The Australian Communications and Media Authority (ACMA)

Submission to

the Australian Communications and Media Authority (ACMA):

Comments on

Spectrum for broadband in the millimeter wave bands

October 20th, 2017

Table of Contents

1. Executive Summary 1

2. Comments 1

Q1. What disposition should the ACMA adopt in progressing possible 5G mmWave bands? Is a traditional approach appropriate, where Australia would wait until there were clears signs of a harmonised, widespread ecosystem developing in a band before it was seriously considered domestically? Or should a more proactive approach be adopted that would potentially make bands available very early in a more speculative manner? What are the benefits and risks to each approach? 1

Q2. When, or under what circumstances, would it be appropriate for potential 5G mmWaves to progress beyond monitoring in the ACMA’s mobile broadband work program? 2

Q3. What bands are the most mature in terms of possible early moves on 5G mmWave bands? 2

Q4. What is the relative priority of investigation of mmWave bands versus other potential mobile broadband bands below 6 GHz? 3

Q5. Are there any specific regulatory changes that would be required to facilitate and support satellite services in the context of 5G? 3

Q6. Should the 26 GHz band be accelerated through the initial investigation stage to the preliminary re-planning stage in the ACMA’s process for consideration of additional spectrum for MBB services? Why/Why not? 5

Q7. Are there specific issues that may affect the timeframe in which the 26 GHz band could be made available for broadband services? 5

Q8. Should the 24.25-27 GHz or 24.25-27.5 GHz be made available initially for broadband services? 6

Q9. What licensing approach should be used for broadband in the 26 GHz band? 6

Q10. What geographical areas should be made available for broadband in the 26 GHz band? 6

Q11. Should any other mmWave bands be accelerated through the initial investigation stage to the preliminary re-planning stage in the ACMA’s process for consideration of additional spectrum for MBB services? Why/Why not? 7

Q12. Are there specific issues that may affect the time frame in which other mmWave bands could be made available for broadband services? 7

Q13. Should part or all of any these bands be considered initially for broadband services? 8

Q14. What licensing approach should be used for broadband in other mmWave bands? 8

Q15. What geographical area should be made available for broadband in other mmWave bands? 8

3. Acronyms and Abbreviation 8

4. Contacts 9

Appendix 1 10

1. Executive Summary

Samsung Electronics Co., Ltd (hereinafter Samsung) is pleased to take an opportunity to submit these comments to the ACMA in response to the consultation on “spectrum for broadband in the millimeter wave bands[1]”, and are grateful for the opportunity to work with the ACMA on 5G spectrum in the millimeter wave bands.

In section 2, Samsung provides views on the issues for comment on 5G. Samsung fully supports ACMA taking into account mmWave bands for 5G. In order to drive an early 5G market using the 26 GHz mmWave bands from 2018 in Australia, Samsung would encourage ACMA to license the portion 26.5 – 27.5 GHz first due to the early global availability of equipment to support this range. Once global licensing developments in the remainder of the 26 GHz band (24.25 – 26.5 GHz) are clearer, for example in Europe and/or China, then ACMA could consider licensing this remainder in a second phase once its clear that global availability of equipment will materialize. Samsung also encourages ACMA to give serious consideration to also making the 28 GHz band (26.5 – 29.5 GHz) available for mobile and fixed applications benefiting from early equipment availability from developments in countries such as the US, Japan and Korea.

Finally Samsung thanks the ACMA for the opportunity to comment on this consultation, and looks forward to working closely with the ACMA continuously.

2. Comments

In this section, Samsung provides views for each question. Especially, Samsung encourages the ACMA to release mmWave bands focusing on 26 GHz and 28 GHz band for early 5G market from 2018 in Australia. Due to early adoption of 28 GHz band for 5G pre-commercial services in some countries like USA, Samsung expects to see early equipment eco-system development in 28 GHz band would be sooner than one in the 26 GHz band

Q1.  What disposition should the ACMA adopt in progressing possible 5G mmWave bands? Is a traditional approach appropriate, where Australia would wait until there were clears signs of a harmonised, widespread ecosystem developing in a band before it was seriously considered domestically? Or should a more proactive approach be adopted that would potentially make bands available very early in a more speculative manner? What are the benefits and risks to each approach?

The use of the mmWave bands will be a vital component for the delivery of compelling and fully capable of 5G services. In these new frequency ranges there may be a number of national spectrum management decisions and actions that are required in order to make these bands available for 5G. These decisions take time. Other countries and regions recognize the need to move early and are therefore taking a more proactive stance that helps provide a focus for the development of harmonized solutions for both spectrum and technology. Already clear preferences are emerging through the identification of the 28 GHz band for 5G in some countries and the commitment to develop the 26 GHz range as a 5G pioneer band in others[2].

Therefore Samsung believes that the Australian digital economy, consumers and businesses will all benefit from a proactive stance with licensing in 2018 and that by fully engaging with the international developments the risks can be minimized.

In addition, Samsung recommends that Australia would benefit from a liberalized electronic communications services licensing approach so that early 5G systems delivering MBB and FWA like services in the 28 GHz band could bring a timely solution for the delivery of widespread broadband services.

Q2.  When, or under what circumstances, would it be appropriate for potential 5G mmWaves to progress beyond monitoring in the ACMA’s mobile broadband work program?

Commercial deployments of 5G using mmWave bands are anticipated to commence in 2018 in US. mmWave bands provide high performance and capacity in dense urban areas and in peak times and will be a significant and essential driver for 5G. Accordingly, Samsung recommends that ACMA takes the earliest opportunity to move from a “monitoring” phase to a “proactive” stance and develops a work plan for the release of mmWave spectrum especially in those bands that are consistent with the international developments identified above and will have equipment availability. In particular Samsung believes the frequency bands in the ranges below 30 GHz (i.e. 26 GHz and 28 GHz) will be vital for early equipment eco-system development.

Q3.  What bands are the most mature in terms of possible early moves on 5G mmWave bands?

As a result of several administrations’ policies, research papers, technology trials and ITU studies, the 26 GHz and 28 GHz band have become a key mmWave band for early 5G. It continues to be a focus and is the most mature from a development perspective for early 5G in mmWave bands.

Samsung recommends the following due to global licensing and equipment availability developments;

-  26.5 – 27.5 GHz is licenced in 2018 benefiting from global developments and equipment availability in Europe (probably some of European countries).

-  26.5 – 29.5 GHz would also made available in 2018 - 2019 benefiting from global developments and equipment availability in the US, Japan and Korea

-  Once the timing for licensing, spectrum availability and equipment availability for 24.25 – 26.5 GHz is clearer for countries in Europe and/or China then ACMA can determine when to licence 24.25 – 26.5 GHz so that there is confidence that equipment will be available to support this range

The 28 GHz band is well supported and will be available early in some markets but it is unlikely to be available in every region and country. Taking into account the growing readiness of the 28 GHz band for early 5G deployment and similar radio propagation characteristics, the 24.25-27.5 GHz band (hereinafter 26 GHz band) could also be a good solution. Europe has identified the 26 GHz band as a European pioneer band for 5G and there may be a good opportunity for technology to incorporate both the 26 GHz and 28 GHz ranges into a single contiguous global harmonized solution. In addition this 26 GHz range is within the scope of the WRC-19 AI 1.13 studies under ITU-R Resolution 238 (WRC-15).

Therefore, Samsung suggests that ACMA should study the 26 GHz and 28 GHz ranges for 5G in Australia and proactively engage in the WRC-19 preparation in particular for the 26 GHz range.

Q4.  What is the relative priority of investigation of mmWave bands versus other potential mobile broadband bands below 6 GHz?

As described in Appendix 1, from the varied studies and investigation in the world, it is foreseen that various spectrum bands will be required. Specifically, many administrations and industries have recognized the potential for early availability of the 3.5 GHz band and mmWave bands for 5G services.[3]

While the 3.5 GHz band offers advantages from coverage and good radio propagation perspectives, mmWave bands are required to provide wider contiguous bandwidth to support the high data throughput that is an essential characteristic of the full 5G vision.

And not only lower band below 6 GHz (focusing on 3.5 GHz band) but also mmWave bands will be necessary to realize new services in 5G era, taking into account the varied ITU references and global investigations.

Today, some countries are reviewing the optimal use case for the bands both below 6 GHz and mmWave. In other words, they are considering both mmWave bands for high throughput mobility service and FWA and below 6 GHz bands for full mobility and coverage.

Consequently, taking into account these efficient usage and mutual-complementary parts of the spectrums for 5G, bands below 6 GHz and mmWave bands will be used for 5G simultaneously.

Therefore, Samsung is of the view that both the bands below 6 GHz (esp. 3.5 GHz band) and the mmWave bands (26 GHz and 28 GHz) are essential components for compelling 5G services that should be investigated and provided with same priority for 5G.

Q5.  Are there any specific regulatory changes that would be required to facilitate and support satellite services in the context of 5G?

The mmWave bands have a characteristic such as very short wavelength. Taking advantage of this property, massive array antenna element supporting extremely narrow beamforming and beam-tracking techniques could be embedded in a very small form-factor. This technique enables to transmit the optimized beams from base station to mobile station. When use these technical approaches for 5G using mmWave bands, there are opportunity to mitigate interference in providing mmWave 5G service that might be advantageous for closer spectrum sharing.

5G systems delivering services in mmWave bands are mostly likely to be deployed in dense urban and highly cluttered environments as described Resolution 238 (WRC-15). This may also facilitate closer spectrum sharing both between different radiocommunication services and between 5G operators.

It is noted that, through FCC R&O, USA having a huge territory, adopted a geographic area licensing type.

On the other hand, as proposed above, Samsung would like ACMA to consider 26 GHz and 28 GHz band for 5G usages (mobile and fixed) in near future. The 26 GHz band is one of the candidate bands for WRC-19 Agenda Item 1.13, and the 28 GHz band are mostly matured that will soon to be commercialized for 5G FWA service as the first step. For international harmonization, especially Europe and other region, Samsung believes that 26 GHz band and 28 GHz band have good momentum.

As results of WRC-15 and CPM19-1, a variety of studies on sharing and compatibility from 24.25 GHz to 86 GHz are being conducted by ITU-R TG 5/1. In case of sharing and compatibility studies in the 26 GHz band, the results would be available at the second half of 2018.

The following table shows status on Region 3 frequency allocation in Radio Regulations and Australian frequency allocations in the band 24.25 GHz to 29.5 GHz.

Table 1. Frequency allocations and usage in Australia (24.25 GHz to 29.5 GHz)

Region 3 Allocations / Australian /
Allocations[4] / Usage[5] /
24.25-24.45
RADIONAVIGATION
FIXED
MOBILE / 24.25-24.45
RADIONAVIGATION
FIXED
MOBILE / Radiodetermination service
24.45-24.65
FIXED
INTER-SATELLITE
MOBILE
RADIONAVIGATION / 24.45-24.65
FIXED
INTER-SATELLITE
MOBILE
RADIONAVIGATION / Radiodetermination service
24.65-24.75
FIXED
FIXED-SATELLITE (Earth-to-space)
INTER-SATELLITE
MOBILE / 24.65-24.75
FIXED
FIXED-SATELLITE (E-s)
INTER-SATELLITE
MOBILE / Radiodetermination service
24.75-25.25
FIXED
FIXED-SATELLITE (Earth-to-space)
MOBILE / 24.75-25.25
FIXED
FIXED-SATELLITE (E-s)
MOBILE / Radiodetermination
service
25.25-25.5
FIXED
INTER-SATELLITE
MOBILE
Standard frequency and time signal-satellite (E-s) / 25.25-25.5
FIXED
INTER-SATELLITE
MOBILE
Standard frequency and time signal-satellite (E-s) / Radiodetermination
service
25.5-27
EARTH EXPLORATION-SATELLITE (s-E)
FIXED
INTER-SATELLITE
MOBILE
SPACE RESEARCH (s-E)
Standard frequency and time signal-satellite (E-s) / 25.5-27
EARTH EXPLORATION-SATELLITE (s-E)
FIXED
INTER-SATELLITE
MOBILE
SPACE RESEARCH (s-E)
Standard frequency and time signal-satellite (E-s) / Space research service,
Radiodetermination service
27-27.5
FIXED
FIXED-SATELLITE (E-s)
INTER-SATELLITE
MOBILE / 27-27.5
FIXED
FIXED-SATELLITE (E-s)
INTER-SATELLITE
MOBILE / Fixed-satellite service,
Radiodetermination service
27.5-28.5
FIXED
FIXED-SATELLITE (E-s)
MOBILE / 27.5-28.5
FIXED
FIXED-SATELLITE (E-s)
MOBILE / Fixed-satellite service,
Fixed service (P-P)
28.5-29.1
FIXED
FIXED-SATELLITE (E-s)
MOBILE
Earth exploration-satellite (E-s) / 28.5-29.1
FIXED
FIXED-SATELLITE (E-s)
MOBILE
Earth exploration-satellite (E-s) / Fixed-satellite service,
Science service
29.1-29.5
FIXED
FIXED-SATELLITE (E-s)
MOBILE
Earth exploration-satellite (E-s) / 29.1-29.5
FIXED
FIXED-SATELLITE (E-s)
MOBILE
Earth exploration-satellite (E-s) / Fixed-satellite service,
Fixed service (P-P)

Therefore, because Australia has also huge territory, Samsung proposes that the ACMA considers the use of geographic area licensing appropriately, taking into account the possibility to mitigate interference from mmWave 5G to existing services. New and/or liberalized licensing approach(es) and other regulatory measures might be important to consider to facilitate the fast roll out of high density cells in urban areas.