Description of Research Project

0915-EX-ST-2019 Text Documents

CCO Fiberlink, LLC

2019-05-31ELS_231174

                         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 22, 2019, to test and evaluate coverage, capacity, and propagation
characteristics in the 3550-3700 MHz band. The proposed operations will occur only in the
3650-3700 MHz portion of the band to avoid Naval radar interference. The testing will advance
Charter’s understanding of technology and network potential in the full 3550-3700 MHz band
and will advance the potential deployment of fixed and mobile wireless services.

Location of Testing

Charter will conduct outdoor and indoor fixed and mobile testing within 8 miles (12.87 km) of
three fixed locations in New York, New York:

    1. 40° 40' 30.18'' N, 73° 48' 44.64'' W
    2. 40° 44' 6.936'' N, 73° 53' 30.84'' W
    3. 40° 35' 25.836'' N, 74° 3' 38.88'' W


Description of Testing

Charter will deploy experimental fixed and mobile equipment in various configurations.
Depending on the testing scenario, devices will be deployed on existing aerial cable strand, on
existing buildings/poles or indoors. Specifically, Charter will use the following deployment
approaches:

    1. Strand mount deployment (Category A or B Radios):1 18 ft. height.
    2. Building/pole mount deployment (Category A or B Radios): up to 100 ft. height.
    3. Indoors (Category A Radios): up to 40 ft. height (3rd floor indoor).
Other equipment will be used by Charter to receive signals from the mounted devices and
transmit back to those devices (“End User Devices” or “EUD”). Charter will evaluate
propagation characteristics; conduct connectivity and throughput testing in the vicinity of each
device; and assess inter-cell interference, mobility characteristics, Spectrum Access System
(“SAS”) compatibility and individual performance of each vendor.


Radio Equipment Description

For the testing, Charter will use 12 different models of fixed equipment and 6 different models of
mobile End User Equipment. The technical information below provides the greatest bandwidth
and power levels that will be used for each piece of prototype equipment.


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.
                                               1


         Charter intends to install approximately 200 fixed transmitters and employ up to 50 mobile
         transmitters during the testing. During most of the testing, approximately 20% of the mobile
         devices will be operational at any given time, with the remainder in a non-transmitting state.
         Charter also intends to conduct capacity testing. At those specific limited times, Charter would
         test a greater number of devices at the same time. Such capacity testing will be of limited
         duration (one week at a time, for 10 hours/day) and Charter will ensure that no interference with
         other users of the 3.5 GHz band will occur.


         Fixed Equipment (12 models):
                               Tx                                     Mean
                                            EIRP        ERP                    Emission      Frequency
   Equipment    Category     Power                                     or                                    Modulation
                                           (dBm)       (watts)                 Designator    Tolerance
                             (mW)                                     Peak
  Prototype 1   A           320           30           0.6            Mean   20M0W7D        0.00001%      64/16 QAM &
                                                                                                          QPSK
  Prototype 2   B           4000          41.5         8.6            Mean   20M0W7D        0.00001%      64/16 QAM &
                                                                                                          QPSK
  Prototype 3   B           4000          50           61.0           Mean   20M0W7D        0.00001%      64/16 QAM &
                                                                                                          QPSK
  Prototype 4   A           500           33           1.2            Peak   20M0W7W        0.00002%      64/16 QAM &
                                                                                                          QPSK
  Prototype 5   B           2000          39           4.9            Peak   20M0W7W        0.00002%      64/16 QAM &
                                                                                                          QPSK
  Prototype 6   B           2000          50           61.0           Peak   20M0W7W        0.00002%      64/16 QAM &
                                                                                                          QPSK
  Prototype 7   A           350           33           1.2            Peak   40M0D7D        0.0005%       64/16 QAM &
                                                                                                          QPSK/BPSK
  Prototype 8   A           890           36           2.4            Peak   40M0D7D        0.0005%       64/16 QAM &
                                                                                                          QPSK/BPSK
  Prototype 9   B           4000          43           12.2           Peak   40M0D7D        0.0005%       64/16 QAM &
                                                                                                          QPSK/BPSK
  Prototype 10 B            10000         53           121.6          Peak   40M0D7D        0.0005%       256/64/16QAM &
                                                                                                          BPSK/QPSK
  Prototype 11 A            500           33           1.2            Peak   20M0W7D        0.00001%      64/16 QAM &
                                                                                                          QPSK/BPSK
  Prototype 12 B            4000          42           9.7            Peak   20M0W7D        0.00001%      64/16 QAM &
                                                                                                          QPSK/BPSK




         End User Equipment (6 models):

                             Tx                     ERP           Mean                                      Modulation
                                      EIRP                                    Emission      Frequency
 Equipment      Category    Power                  (Watts)       or Peak
                                     (dBm)                                    Designator    Tolerance
                            (mW)
Prototype 13    EUD        200       23          0.2           Peak          20M0W9W        0.0005%      64/16 QAM &
                                                                                                         QPSK/BPSK
Prototype 14    EUD        200       23          0.2           Peak          20M0W9W        0.0005%      64/16 QAM &
                                                                                                         QPSK/BPSK
                                                                  2


Prototype 15       EUD      200       23       0.2       Peak      20M0W9W         0.0005%     64/16 QAM &
                                                                                               QPSK/BPSK
Prototype 16       EUD      200       23       0.2       Mean      20M0W7D         0.00001%    64/16 QAM &
                                                                                               QPSK
Prototype 17       EUD      200       23       0.2       Peak      20M0W9D         0.00001%    64/16 QAM &
                                                                                               QPSK/BPSK
Prototype 18       EUD      200       23       0.2       Peak      20M0W7W         0.0001%     64/16 QAM &
                                                                                               QPSK/BPSK


         All testing will be conducted within Charter’s existing service areas, and employ power and
         backhaul from Charter’s existing cable distribution plant or an expansion of this plant. The fixed
         devices will be mounted on Charter’s existing strand, select street furniture and/or building
         facades/rooftops. Additionally, some fixed devices will be placed indoors.

         Based on the height of these facilities, the devices may be more than 6 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 1 meter above those facilities.

         Protection Against Interference

         Charter requests use of the 3650-3700 MHz band. Charter understands that it must accept
         interference from any federal and non-federal incumbent users of this band and that all Charter
         operations will be on a secondary basis.

         Charter is conducting this testing in cooperation with Federated Wireless (“Federated”), and will
         employ Federated’s developmental SAS database. Although New York City is located within
         NTIA’s coastal exclusion zone, this authorization seeks authority only to test in the 3650-3700
         MHz frequencies. The following methods will be used to prevent harmful interference:

                  Primary: Via the design process of a fully functional SAS combination, with the SAS
                   commanding 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 will coordinate all testing with grandfathered Wireless Broadband Licensees with
         registered locations in the requested testing areas, 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.




                                                           3


Charter is aware of Fixed Satellite Service (FSS) earth stations operating in the 3650-3700 MHz
band in the areas in which Charter seeks to conduct testing and will coordinate with these earth
station operators to confirm Charter’s testing will not cause harmful interference.

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.

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: 2019-05-31 14:59:38
Document Modified: 2019-05-31 14:59:38

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