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By Tim McElgunn
June 23— The National Cable & Telecommunications Association (NCTA) on June 11 filed comments with the Federal Communications Commission “expressing concerns with current plans to deploy LTE-U systems in ways that may unfairly degrade the performance of hundreds of millions of Wi-Fi devices and routers.”
In a blog post explaining the filing, the association says that the “lifeblood” of Wi-Fi—freely available unlicensed spectrum—is “potentially [put] at risk by the deployment of a new technology called LTE-U that may not play well with others in the unlicensed sandbox.”
With companies as large and influential as Comcast, Time Warner and Charter joining the fray, the battle over how to manage unlicesnsed spectrum uses is much more evenly balanced than previously. Google and other large enterprises support protecting unlicensed uses, but their filings and public statements have been relatively low-key.
In addition to the cable operators' individual and collective financial heft, the entry into the debate of major buyers of technology will force cable equipment and software suppliers to either fall in line or take a neutral position in the debate, adding to the potential impact of the filing.
The NCTA filing puts a stake in the ground for the cable industry, and indicates that the industry is increasingly concerned that the companies and consortia behind LTE-U and LAA are moving much faster and seeking to create “facts on the ground” that will give them more leverage in the discussion of whether and how the technologies can co-exist with Wi-Fi.
And the filing is among the signs indicating that cable is getting close to unleashing its Wi-Fi infrastructure in competition with mobile wireless providers but that it is not yet ready to launch in earnest.
The NCTA isn't mincing words, using terms including “threatening,” “end-run,” “refusing” and “intentionally” in describing the wireless industry's pursuit of a foothold in the unlicensed spectrum bands that are used primarily for Wi-Fi today.
The filing states that “LTE-U and LAA proponents are threatening the Commission's ability to rely on self-governance of unlicensed bands by doing an end-run around IEEE's open standards-setting process, refusing to adopt industry-standard sharing mechanisms, and intentionally designing their protocols so that they are available only to licensed mobile carriers.”
Instead, the NCTA filing says, LTE-U and LAA standard-setting activity is restricted to the 3GPP group, which has ignored IEEE's request for details on specific operational features of the new technology.
NCTA is calling for the FCC to open a docket to investigate the state of play in LTE-U and LAA and to act quickly in the face of wireless industry moves to push forward with non-standard versions of the technologies.
The cable industry wants the commission to ensure that licensees do not launch non-standard versions of LTE-U into the U.S. market until the FCC has put some rules in place to protect Wi-Fi and ensure that licensed users cannot monopolize unlicensed spectrum.
The association is asking the FCC to step in to help shape standards for the new technologies or, failing that, to directly regulate how and where such technology can be deployed.
Meanwhile, the wireless industry's own filing, which assured the FCC that nascent LTE unlicensed and licensed-assisted access (LAA) technologies will fully comply with the FCC's Part 15 rules for unlicensed wireless operations, and therefore the agency should refrain from regulating the technologies.
Developers of the technology, CTIA said, should be allowed to “test and ensure coexistence with Wi-Fi without regulatory oversight by the Commission of this industry-based process.” Instead, industry standards bodies like 3GPP and the LTE-U Forum, which includes Alcatel-Lucent, Ericsson, Samsung Electronics Co., Qualcomm Technologies Inc. and Verizon Communications Inc. should take the lead, the group said.
NCTA claims that proponents of LTE-U and LAA pursuing standardization under the auspices of 3GPP—of which CableLabs is a member—are not just refusing to engage with IEEE to ensure effective spectrum sharing mechanisms between LTE-U/LAA and Wi-Fi. They are also actively seeking to prevent unlicensed users from themselves using LTE technology in unlicensed spectrum, according to NCTA.
The filing notes that a document submitted to a 3GPP meeting provides “an explicit roadmap for “precluding” standalone use of LTE by unlicensed carriers because “[s]tandalone deployment in unlicensed spectrum implies drastically different business models from nowadays and might impact the value chain.”
In the meantime, NCTA and its members are pursuing a number of simulations and tests, and it reports that the results are not heartening for Wi-Fi.
Specifically, the filing points to a CableLabs simulation that indicates that even LTE-u=U/LAA's listen-before-talk mechanism—mandated in some countries and suggested as a solution to interference between licenses assisted and unlicensed users—appears to fail as a method to prevent unacceptable performance degradation of Wi-Fi signals.
The industry's R&D consortium is also pursuing a field test looking to show that “technical mechanisms [can] be designed to help LTE unlicensed play nicely with Wi-Fi,” in real world deployments. CableLabs has asked the FCC to authorize a 24-month experimental license for the test.
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