103. Nonetheless, because the Protection Zones are based on typical LTE devices operating at a maximum EIRP of 20 dBm, we propose an EIRP power limit of 20 dBm (100 mW) for mobiles and portables (handhelds) operating in the 1695-1710 MHz and 1755-1780 MHz bands. The Commission's rules will govern all devices nationwide, rather than typical devices operating near the 27 Protection Zones. Therefore, we seek comment on whether an EIRP limit of 23 dBm would necessitate enlarging the Protection Zones, and if so, whether the benefits this higher power limit would outweigh the increased burden of having to coordinate more commercial operations with Federal incumbents. For mobiles and portables (handhelds) operating in the 2020-2025 MHz band, we propose a maximum of 2 watts EIRP. Regarding the latter proposal, we believe there is virtually no risk of overloading BAS receivers in the adjacent 2025-2110 MHz band given the likely separation distances, AWS-3 mobile nominal transmit powers, steerable BAS antennas, and path losses. We further propose that mobile and portable stations operating in these bands must employ a means for limiting power to the minimum necessary for successful communications. We seek comment on these proposals, including the costs and benefits of the proposals and any alternatives.
104. Co-Channel Interference between AWS-3 Systems. If we ultimately decide to license the AWS-3 bands on the basis of geographic service areas that are less than nationwide, we will have to ensure that such licensees do not cause interference to co-channel systems operating along common geographic borders. The current rules for AWS-1 and AWS-4 address the possibility of harmful co-channel interference between geographically adjacent licenses by setting a field strength limit from base stations of 47 dB[mu]V/m at the edge of the license area. Due to the similarities between AWS-1, AWS-4, and AWS-3 spectrum use, we propose to amend
105. In recent filings in the H Block and Incentive Auctions proceedings, commenters have suggested that the boundary limit be adjusted to accommodate varying channel bandwidths. In the H Block proceeding, Sprint requested that the Commission modify the boundary limit to set a reference measurement bandwidth of 1 MHz, with the aim of limiting boundary power density to the equivalent of that first applied to PCS systems in 1993. At that time, operators were deploying mostly Digital AMPS, PCS1900 and CDMA technologies, which had channel bandwidths of 30 kHz, 200 kHz and 1.25 MHz, respectively. Sprint claims that because today's LTE transmissions operate on much wider bandwidths up to 20 MHz, a 47 dB[mu]V/m limit measured over the full channel bandwidth will effectively result in a comparatively lower power level. Sprint proposed to adjust the field strength limit from 47 dB[mu]V/m to 62 dB[mu]V/m per MHz.
106. We tentatively agree with Sprint that, in concept, a boundary limit that adjusts for large differences in channel bandwidths may be appropriate. The specific limit of 62 dB[mu]V/m per MHz proposed by Sprint may not be the optimal solution. Sprint derives the value for the field strength based on a comparison against a 30 kHz Digital AMPS signal. Other technologies may provide a more appropriate reference upon which to base the value for the field strength. Also, there are other metrics that may be used to limit the signal at the boundary, such as power flux density. We observe that the Commission has already adopted a bandwidth-independent approach when setting boundary limits with
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