PUBLIC REDACTED Narrative Statement Comcast CBRS Exp Lic Appl

0226-EX-CN-2019 Text Documents

Comcast CBRS, LLC

2019-03-29ELS_226468

                          REDACTED – FOR PUBLIC INSPECTION



                      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 April 15, 2019.

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 area surrounding King of Prussia, Pennsylvania market within its service territory.
Specifically, testing will be conducted within a 15 km radius of the following location:

         Locality                          Latitude                         Longitude
    King of Prussia, PA                 40° 5' 26.86'' N                 75° 22' 04.13'' W

Description of Testing

The experimental operations will [[BEGIN CONFIDENTIAL]]
                                                               [[END CONFIDENTIAL]]
within the 15 km radius of the location set forth above. The first type of transmitter will consist
of [[BEGIN CONFIDENTIAL]]

                          [[END CONFIDENTIAL]]. The second type of transmitter will
consist of [[BEGIN CONFIDENTIAL]]
                  [[END CONFIDENTIAL]] The third type of transmitter will consist of
[[BEGIN CONFIDENTIAL]]                                             [[END
CONFIDENTIAL]].

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 [[BEGIN CONFIDENTIAL]]

         [[END CONFIDENTIAL]].



                                                 1


                               REDACTED – FOR PUBLIC INSPECTION




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 [[BEGIN CONFIDENTIAL]]
[[END CONFIDENTIAL]] will be a Category B transmitter with the technical characteristics
shown below. Comcast will utilize lower power Category A radios mounted on [[BEGIN
CONFIDENTIAL]]                        [[END CONFIDENTIAL]] and Category A femto radios for
[[BEGIN CONFIDENTIAL]]                                [[END CONFIDENTIAL]]. Each type of
the proposed radio equipment has been certified by the Commission pursuant to the equipment
authorization rules.2 Comcast also plans to use prototype radio equipment with the same or
similar technical characteristics as the authorized radio equipment.

Comcast will utilize [[BEGIN CONFIDENTIAL]]               [[END CONFIDENTIAL]] 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: (1) traditional mobile handsets; (2) USB Mobile Dongle Hotspot
Devices; (3) and MiFi Mobile Hotspot devices.

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
    Type 13    B        N/A      50    61      Mean 20M0W7W 0.00000005 256QAM/64QAM/
                                                                         16QAM/QPSK
    Type 2     A        0.5      30    0.6     Mean 20M0W7W 0.0000002 256QAM/64QAM/
                                                                         16QAM/QPSK
    Type 3     A        0.5      30    0.6     Mean 20M0W7W 0.0000002 256QAM/64QAM/
                                                                         16QAM/QPSK




1
  See 47 C.F.R. §§ 96.3 and 96.41.
2
  Type 1 Radio Equipment: Ericsson Remote Radio Unit 2208 - FCC ID:TA8AKRC161711-1; Type 2 Radio
Equipment: Ruckus Q910 - An integrated, outdoor CBRS LTE access point - FCC ID: S9GQ910US00; Type 3
Radio Equipment: Ruckus Q710 - A high-capacity, indoor CBRS LTE access point - FCC ID: S9GQ710US00.
3
  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.



                                                           2


                           REDACTED – FOR PUBLIC INSPECTION



End User Equipment (3 Types)

    TransmitterCategory Tx Power   EIRP ERP Mean or Emissions Frequency Modulation
    Type                (mW)       (dBm) (Watts) Peak Designator Tolerance
    Essential  EUD      200        23    0.2     Mean 20M0W7W 0.0000001 64QAM/ 16QAM/QPSK
    PH1 or
    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

Protection Against Interference

Pursuant to the Commission’s experimental licensing rules,4 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 King of Prussia, PA, 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 Fixed Satellite Service (FSS) earth stations and wireless
broadband licensees holding grandfathered licenses in the 3650-3700 MHz band. Where the SAS
is not capable of coordinating channel assignments via automated systems, Comcast will
manually coordinate operations.

Restrictions on Operation

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




4
    See 47 C.F.R Part 5.



                                                3


                         REDACTED – FOR PUBLIC INSPECTION



Contact Information

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

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




                                                4



Document Created: 2019-04-28 07:21:25
Document Modified: 2019-04-28 07:21:25

© 2026 FCC.report
This site is not affiliated with or endorsed by the FCC