Narrative and Public Interest Statement

0699-EX-PL-2007 Text Documents

Comcast WCS ME19, Inc.

2007-12-17ELS_86749

                                                                    Experimental Application
                                                                    File No: 0699-EX-PL-2007
                                                                    FRN: 0002205847


                DESCRIPTION OF THE PROPOSED EXPERIMENT AND
                       STATEMENT OF PUBLIC INTEREST

        Comcast requests that the FCC grant an experimental license so that tests can be
performed with 802.16e mobile WiMAX equipment on WCS channel blocks A, B, and C, in
Muncie, Indiana (call signs: KNLB280, KNLB281, and WPQL633). The tests will be
performed at a single base station location, with base station antennas mounted on an existing
antenna structure that is currently owned and operated by Comcast (ASR Registration Number:
1031323). The base station will be a standard three-sector base station with three antennas
connected to three base station transceivers; each is designed to cover a 120 degree sector, and
together they will provide omni-directional coverage around the base station. The coverage
range is not expected to exceed three kilometers. The mobile stations will be PC card devices in
notebook computers.

        The equipment to be used in these tests is standard production equipment that is widely
used in other parts of the world, and is designed for the 2.3-2.4 GHz global WiMAX band
conforming to the IEEE 802.16e global wireless broadband standard and the WiMAX Forum
band class 1A system profile. However, neither the base station equipment nor the mobile
stations are type accepted by the FCC to meet part 27 rules for the WCS band. Therefore, at
some power levels within the range of normal operation, the emission levels may briefly exceed
the limits specified in part 27.53. At all times, however, during the course of testing under the
requested experimental license, Comcast will have the ability to control and limit the operating
range of both the mobile stations and the base station to comply with part 27.53 emission limits.

        Under tightly controlled conditions, for limited periods of time, and with careful
monitoring of any interference to neighboring bands, Comcast requests authority to include
testing under the experimental license to operate in ranges for both the base station and mobile
stations that exceed the limits of part 27.53. In these cases, the emission levels will be known
and the impact to other services will be assessed. For the majority of testing under the
experimental license, the base station EIRP will be below the limits set in part 27.50. However,
Comcast requests authority to test base station operation above 2,000 watts peak EIRP, but
conforming to a 2,000 watt average power EIRP limit. Signals tested above 2,000 watts peak
EIRP will be for very limited time periods, under controlled conditions, and with careful
monitoring of interference. At all times, Comcast will maintain the ability to turn down the peak
EIRP below 2,000 watts if needed. All other requirements for part 27 WCS band operation will
be adhered to.

        As described above, Comcast requests the experimental license in order to conduct tests
to determine the applicability of global WiMAX equipment designed for the 2.3-2.4 GHz band to
the United States WCS band. Comcast seeks to test various technical parameters, such as range,
coverage, throughput, latency, reliability, and availability, as well as mobile broadband
applications enabled by this technology that may provide additional options for wireless
broadband connectivity, which may significantly benefit consumers. WiMAX has been chosen
because it is a global standard with significant technical advantages, and equipment is readily


                                                                    Experimental Application
                                                                    File No: 0699-EX-PL-2007
                                                                    FRN: 0002205847

available from multiple sources that work in the WCS band. 802.16e based mobile WiMAX
shares many common features with other fourth generation mobile standards, such as those
proposed by 3GPP and 3GPP2 (commonly referred to as UMB and LTE). These common
features include OFDM, OFDMA, and MIMO, as well as similar EIRP and out of band emission
characteristics. So while the testing under this experimental license will use 802.16e mobile
WiMAX equipment, the lessons learned will apply to all fourth generation mobile broadband
standards under consideration.

        Finally, paramount importance will be placed on causing no harmful interference to
SDARS receivers. In fact, a significant goal of these tests will be to attempt to determine the
maximum operating range of the WiMAX base station and mobile station(s) within which no
harmful interference will be caused to SDARS receivers. Comcast will then seek to determine if
the service provided within this operating range has satisfactory range, coverage, throughput,
latency, reliability, and availability to satisfy customer requirements. Both WCS and SDARS
license holders have filed petitions with the FCC to modify parts 25 and 27 in an effort to lessen
interference. In meetings between the FCC and WCS license holders, it was agreed that more
testing would help determine what changes, if any, should be made to parts 25 and 27 to help
both SDARS and WCS licenses operate without harmful interference to each other. The testing
under this experimental license is of a limited timeframe and only in one specific location, so it
cannot answer all questions. Still, the testing proposed in this application will significantly
advance the mutual goal of interference avoidance while permitting flexible use of scarce
spectrum resources, which is in the public interest and a key policy directive of the FCC.




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Document Created: 2007-12-17 15:09:24
Document Modified: 2007-12-17 15:09:24

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