Wireless Industry Urges Revisions to FCC Proposal for CBRS on 3.5 GHz Band
Most major wireless parties continued to urge the FCC to revise the rules it proposed for a new Citizens Broadband Radio Service on the 3.5 GHz band. Replies said the major faults of the rulemaking continue to be the proposed exclusion zones and the three-tiered spectrum access system (SAS) licensing framework. The comments, posted Friday and Monday in docket 12-354, repeated concerns that parties raised in July (CD July 16 p4). Commissioners Mike O'Rielly and Ajit Pai had also raised concerns about the size of the proposed exclusion zones, in which spectrum use would be restricted to protect government incumbents, when the commission approved the FNPRM in April (CD April 24 p4).
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Verizon said the proposed exclusion zones and the SAS framework don’t “provide incentives to promptly deploy networks using existing technologies” and “would compromise the ability of users to deploy” in the 3.5 GHz band. Verizon urged the FCC to reduce the size of the proposed “very large” exclusion zones, saying multiple analyses show the zones can be “substantially smaller” and provide protection to incumbents. The carrier urged the commission to adopt a transitional two-tiered framework instead of the three-tiered SAS framework because necessary equipment and techniques are already available to operate under a two-tiered system, allowing for prompter investment. Verizon said it doesn’t oppose increasing the power limits for general authorized access (GAA) users on the band, but said if the FCC chooses to keep current limits for GAA users, it shouldn’t simultaneously “handicap” priority access licensees (PALs) through “similarly low” limits (http://bit.ly/1w1neIq).
AT&T said it agrees the FCC should reduce the size of proposed exclusion zones, saying they “threaten to undermine the commercial viability” of the 3.5 GHz band and would deny access to services on the band for 60 percent of U.S. consumers. The carrier also advocated using a transitional framework, saying the SAS framework would be a “quagmire of uncertainty.” A transitional framework would enable immediate use of the 3.5 GHz band while the FCC revises the SAS framework, AT&T said. It said the FCC shouldn’t allow SAS to make “dynamic spectrum assignments for PALs and should provide license terms for PALs that last longer than one year to better incentivize investment in the band (http://bit.ly/VzoCS2).
Qualcomm said the FCC should reassess exclusion zone sizes based on the use of small cells, noting they can operate without interference very close to U.S. coastlines where federal naval systems operate. Interference-free sharing with those systems will be critical since the systems can’t completely clear off the 3.5 GHz band, Qualcomm said. A transitional framework would be preferable to the SAS framework, because the FCC “has no experience implementing” a framework with SAS’s attributes and its implementation would delay use of the 3.5 GHz band “for many years,” Qualcomm said. It urged the commission to license the band in large geographic blocks instead of the census block level licenses it’s currently proposing. The FCC licenses other bands using large geographic blocks, so using the census block licensing system “would not only heavily burden licensees’ administrative resources, but it would also create potentially overwhelming interference management challenges at millions of license boundaries,” Qualcomm said (http://bit.ly/1pWh2fd).
Google said the FCC should only consider potential interference to federal systems when it calculates exclusion zones, rather than factor in protections for commercial operations, which it called “unnecessary and inappropriate.” Smaller, more “dynamic” exclusion zones would be sufficient to protect commercial operations based on recent Google tests, the company said. Unlike the carriers, Google said it supports FCC adoption of the SAS framework. Rules for SAS should allow dynamic use of the 3.5 GHz band, particularly creating PAL areas based on interference protection and finalizing rules the enable a wide range of small cell operations on the band, said the firm (http://bit.ly/Vzou4R).
Microsoft also said it supports adoption of the SAS framework, saying the framework could assign channels to PALs when incumbents aren’t using the spectrum and to GAA users when incumbents and PALs aren’t using it. The FCC would be taking a “major step backward” if it adopted a transitional framework, Microsoft said (http://bit.ly/1rNYHjE).
The Telecommunications Industry Association said the FCC should adopt rules that better protect the rights of PALs, saying the commission’s proposed rules effectively give GAA users “superior” rights to PALs, such as reserving 50 percent of all available spectrum for GAA use. The rules appear to be “backward if the underlying premise is that PAL users -- who must meet more stringent qualifications in applying for spectrum -- should have priority, or expressed general concerns that the proposed rules created significant uncertainty for PAL licensees,” TIA said (http://bit.ly/Ypsgj0).
PCIA, WISPA
PCIA and The HetNet Forum said they support FCC suggested revisions to the PAL tier rules, including adoption of a “transitional approach to implementation.” PCIA and HetNet Forum asked the FCC to consider increased power output levels “to enable the most flexible use of the band’s potential applications” (http://bit.ly/1oUA0Pa).
The Wireless Internet Service Providers Association (WISPA) said it still strongly supports FCC adoption of the SAS system and opposes industry calls for a transitional framework. The only material change WISPA wouldn’t oppose would be to use priority access spectrum for contained access use, the group said. WISPA said it continues to propose that the FCC incorporate spectrum sensing with the SAS and use a federal database to reduce the size of exclusion zones by including time-based and frequency-based restrictions on commercial use of the 3.5 GHz band (http://bit.ly/1v8EIhQ).
The Satellite Industry Association (SIA) said it remains concerned that introducing CBRS operations on the 3.5 GHz band will adversely affect current and future FSS earth station operations on and around the band. SIA also urged the FCC to fully test the efficacy of its SAS framework before it allows CBRS operations to begin. Exclusion zones should be sufficient to prevent in-band and adjacent-band interference to FSS earth stations, and should be based on ITU interference criteria, SIA said. The FCC must also ensure that CBRS devices are protected against unauthorized use, SIA said (http://bit.ly/1p6p5ac).
The Public Interest Spectrum Coalition (PISC) -- Common Cause, the Institute for Local Self-Reliance, New America Foundation’s Open Technology Institute and Public Knowledge -- said it “strongly supports” the SAS framework and opposes proposals for a transitional framework. The coalition said it supports reserving at least 50 percent of available spectrum on the 3.5 GHz band for GAA users and authorizing “opportunistic” GAA use of unused PAL bandwidth (http://bit.ly/1tfpIhZ).
AT&T, Google, Microsoft, PISC and WISPA said they support the FCC proposal to include the 3650-3700 MHz band in the licensing regime, while SIA and the Utilities Telecom Council (http://bit.ly/1ldodkx) opposed the proposal. Supporters of including the 3650-3700 MHz band in the licensing regime supported adopting rules to protect fixed wireless users on that band during a transition period.