Canada became the latest country to make spectrum available for enterprise private wireless networks (see here for the global market). Using a 80 MHz slice of C-band spectrum between 3900 MHz – 3980 MHz, enterprises and service providers will be able to apply for a spectrum license under the Non-Competitive Local Licensing Framework (NCL). NCL aims to cater to different types of use cases: aside from enterprise private wireless, it seeks to address rural area connectivity among other use cases. Since different applications have different requirements, it raises the question of whether NCL will meet the needs of different market segments. As it stands, it runs the risk of pleasing no one.
The Highlights
NCL licenses are available for local areas based on a vector that defines the boundaries of the service area. Licenses are for a one-year term with an option – or high expectation – to renew on an annual basis. Licensees have to demonstrate their deployment through site data uploads to maintain their license.
Two type of licenses type will be available: low and medium power. Low power licenses have a 15 km2 area limit and are available in all geographies (~2.5 km cell radius). Medium power licenses are available in rural and remote areas only to cover a minimum area of 75 km2 and a maximum area of 165 km2 (between ~5 – ~8 km cell radius).
Licensees are capped at maximum 20 MHz in a license area, which will consequently cap performance. Service providers with more than 100k subscribers will not be able to operate in upper 40 MHz of the band (3940-3980 MHz).
The power levels will be defined in separate technical rules to follow [see update below]. However, ISED (the regulator) already stated that NCL will feature lower permissible power levels than auctioned spectrum; while rural areas will be allowed higher power than urban areas.
Pricing Quirks
NCL license fees vary depending on bandwidth and geography, subject to a minimum $48/year license fee. The annual fees are:
- Urban area: $1.8 /MHz/km2
- Rural area: $0.45 /MHz/km2
- Remote area: $0.01 /MHz/km2
As an example of license cost, a medium power rural operator with 20 MHz spectrum and coverage area of 75 km2 will have to pay $675/year, or $56/month. In contrast, an enterprise seeking to cover a square block in a city measuring 1,500 m a side – which is a very large area in that setting – would only pay $48/year, or only $4/month!
In other words, spectrum is attractively priced in urban areas, but it is not comparatively so in rural areas (especially when one considers Wireless Broadband Services – WBS – spectrum as mentioned below).
Implementation Questions
Interestingly, NCL makes spectrum accessible by applying elements of auctioned spectrum (e.g. service area, spectrum cap, license fees, etc.). As more entities use NCL, coordination issues including interference will develop. In auctioned spectrum, licensees are protected from interference, while in unlicensed spectrum, interference is the price to pay for a shared asset. NCL is neither: licensees are under many similar terms to those of auctioned spectrum, but without the protection.
It is not clear to me how to compel licensees to limit coverage to a defined service area. There is no power limit defined at the service area boundary; nor that one is easy to enforce should it have been defined. I suppose that this is not a priority now given it’s a greenfield band. But I suspect that such issues could develop relatively quickly if the model is successful (i.e. 5G private network take off and become widely deployed).
WISPs Disadvantage
NCL is a part of reorganizing 3.5 GHz spectrum where part of Telesat’s C-band spectrum will be auctioned later this year. The auction will include 50 MHz in 3.65 – 3.7 GHz (WBS) that’s currently used by wireless ISPs, enterprises and others under a lightly-licensed regime. There are several issues that make WBS licensees unhappy with NCL. For one, WBS was easily accessible from both licensing and equipment availability perspectives because it leveraged a similar pre-CBRS US band. WBS license fees are much lower than NCL fees. Unlike WBS, NCL has restrictions on bandwidth and service area. Moreover, it will be more challenging to find appropriate equipment for rural areas in 3.9 GHz band now that the overlap with the larger US ecosystem is eliminated. [In the US, this band was auctioned to mobile network operators who would deploy a different class of products to address mobile connectivity which are not a fit for rural FWA. See note below.]
Concluding Thoughts
NCL is a very ambitious framework that seeks to meet the requirements of many different use cases: urban, rural, private networks and rural connectivity to name a few. Choosing a licensed-approach placed restrictions that, I believe, are a net negative for rural operators in comparison with the outgoing WBS framework. In urban areas, enterprises will have access to reasonably priced spectrum, but will 20 MHz be enough to support their application requirements? In all, incumbent mobile network operators developing their own enterprise private network services need not to worry about the competitive potential of NCL!
Note: After posting this article on LinkedIn, I received a few comments that NCL aligns with European spectrum bands in the range between 3.8 – 4.2 GHz. Specifically mentioned are the UK, Netherlands, Belgium and France in 3.8 – 4 GHz, in addition to UAE and Saudi in 4 – 4.2 GHz. My reference to equipment availability is specific to rural deployments which typically don’t use 4G or 5G, but proprietary solutions from companies like Ubiquity and Cambium among others (these two dominate the Canadian market). My understanding is that these companies have promised to develop products for NCL, but I see no evidence yet of any such products. For WBS licensees who have to move to NCL, this has become a major issue, even to the degree of closing their business.
Update – August 11, 2023: ISED released equipment certification requirements (RSS-198) with the power limits below. They opted for similar to CBRS (47 dBm/10 MHz), with a difference being CBRS defines power per devices, but ISED bases it on per-antenna, so a 3 dB advantage for 2-antenna systems:
| Equipment type | Maximum power spectral density (per antenna) |
|---|---|
| Outdoor base station, fixed service equipment | 37 dBm/MHz e.i.r.p. |
| Indoor base station | 20 dBm/MHz e.i.r.p. |
| Fixed subscriber equipment | 20 dBm/MHz e.i.r.p. |
| Subscriber equipment other than fixed subscriber equipment | 30 dBm/channel bandwidth e.i.r.p. |