Representatives from Qualcomm (NASDAQ:QCOM) and T-Mobile US (NYSE:TMUS) argued this week that the FCC should not step in to regulate LTE Unlicensed (LTE-U) and related technologies. At a CTIA-organized briefing for reports on Monday, Qualcomm and T-Mobile officials argued that LTE-U can coexist happily with Wi-Fi and that opponents of the technology had not marshalled sound technical reasons for opposing it.
Meanwhile, the National Cable & Telecommunications Association, speaking for many cable companies that have their own Wi-Fi networks, hit back hard against Qualcomm. In an FCC filing made public on Wednesday, NCTA said that Qualcomm has not engaged in meaningful collaboration with the unlicensed community, and that its proposals thus far on LTE-U/Wi-Fi coexistence are not fair or equitable.
NCTA said that "even if the 3GPP process eventually results in adequate protection mechanisms being adopted for Europe and elsewhere, there is no guarantee that such mechanisms will ever be deployed in the United States, given the announced plans for non-standard deployment of LTE-U rather than" License-Assisted Access (LAA).
"NCTA is nevertheless confident that a truly collaborative process toward effective sharing is achievable and can yield solutions that will allow LTE technologies to operate fairly in unlicensed bands," NCTA said in its filing. "But this process will require Qualcomm and others to recognize the shortsightedness of their ongoing efforts to downplay the serious concerns of consumers and the unlicensed community, and to recognize that the so-called 'sharing solutions' suggested to date are incomplete and insufficient."
During the CTIA-hosted meeting, Qualcomm's Dean Brenner, senior vice president of government affairs, said that "many of the same groups that are expressing concern about LTE-U have expressed similar concerns about LAA. He said "it comes down to the cable industry," which "is doing whatever it can to slow down, delay, obstruct LAA."
Chris Wieczorek, T-Mobile's principal corporate counsel for federal regulatory affairs, said that he thinks the conflict is "a little bit overblown." Both Wieczorek and Brenner said that their companies have vested interests in Wi-Fi and ensuring that LTE-U and LAA do not interference with Wi-Fi. However, they said the FCC should stay out of the debate. The FCC in May opened a public inquiry into LTE-U and LAA.
"We think that FCC should take a regulatory-neutral, light touch approach," Wieczorek said. "Unlicensed LTE is a new technology that's coming out onto the scene. The FCC has long and wisely chosen to not specify what technology to use in different bands."
Brenner noted that LTE-U complies with all of the FCC's rules. "There is absolutely no reason for any sort of FCC involvement," Brenner said. "The FCC is doing what they should be doing, which is they asked questions, they got technical information, and we think that we are doing all the things people at the FCC would want us to do. We're collaborating, we're working together, we're doing everything we can to make sure the technologies work well. At some point there has to be a technical basis for these issues. We've responded to all the concerns that have been raised with an extraordinarily detailed mountain of technical information."
Wieczorek said that the "biggest source of interference in Wi-Fi is baby monitors, but there's no ongoing discussion or forum right now about the hard impacts of baby monitors knocking off Wi-Fi access points."
However, the NCTA said that Qualcomm and other LTE-U proponents have not properly addressed interference concerns. "LTE-U proponents assert that they will protect Wi-Fi consumers by occupying the least-used Wi-Fi channel and then by using a duty cycling approach. The record shows that this approach is not only fundamentally flawed, but that it depends crucially on numerous undisclosed technical details," NCTA states. "How will an LTE-U system select a channel in urban environments where every channel is heavily utilized by Wi-Fi and potentially other LTE-U cells? Once it has selected a channel, exactly how will an LTE-U system determine the proportion of airtime to allocate to itself? What, if anything, will be done to ensure that operators do not configure this behavior to allocate the maximum amount of airtime to themselves?"
"As for LAA -- which is irrelevant if carriers deploy LTE-U in the United States -- proponents indicated only that LAA is anticipated to include some manner of listen-before-talk functionality," NCTA added. "But proponents fail to provide important details such as the required 'listening' sensitivity or whether this functionality will be accompanied by exponential back-off. These details make a dramatic difference in LAA's ability to share effectively."
A major bone of contention between LTE-U proponents and the unlicensed community is whether Qualcomm and its allies have collaborated enough with unlicensed interests through the established IEEE standards-setting process for unlicensed technologies.
"There has been collaboration with the IEEE," Brenner said. "A representative from the IEEE attended an all-day technical workshop that Qualcomm, Verizon and the other members of the LTE-U Forum gave on May 28. The presentations at that workshop were extraordinarily deep-dive presentations. They're all available on the LTE-U Forum website."
Brenner also noted that Verizon (NYSE: VZ) and Qualcomm presented a technical briefing on LTE-U to the IEEE 802.19 group at the IEEE 802 Plenary Session on July 14. The session discussed the coexistence among wireless technologies.
NCTA says that is not enough. "The fact that Qualcomm has held a handful of meetings, exchanged letters, or made presentations at trade shows does not constitute true coordination in the development of sharing solutions, and is no substitute for the time-tested IEEE process," NCTA said.
"These are deep technical issues, deep engineering issues," Brenner said. "We are doing everything we can to allay concerns."
Brenner added: "I think there are competitive issues underlying some of the complaints. It's destabilizing. These technologies are going to shake things up. We know they are going to shake things up for the better by giving consumers more options. But look, the whole history at the FCC is whenever a new entrant comes in with a technology, incumbents oppose the technology."
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