REDACTED PUBLIC FILE Comcast CBRS Experimental License App

0110-EX-CN-2018 Text Documents

Comcast CBRS, LLC

2018-02-12ELS_204741

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                       Description of Proposed Experimental Operations

Pursuant to Sections 5.3(j) and Section 5.54(a)(1) of the Federal Communications Commission’s
rules, 47 C.F.R. §§ 5.3(j) and 5.54(a)(1), Comcast CBRS, LLC (“Comcast”), a subsidiary of
Comcast Cable Communications, LLC, requests authorization to conduct experimental
operations under a conventional radio experimental license issued by the Commission for a term
of one year commencing on March 1, 2018.

Comcast seeks authorization to conduct pre-commercial outdoor field trials in the 3650–3700
MHz Citizens Broadband Radio Service (“CBRS”) band. The field test will evaluate coverage,
throughput, and mobility of equipment and facilities operating in the CBRS band to obtain data
and advance Comcast’s understanding of the full potential of the technology and equipment
utilized in these experimental operations. The field testing will also evaluate the performance of
pre-commercial equipment in the CBRS band. To ensure full compliance with the operational
restrictions in the NTIA’s 3.5 GHz exclusion zone, all experimental testing subject to this
application will be limited to the 3650–3700 MHz band.

Location of Testing

Comcast will conduct outdoor and indoor fixed and mobile testing in a small targeted portion
of the Philadelphia, Pennsylvania market within its service territory. Specifically, testing will
be conducted within a 7 km radius of the following location:

          Locality                          Latitude                            Longitude
      Philadelphia, PA                    39°56'31.3"N                         75°09'32.9"W

Description of Testing

The experimental operations will
                                        within the 7 km radius of the location set forth above. The
first type of transmitter will consist of rooftop-mounted sectorized base stations located at
current or former cell sites. The
                                                 The second type of transmitter will consist of
                                                                      . The third type of transmitter
will consist of                                                .

Through the use of mobile test devices and commercial handsets (i.e. “End User Equipment”),
Comcast will evaluate propagation characteristics for model verification, data throughput
performance, inter-cell interference, and advanced Spectrum Access System (“SAS”)
functionality.

All testing will be conducted within
                                                                           .




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Radio Equipment Description

The radio equipment that will be used in the proposed experiment will consist of a mix of
Category A and Category B transmitters (as those terms are defined in Sections 96.3 and 96.41
of the Commission’s rules).1 Any                                will be a Category B transmitter
with the technical characteristics shown below. Comcast will utilize lower power Category A
radios mounted on                , and Category A femto radios for                   . All of
these proposed radios are prototypes not available in the commercial market.

Comcast will utilize        different types of End User Equipment to receive signals from the
transmitters in order to evaluate performance of the equipment described above. Specifically,
Comcast will utilize the following types of End User Equipment:
                                                                                 .

The tables below summarize the technical characteristics of each piece of equipment described
above.

Fixed Equipment (3 Models)

    TransmitterCategory Tx Power EIRP ERP Mean or Emissions Frequency Modulation
                        (W)      (dBm) (Watts) Peak Designator Tolerance
    Prototype 12 B      N/A      50    61      Mean 20M0W7W 0.00000005 256QAM/64QAM/
                                                                         16QAM/QPSK
    Prototype 2 A       0.250    30    0.6     Mean 20M0W7W 0.0000002 256QAM/64QAM/
                                                                         16QAM/QPSK
    Prototype 3 A       0.250    30    0.6     Mean 20M0W7W 0.0000002 256QAM/64QAM/
                                                                         16QAM/QPSK

End User Equipment (3 Types)

    TransmitterCategory Tx Power         EIRP ERP Mean or Emissions Frequency Modulation
    Type                (mW)             (dBm) (Watts) Peak Designator Tolerance
    LG V30 or EUD       200              23    0.2     Mean 20M0W7W 0.0000001 64QAM/ 16QAM/QPSK
    equivalent
    Dongle     EUD      200              23       0.2       Mean        20M0W7W 0.0000001             64QAM/ 16QAM/QPSK
    MIFI       EUD      200              23       0.2       Mean        20M0W7W 0.0000001             64QAM/ 16QAM/QPSK




1
  See 47 C.F.R. §§ 96.3 and 96.41.
2
  This transmitter is a directional antenna. The width of the beam at the half-power point is 65.00 degrees. When
installed in the testing location described above, three separate antennas will be oriented in the horizontal plane at 0
degrees, 120 degrees, and 240 degrees. All three antennas will be oriented in the vertical plane at 6.80 degrees from
horizontal.



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Protection Against Interference

Pursuant to the Commission’s experimental licensing rules,3 Comcast understands that, for
purposes of the experimental operations described in this application, it must accept
interference from any federal and non-federal incumbent users of the 3650–3700 MHz band
and that Comcast’s experimental operation will be conducted on a secondary basis.

Comcast’s experimental operations will be conducted in cooperation with two leading SAS
vendors that the Commission has already authorized to operate. Comcast will employ the
vendors’ SAS databases when conducting experimental operations to avoid interfering with
incumbent users. As previously noted above, although Philadelphia is located within the
NTIA’s coastal exclusion zone for operations in the 3550-3650 MHz band, this application
only seeks authority to test operations in the 3650-3700 MHz band.

To ensure prompt resolution of any potential interference events, Comcast will establish a
point of contact, available 24/7 during the time when all experiments are conducted. This
person will have authority and the ability to disable all transmissions when notified that
interference is impacting primary-licensed services. Should interference occur during these
testing periods, Comcast will take immediate steps to resolve the interference, including
discontinuing operations, or, if appropriate, moving operations to a different channel.

Comcast will coordinate all testing with other wireless broadband licensees holding
grandfathered licenses in the 3.65 GHz band. Coordination with the grandfathered wireless
broadband licensees with registered locations will occur via Federated’s developmental SAS to
coordinate channel assignments. Where the SAS is not capable of coordinating channel
assignments via automated systems, Comcast will manually coordinate operations.

Additionally, Comcast confirms that it has not identified any Fixed Satellite Service (“FSS”)
earth stations operating in the 3650-3700 MHz band in the area of the experimental test bed.

Restrictions on Operation

Comcast does not seek authority to perform a commercial market study under the requested
experimental license. Comcast will retain control over all of the prototype equipment utilized
in the testing at all times.

Contact Information

FCC licensing issues:
K.C. Halm
Davis Wright Tremaine LLP
Counsel to Comcast CBRS, LLC
202.973.4287
kchalm@dwt.com


3
    See 47 C.F.R Part 5.




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Test Bed Operations:
Ronald Phillips
RF Engineer
1701 JFK Blvd
Philadelphia, PA 19103
Ronald_Phillips@comcast.com
Mobile: 914.954.4771

Field Test Manager (* available at all times for all issues and requests to cease transmissions)
Ronald Phillips
RF Engineer
1701 JFK Blvd
Philadelphia, PA 19103
Ronald_Phillips@comcast.com
Mobile: 914.954.4771




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Document Created: 2018-02-12 15:09:41
Document Modified: 2018-02-12 15:09:41

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