The document summarizes SAMENA's response to Iraq's Communications & Media Commission regarding proposed fixed wireless broadband licensing and spectrum allocation. Key points: 1. SAMENA believes licenses should allow both fixed and mobile broadband to promote broader access and a viable business case. Restricting licenses to just fixed use may undermine commercial deployment. 2. There may be cross-border interference issues, particularly with neighboring countries using all TDD networks in the 2.6GHz band. Band plans should be harmonized as much as possible to minimize interference. 3. The proposed amount of spectrum for fixed wireless may exceed market needs. A combined mobile/fixed approach could better support broadband access through economies of scale for operators.

1. 1
SAMENA Response to CMC Iraq – Fixed Wireless Broadband
Licensing and Spectrum
January 2019
Introduction
SAMENA Telecommunications Council welcomes the opportunity to respond to this
important consultation from the Communications & Media Commission of Iraq.
SAMENA would like to address two issues regarding the proposed award, namely:
1. The general approach to service neutrality and the aim to restrict licences to fixed
broadband (Question 3). SAMENA believes that technology neutrality should go
hand in hand with service neutrality. A mobile licence that allows fixed to be provided
would be the best approach to promote broadband for the benefit of consumers,
society and the economy in Iraq. A licence that only allows fixed use may be too
restrictive. This will undermine the business case for commercial deployment.
2. That there may be engineering issues that need to be addressed with regard to
cross-border radio interference control, particularly with the 2.6 GHz band. We
understand that some of Iraq’s neighbours (such as Saudi Arabia) are intending to
use an all TDD band plan (Band 41). That consideration should be given to
harmonising band plans with neighbouring countries as far as possible to minimise
cross-border interference.
SAMENA believes that the Fixed Wireless Broadband market may be too small to merit the
amount of spectrum being suggested in this consultation. The Ovum report quoted in the
consultation suggests that in the Middle East there will be around 40,000 connections by
2020 – assuming 4 people per household that is 160,000 users. Assuming a Middle East
population of 371 million (Wikipedia), this is less than 0.05%. Mobile is close to 100%
penetration in many markets (but less in Iraq).
For questions regarding this paper please contact:
Mr Roberto Ercole CEng, Director Public Policy, SAMENA,
roberto@samenacouncil.org
#304, Alfa Building, Knowledge Village, P.O. Box: 502544, Dubai, UAE

2. 2
About SAMENA
SAMENA Telecommunications Council1
is tri-regional not-for-profit industry association
spanning more than 25 countries, including Afghanistan, Algeria, Bahrain, Bangladesh,
Egypt, Iran, Iraq, Jordan, Kuwait, Lebanon, Libya, Morocco, Nepal, Oman, Pakistan,
Palestine, Qatar, Saudi Arabia, Sri Lanka, Sudan, Syria, Tunisia, Turkey, United Arab
Emirates, and Yemen. It represents the interests of more than 85 telecom operators and
service providers in the fixed and mobile space, and stakeholders from the wider digital
ecosystem, including technology, equipment, and software manufacturers, internet
companies, consulting companies, academia and regulatory authorities.
It is SAMENA’s mission to serve as a sector-development partner to governments and
industry for the joint creation of a flourishing and sustainable ICT sector to enable
sustainable digital transformation. Our key objectives are to enable sustainable growth,
incentivize investments and broaden value creation through effecting adoption of new
regulatory approaches in the areas of Digital Services, Data Regulation, Spectrum
Management, and Industry Fees & Taxation.
Issue 1 – The licensing of the band for Fixed Wireless Broadband
It is important that Iraq ensure that the mobile industry has enough spectrum to be able to
meet growing consumer demands, such as demand for data. As far as SAMENA is aware,
of the 1000 MHz or so identified for mobile broadband (IMT) services, only around 200 MHz
has been awarded to mobile services in Iraq. This places Iraq at the lower end of the
spectrum available for mobile in the region (based on data available to SAMENA and
presented at the Leaders’ Summit of 20182
).
Source - SAMENA
1 https://www.samenacouncil.org/index
2 https://www.samenacouncil.org/ls2018/
25.8% 27.5%
15.8%
44.1% 43.3%
56.0%
17.5%
29.9%
59.3%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
Percentage of Harmonised 1200 MHz
for commercial mobile

3. 3
Iraq also has a relatively low subscriber penetration rate of just over 50% according to
GSMA data3
. It is possible that mobile operators are constrained by the amount of spectrum
they have to offer higher data rates. SAMENA understand that in KSA mobile downlink data
rates have gone from @9 Mbps to 26 Mbps since the two recent spectrum awards increased
available mobile spectrum.
The summary of spectrum bands mentioned in Section 4.10 of the consultation (to be
allocated to fixed wireless broadband) amounts to over 300 MHz (not counting 450 MHz
band) of prime mobile spectrum. It is not clear from the consultation document how the
relative spectrum demands for mobile and fixed wireless have been arrived at. The number
of fixed wireless broadband connections globally is low compared to mobile. The Ovum
report shows very limited subscriber numbers of perhaps 40K in the region. The table below
shows OECD deployment, with the highest being around 10.5% in the Czech Republic.
According to ITU data the number of fixed wireless broadband connections in KSA was 3.8
million in 2014. However, KSA has been able to ensure increased mobile spectrum supply
whilst catering for a large number of fixed wireless broadband users.
https://www.oecd.org/sti/broadband/1.2.OECD-FixedMobileBB-2017-12.xls
note there may be some inclusion of Wi-Fi services in above data.
It seems that the best chance of having a commercially viable broadband network using
spectrum, is to allow operators to offer a mix of both fixed and mobile. The business case
for a standalone fixed wireless operator would seem weak, and past experience with
networks such as Wimax (and other systems before) seems to suggest it is a niche business
case at best. CMC wishes deliver broadband to the Iraqi people without the need for public
subsidy (as stated in 1.1 of the consultation document). SAMENA would recommend that the
licences issued should not unnecessarily restrict the service offering. Ideally via using a
3 https://www.gsmaintelligence.com/research/?file=4341c31bb1650dd595909a6761ffd9f0&download
0.776
10.436
5.801
0
2
4
6
8
10
12
Fixed Wireless (% Penetration)
source: OECD

4. 4
mobile licence that allows fixed use. With over 5 billion unique mobile users globally (and a
very small number of fixed only operators) seems to show the logic of such a decision.
Conclusion on Issue 1
SAMENA believes that the amount of spectrum identified for fixed wireless broadband in Iraq
may be more than can be realistically supported in the market. The main commercial
chance seems to be for a mobile operator to offer fixed wireless broadband as an add-on to
its mobile service. This will allow for economies of scale and scope (common core network,
billing, customer support etc) rather than a dedicated fixed provider.
If the aim is to award licences as fixed until band clearance and refarming can be done, then
this should be clearly stated. Otherwise the danger is that mobile operators (who need more
spectrum and could provide both mobile and fixed broadband services in and economically
efficient way) will not be able to. SAMENA believes that lack of spectrum acts as a
constraint to the data services a mobile operator can offer, and that Iraq’s relative position in
penetration and amount of spectrum (relative to her neighbours) means this should be
carefully considered.
Issue 2 – cross-border coordination
SAMENA believes that harmonising the use of bands within the region is the best way to
control cross-border interference. This helps to prevent the most complex form of
interference which is base transmit into base receive. In this situation not only do you have
the potential for two high gain antennas (perhaps 18 dBi each) to be pointing at each other,
but they are both relatively high above the ground. In FDD system this means that this is
avoided.
In the case of TDD this might not be the case unless there is some alignment of the frame
structure between operators near a border. This may be a particular problem in the 2.6 GHz
band, if Iraq adopts an FDD/TDD band plan (band 38 and 7) whilst a neighbour such as
Saudi Arabia adopts all TDD (band 41).
This is explored in Annexes 1-3, where international benchmark figures for electric field
strength at a border for LTE are shown (and derived). This is then used to calculate the
propagation loss required to meet such levels. This loss value (133 dB) is then used to
calculate a possible coordination distance. The distance derived for the case of two
uncoordinated TDD systems at 2.6 GHz are:
• 60km using Free-Space attenuation; and
• 30 km using the ITU propagation model P.452 for calculating interference on the
Earth.

5. 5
Annex 1 Extract ECC Recommendation (11)05 - Amended Feb. 2017
Cross-border Coordination for Mobile/Fixed Communications Networks (MFCN) in the
frequency band 2500-2690 MHz
Using 3GPP standards to derive a field strength value
Using the assumption of LTE deployment allows for the appropriate figures from the 3GPP standards to be
used4
. According to 3GPP TS 36.141 (v14.3.0 release 14) the test requirement for in-channel selectivity is given
in table 7.4-1. The table suggests a figure of -77 dBm for an E-UTRA bandwidth of 10 MHz. The in-channel
selectivity is a measure of the receiver’s ability to receive a wanted signal in the presence of interference on the
same channel, with a wanted signal specified at -96.7 dBm. At -77 dBm the receiver can achieve a throughput of
at least 95% of its maximum for a 10 MHz channel, operating near its maximum usable sensitivity (thermal noise
floor plus the receiver noise figure).
Using formulas in ITU-R P.525-3, it is possible to convert this -77 dBm power in the victim receiver to a field
strength level of 68 dBV/m for a 10 MHz channel. This agrees with Table 1 (centre frequencies not aligned and
converting from 5 to 10 MHz bandwidth). However, because this is base transmit to base receive, there is a need
to add 18 dB for the victim receiver, as well as converting from 3m height to say 25m (i.e. mobile to base station
height). Hence the value used is 33 dBV/m for the maximum field strength trigger (unsynchronised TDD).
4 http://www.3gpp.org/

6. 6
Annex 2
Discussion of the Engineering Issues regarding Cross-Border interference
The general method used in this paper is to equate an LTE base station power to an electric
field strength at the transmitter (Tx_FS5
). The maximum interfering electric field strength that
an LTE receiver can work in is then derived (Rx_Sens). This value is either calculated
(using 3GPP standards) or a figure is taken from a CEPT recommendation. The difference
between the maximum interfering field strength an LTE receiver can tolerate, and the field
generated by a base station is calculated.
This difference is the propagation path loss required to prevent cross-border interference, as
shown in the equation below.
equation 1 (in dBs)
This equation would then give an indicative value for the path loss required to prevent
interference from mobile services in neighbouring countries into Iraq. This path loss can
then be converted into a distance using an appropriate propagation model such as ITU
P.4526
with or without detailed terrain data. This can give a general estimation of the
potential coordination distance between Iraq and her neighbours (such as Saudi Arabia, and
Jordan, etc.).
For a more accurate calculation of the separation distance required at the border it would be
necessary to use details of the specific networks. That is:
• The exact locations of the base stations (to allow pathloss to be calculated using real
terrain and clutter data); and
• The real antenna patterns of the two base stations (victim and interferer) would need
to be used.
It may be that operators will set up their macro base stations near the border but pointing
towards their subscribers. That is a Jordanian network macro base station near the Iraqi
border will point into Jordan - so the main lobe antenna gain is not “seen” in Iraq (i.e. the
back-to-front ratio must be used).
It should also be remembered that these would be “trigger values” and would not necessarily
mean there would be cross-border interference, but that more detailed study would be
required.
In the discussion here for LTE a 1300 W macro base station transmitter power is assumed
(31.14 dBW)7
. Using equation 7 of ITU-R P.525-3 (at 1m) gives a field strength of 166
dBµV/m. This 166 dBµV/m value is used as the TX_FS value in equation 1 for this
paper. This transmitter field strength value is frequency independent – however antenna
effective aperture is not, and this leads to different RX-Sens field strength values at different
frequencies.
5 The field strength at 1m is used.
6 https://www.itu.int/rec/R-REC-P.452/en
7 Assume 20W transmitter with 18 dBi antenna gain for macro base station.

7. 7
Annex 3
Path Loss at 2.6 GHz using Free-Space and ITU-R P.452-16
Source- Seamcat https://www.cept.org/eco/eco-tools-and-services/seamcat-spectrum-
engineering-advanced-monte-carlo-analysis-tool
Parameters:
2500 MHz, 25m transmit and receive height (to simulate base tx to base rx interference)
50%-time availability (P.452), 100% outdoor no clutter (tx or rx)
Required Path loss* = 166dB – 33dB = 133 dB
Gives around 60 km free-space or 30 km using P.452-16
*166 from Annex 2, and 33 from Annex 1 table 2 (converting CEPT figure from 5 to 10 MHz
value for uncoordinated TDD networks).