Cambium Network Comments on RADWIN Petition for Amendment of Part 15

Cambium Networks submitted comments today (attached) to the FCC in response to RADWIN's Petition for Rulemaking, RM 11812, Amendment of Part 15 of the Commission’s Rules to Advance Improved Broadband Services in the U-NII-1 and U-NII-3 Bands, (filed June 18, 2018).  Broadly speaking Cambium Networks supports the Petition and concurs with others who recommend that the FCC open a rulemaking proceeding to consider the rule changes that RADWIN proposes in the Petition.

In addition, Cambium suggests that a NPRM should seek comment on applying the proposed higher power limits not only to a single directional beam, but also to multiple simultaneous directional beams. While such simultaneous narrow-beam transmissions may be more spectrally efficient and may enhance system capacity in terms of concurrent service to a greater number of end users, the FCC should consider applying the power limit per beam, not to overall transmission (i.e. dividing the allowed power over a number of beams). Otherwise, dividing the power limit over multiple beams would require each beam to transmit at a lower power relative to a single beamformed transmission, thereby reducing on average each transmission’s modulation level. This difference in power limits disadvantages the more spectral efficient technology (multiple directional beam) compared to the less spectral efficient solution (one single directional beam).