
      End User Devices (fixed and mobile - multiple models):

                          Tx                  ERP       Mean                                     Modulation
                                    EIRP                           Emission      Frequency
Equipment    Category    Power               (Watts)     or
                                   (dBm)                           Designator    Tolerance
                         (mW)                           Peak
Mobile         EUD        200        23        0.2      Peak       20M0W9W       0.0005%      256/64/16 QAM;
prototypes                                                                                     QPSK; BPSK
Fixed          EUD         600      42.8       11.6     Peak       60M0W9W       0.00001%     256/64/16 QAM;
wireless                                                                                       QPSK; BPSK
CPE

      Based on the height of these facilities, the devices may be more than six meters above ground
      level. However, there is no risk of physical interference because all devices will be mounted on
      existing facilities, and will not extend more than two meters above those facilities. Charter is
      aware of the presence of Centennial Airport (ICAO: KAPA) contained within the requested area
      of the experimental license. As all equipment will be either indoors, or operate no more than two
      meters above existing structures, none will pose an obstruction to aviation.




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Protection Against Interference

Charter requests use of the 3550-3700 MHz band. Charter understands it must accept interference
from any federal and non-federal incumbent users of this band and all Charter operations will be
on a secondary basis.

With the exception of testing in our wireless laboratory, Charter is conducting this testing in
cooperation with Federated Wireless (“Federated”), and will employ Federated’s developmental
SAS. The test area is not located within the coastal exclusion zone. However, the following
methods will be used to prevent harmful interference:

       Primary: Via the design process of a fully functional SAS, with the SAS commanding the
        test CBRS devices to non-interfering channels.
       Secondary: Federated will manually command the SAS to command CBRS test devices
        to shift to non-interfering channels.
       Tertiary: Charter has established a point of contact, identified below, available 24/7 during
        all testing, with “kill switch” authority should any interference occur to primary licensed
        services. Should interference occur, Charter will take immediate steps to resolve the
        interference, including, as appropriate, channel shifting or discontinuing operations.

Charter has confirmed there are no Fixed Satellite Service (FSS) earth stations operating in the
3600-3650 MHz band in the areas in which Charter seeks to conduct testing.

Charter will coordinate all testing with grandfathered Wireless Broadband Licensees registered in
the requested testing area, and intends to employ Federated’s developmental SAS to coordinate
channel assignments. Where the SAS is not capable of doing so, Charter will manually coordinate
operations, primarily by operating below 3650 MHz when so required.

Finally, given the low EIRP transmit levels of the proposed radios, coupled with their low installed
elevation, Charter expects limited RF propagation distances as well as limited and localized
aggregative contribution to the RF noise floor.

Restrictions on Operation

Charter does not seek authority to perform a market study under the requested license and will
retain control over the equipment in the testing at all times.




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Contact Information

Point of contact for FCC licensing issues:

       Colleen King
       Vice President, Regulatory Affairs
       (202) 621-1921
       colleen.king@charter.com

Point of contact for questions about testing operations:

       Greg McLaughlin
       Sr. Director of Wireless Operations, R&D
       (720) 482-4290
       greg.mclaughlin@charter.com

The following individual will be available 24/7 during all testing, and has authority and ability to
immediately cease all operations:

       Todd Herring
       Director of Wireless Operations
       (303) 345-7907
       todd.herring@charter.com
       Wireless Ops Hotline: (720) 536-9205




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Document Created: 2019-05-10 11:35:20
Document Modified: 2019-05-10 11:35:20

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