assuredcommunications™

HARRIS CORPORATION

Government Relations 600 Maryland Avenue, S.W.

Suite 850E Washington, D.C. 20024

phone 1-202-729-3700 fax 1-202-729- 3735

www.harris.com

December 3, 2013 Via Electronic Filing Ms. Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445 12th Street, SW Washington, D.C. 20554 Re: Ex Parte Notice, GN Docket No. 13-5 Dear Ms. Dortch: Pursuant to 47 C.F.R. § 1.1200, et seq., Harris Corporation (Harris) hereby notifies the Federal Communications Commission (Commission) of the following ex parte communication in the above-referenced proceeding. On December 2, 2013, Mark Graham, David AmRhein, and Patrick Sullivan, on behalf of Harris, and Maureen Cedro, William Syptak, and Emily Campbell of the Federal Aviation Administration (FAA), Alfred Lee and Tim Sloan of the National Telecommunications and Information Administration (NTIA), and Thomas Duncan of ITstrategy (collectively, the participants) met with Jon Sallet of the Technology Transitions Policy Task Force, Stephanie Weiner of the Office of General Counsel, Jonathan Chambers and Henning Schulzrinne of the Office of Strategic Planning & Policy Analysis, and Tim Stelzig of the Wireline Communications Bureau. The discussion centered on the above-referenced docket and the attached presentation. Mr. Graham provided a technical briefing on the FAA National Airspace System (NAS) architecture and the FAA Telecommunications Infrastructure (FTI) program. He made clear that, while efforts are being made through the FAA’s “NextGen” programs to upgrade the NAS to communications interfaces based upon Internet Protocol (IP) standards, the vast majority of FTI services continue to be TDM-based. He stated that, as no methods currently exist that are capable of replacing TDM-centric services with compatible IP-based and digital services, Harris expects that support for TDM technologies will be required beyond 2020. Mr. Graham noted that there are funding and scheduling issues that impact the FAA’s ability to upgrade to IP interfaces that would be suitable for the NAS. Moreover, Mr. Graham explained, many mission critical NAS applications have stringent timing and latency requirements that are not met by IP-based services. Mr. Graham urged the Commission to ensure that that there is no interruption to FTI services during the IP transition or IP Transition Trials. However, he made clear that Harris does not oppose IP Transition Trials per se, and understands the Commission’s desire to initiate a diverse set of experiments to evaluate impact of the eventual loss of TDM services. He suggested that the Commission consider working with the FAA and Harris on IP transition evaluations at FAA testing locations in Atlantic City and/or Oklahoma City. Finally, Mr. Graham requested that the Commission ensure that participating carriers collaborate with the FAA to identify services that could be impacted at serving wire centers participating in any IP Transition Trials and provide suitable technical solutions.

assur ed commun icat i ons™

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Respectfully submitted, ______/s/__________ Patrick Sullivan Government Relations Harris Corporation CC: Jon Sallet Stephanie Weiner Jonathan Chambers Henning Schulzrinne Tim Stelzig

harris.com

December 2, 2013

TDM to IP Transition Briefing to Mr. Jonathan Sallet

Interim Director, Technology Transitions Policy Task Force

| 2 TDM to IP Migration – Briefing to Mr. Sallet |

Briefing Topics

• Problem Statement • Summary and Recommendations • NAS and FTI Overview • FTI Service Mix – TDM and IP • Concerns with IP and Wireless Alternatives

– Timing and Synchronization – Service Performance – Information Security

• FAA System Modernization Summary • Types of TDM Services FTI delivers to other agencies • Status of Alternative Technology Assessements • Review of Summary and Recommendations

| 3 TDM to IP Migration – Briefing to Mr. Sallet |

Problem Statement

• Current policy proposals suggest discontinuing provision of Time Division Multiplexing (TDM) services at trial level and more comprehensively.

– Some providers indicate objective to discontinue TDM services by 2020.

• The FAA’s Telecommunications Infrastructure (FTI) Program, which provides the telecommunications services the FAA needs for the National Airspace System, uses TDM applications and services extensively to deliver those services.

• While efforts are being made through the FAA’s “NextGen” Programs to upgrade the National Airspace System (NAS) to communications interfaces based upon Internet Protocol (IP) standards, the vast majority of FTI services continue to be TDM-based.

• Support for TDM technologies will be required beyond 2020 until methods of replacing TDM-centric services and delivery of IP-based and digital services can be achieved.

| 4 TDM to IP Migration – Briefing to Mr. Sallet | 12/2/2013

Summary and Recommendations

• The critical nature and mission of the NAS coupled with the numerous number of services requires that legacy TDM services be continued beyond 2020.

• Prior to any IP Transition Trial, the Commission should require participating carriers to, in partnership with the FAA, identify services that could be impacted at implicated Serving Wire Centers (SWCs) and provide suitable technical solutions.

• The Commission should ensure that there is no interruption to FTI services during the IP Transition Trial.

• The Commission should consider working with the FAA/Harris on IP Transition evaluations at FAA testing locations in Atlantic City and/or Oklahoma City.

| 5 TDM to IP Migration – Briefing to Mr. Sallet |

FAA National Airspace System (NAS) Architecture

| 6 TDM to IP Migration – Briefing to Mr. Sallet |

Air Traffic Control Tower (ATCT) Detail

| 7 TDM to IP Migration – Briefing to Mr. Sallet |

The NAS Is Highly Dependent on FTI

F T I

AA elecommunications nfrastructure

| 8 | TDM to IP Transition – Briefing to Mr. Sallet

FTI Networks and Telecomm Service Offerings

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East Coast TeleportWoodbine, MD

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West Coast TeleportSomis, CA

(19) ARTCC w/Satellite(0) ARTCC w/o Satellite(40) KU-Band Satellite(3) C-Band Satellite(10) Microwave(15) Telco(7) Temporary Satellites

converting to Telco

CQY

Tower

Pink outline – Temporary InstallBlue outline – Permanent Install

Operations Network (Voice & Data) • Voice and data traffic critical to flight operations • Over 4,400 sites with over 22,000 telecom services • Range of service types (speed, digital/analog, IP, interfaces) • Trusted internet connections

Mission Support Network (Voice & Data) • Administrative traffic • Over 1,000 sites using IP technology • Remote VPN access for over 25,000 users

FTI-SAT Network • Provides satellite connectivity to remote portions of operational

network • 50 Satellite Sites • East and west hub sites for redundancy Microwave Network • Cost-effective communication services in challenging geographic

locations • Over 175 sites in continental US, Alaska, Hawaii, Guam, Puerto

Rico, and Virgin Islands HawaiiHawaii

Puerto Rico – VIPuerto Rico – VI

GuamGuam2GHz LDRCLRCL NetworksNon-reallocated LDRCL

2GHz LDRCLRCL NetworksNon-reallocated LDRCL

Alaska

Network Operations

Network Operations

Control Centers

Primary, Backup, and Emergency

(PNOCC, BNOCC

ENOCC)

Security Operations

Control Center (SOCC)

| 9 | TDM to IP Transition – Briefing to Mr. Sallet

Typical FTI Service Implementation

PrimaryWAN

AlternateWAN

PrimarySWC

AlternateSWC

PrimarySWC

AlternateSWC

Carrier provided leased circuits

FAA Site

FTIE

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FAA

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FAA Site

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FAA

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Access(DS0, DS1, DS3, OC-x) Transport Access

(DS0, DS1, DS3, OC-x)

SWC – Serving Wire CenterCarrier-Leased Telecommunication Circuits: An Integral Component of FTI Services

| 10 | TDM to IP Transition – Briefing to Mr. Sallet

FTI Service Mix

• The NAS is a large and diverse enterprise with over 22,000 services

Service Implementation Service Count Percent of TotalTDM Services 21051 92%IP Services 1928 8%

Total Services 22979

The Vast Majority of FTI Services Are TDM-Based

| 11 | TDM to IP Transition – Briefing to Mr. Sallet

FTI TDM-Based Service Types

• There are five basic types of TDM-based services that are problematic for IP and wireless alternatives – Voice Grade services, VG-x (where x = 1,2,3,4,5,6,7 or 8) as

defined by Bellcore TR-NWT-000335 – Direct Digital Connectivity (DDC) – Digital Data Service (DDS) – Transmission System 1 (T1) – Other TDM Services

• e.g., Fractional T1, T3

There Are Many Variants of the 5 Types of TDM-Reliant Services Identified

| 12 | TDM to IP Transition – Briefing to Mr. Sallet

Scope

Service InterfaceType Quantity

VG-x 11690DDC 5818DDS 302T1 2907Other 334

• The scope of the FAA’s inventory of TDM-based services is significant:

No Single Technology or Service Alternative Can Support All of The TDM-Reliant Interface Types

| 13 | TDM to IP Transition – Briefing to Mr. Sallet

Technical Issues with IP and Wireless Alternatives for TDM

• Timing and Synchronization • Service Performance • Information Security

| 14 | TDM to IP Transition – Briefing to Mr. Sallet

Timing and Synchronization

• FAA Legacy TDM-based systems require timing accuracy traceable to a GPS or Cesium clock source

• FAA NAS Navigation and Weather Systems also require accurate timing • IP timing techniques such as Network Time Protocol (NTP) or Precision

Time Protocol (PTP) do not provide the needed accuracy

1 ms1 μs1 ns

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PTP

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Current TDM Timing Accuracy

IP Timing Accuracy

Carrier-Provided TDM T1 Circuits Provide the Necessary Timing Accuracy for Key NAS Systems

| 15 | TDM to IP Transition – Briefing to Mr. Sallet

Service Performance

• The primary mission of the NAS is to ensure the safety of the flying public • FTI availability and latency requirements are stringent:

• The availability of Carrier Ethernet services varies due to differences in implementation and standards maturity

• Carriers do not currently offer Service Level Agreements (SLAs) for their 4G LTE wireless networks – Dependent on cell density, capacity over a shared infrastructure, and

other factors – Early evaluations have also observed significant latency issues

RMA1 0.9999971RMA2 0.9999719RMA3 0.9998478RMA4 0.9979450RMA5 0.9972603RMA6 0.9904215RMA7 0.9970000

LL1 50msLL2 90msLL3 225msLL4 350msLL5 750msLL6 1000msLL8 370ms

AVAILABILITY LATENCY

Wireless and Ethernet Do Not Provide the Required Availability and Latency Performance Needed for Critical NAS Services

| 16 | TDM to IP Transition – Briefing to Mr. Sallet

Information Security

• FTI provides Private Line TDM services that do not share bandwidth with other services

• Private Line TDM services provide deterministic performance • Statistically multiplexed IP services and Carrier Ethernet services

share bandwidth and exhibit stochastic behavior – FTI provides private IP service by implementing IP technology over

TDM technology – Routers are not shared with any other users outside of the NAS – Private IP implementation greatly reduces the threat of outsider attacks

• Wireless services are susceptible to jamming – Creates risk if both primary and backup circuits are wireless

Shared Infrastructure IP, Carrier Ethernet, and Wireless Services Are Less Secure Than Private Line TDM Terrestrial Services

| 17 | TDM to IP Transition – Briefing to Mr. Sallet

FTI Network Infrastructure for TDM and IP-based FAA Systems

FAA Site

DS0 (VG or DDS)

FTI Service Delivery Point (SDP)

FAASystem

FAASystem

FAASystem

FAASystem

FAASystem

FAASystem

Router

DigitalAccessCarrierSystem(DACS)

FAASystem

DS0 (VG)

DS1 or DS3

Modem

OCx

FAASystem

AlternateSWC

OpticalMultiplexer

Ethernet

DS0 (VG or DDS)

Router

DS0 (VG)

DS1 or DS3

Modem

OCx

OpticalMultiplexer

Multiplexer

PrimarySWC

FAASystem

FAASystem

FAASystem

FAASystem

FAASystem

FAASystem

FAASystem

FTI Equipment

DigitalAccessCarrierSystem(DACS)

Multiplexer

A/B Switch

VG or DDS

DDC

T1

VG, DDC, or DDS

VG, DDC, or DDS

VG orDDC

VG, DDC, or DDS

VG, DDC, or DDS

T1

VG or DDS

DDC

Ethernet

Ethernet

Ethernet

• The largest FAA site has1117 FTI services; smallest site has 1 service

• Example service delivery methods and interface types are represented on this illustration

• IP services are currently transported over private TDM infrastructure

Transition to IP Technology May Result in Major System and Equipment Changes

| 18 | TDM to IP Transition – Briefing to Mr. Sallet

FAA System Modernization Summary

• The FAA has five NextGen transformational programs underway that will utilize updated communications interfaces as part of modernizing the NAS:

– Automatic Dependent Surveillance Broadcast (ADS-B) – Data Communications Integrated Services (DCIS) – NAS Voice System (NVS) – SWIM (now called NEMS – NAS Enterprise Messaging Service) – NNEW (now called CSS-Wx - Common Support Services Weather )

• NVS will upgrade many of the VG-x interfaces to VoIP technology but it is expected to take more than ten years to complete transition

– Progress dependent on consistent funding and mitigation of operational risk • Other programs such as Surveillance Interface Modernization (SIM) will

upgrade many DDC interfaces but it is expected to take several years to complete transition

• However, there are many TDM legacy interfaces that these NextGen programs do not upgrade

– e.g., Weather Sensors, Flight Strips, Flight Movement, etc.

NextGen Does Not Currently Plan to Upgrade All Legacy TDM Interfaces and It Will Take Several Years to Upgrade Those That it Does

| 19 | TDM to IP Transition – Briefing to Mr. Sallet

Example 1: FAA Roadmap for Voice Switches and Recorders

Replacement system does not enter production phase until FY2016-17 timeframe

Legacy TDM-Based Switches Will Remain in Operation Beyond CY2020

| 20 | TDM to IP Transition – Briefing to Mr. Sallet

Example 2: FAA Roadmap for Surveillance Radars

Deployment of replacement capabilities

extends beyond 2020

Radar services depend on the synchronous characteristics of TDM-based services Radar Services Depend on the Synchronous Characteristics of TDM-Based Services

| 21 | TDM to IP Transition – Briefing to Mr. Sallet

Types of TDM Services FTI delivers to other agencies

• Department of Defense (570 services) – Military Airports

Voice Radar Inter-facility Data

– NAS Defense Program Voice Bridges with FAA Air Traffic Controllers SCRAMNet

• National Weather Service (787 services)

– Weather sensors – Weather radar

FTI Provides Services to Other Government Agencies Via TDM-Based Technology

| 22 | TDM to IP Transition – Briefing to Mr. Sallet

Status of Alternative Technology Assessments

• Carrier Ethernet – Held technology meetings with AT&T, Sprint, XO, Coriant (aka Sycamore) and

Verizon – Received TDM to IP conversion equipment from RAD for evaluation – Evaluation is just getting started

• LTE – LTE equipment received and AT&T Private Network configured – Currently experiencing high latency – investigation is in progress – Next step is to connect equipment with serial/analog interfaces to IP conversion

equipment

• TDMA Very Small Aperture Terminal (VSAT) for remote locations – Issued RFI to several vendors to assess capabilities and develop a business case – Likely to require some relaxation of availability and latency performance

specifications

One Transition Solution Will Not Address the Needs of All TDM-Based Services

| 23 TDM to IP Migration – Briefing to Mr. Sallet | 12/2/2013

Review of Summary and Recommendations

1. The critical nature and mission of the NAS coupled with the numerous number of services requires that legacy TDM services be continued beyond 2020.

2. Prior to any IP Transition Trial, the Commission should require participating carriers to, in partnership with the FAA, identify services that could be impacted at implicated Serving Wire Centers (SWCs) and provide suitable technical solutions.

3. The Commission should ensure that there is no interruption to FTI services during the IP Transition Trial.

4. The Commission should consider working with the FAA/Harris on IP Transition evaluations at FAA testing locations in Atlantic City and/or Oklahoma City.