Petition for Reconsidering 3.5 GHz Rules Leads Down Path to More FSS Interference, SIA Says

to a CTIA petition for reconsideration of FCC rules on the 3.5 GHz shared spectrum band. Instead, stricter citizens broadband radio service (CBRS) limits are needed to avoid "a significant increase" of more than 11 km in the protection distance needed between CBRS devices and FSS earth stations, SIA said in a filing in docket 12-354. While both CTIA and Nokia have pushed for greater emissions limits, "neither provides an adequate rationale," with CTIA itself arguing for more stringent OOBE limits "when its own members' operations could be the victims of unwanted emissions," SIA said. The satellite group also rejected the idea of changing the metric for OOBE limit compliance from average power measurements to a peak detector, because that would "undermine the prophylactic objectives of the OOBE limits." Similarly, a higher maximum effective isotropic radiated power (EIRP) and an eliminating of the antenna height limit for nonrural Category B citizens broadband radio service devices (CBSDs) will also "substantially increase the separation distances" needed to protect FSS from interference. Petitioners pushing for such higher EIRPs "fail to even acknowledge these trade offs," SIA said. But SIA said some areas of the FCC order should be reconsidered, such as the 60-second delay allowed for a CBSD to end transmission, lower its power or relocate to another channel, since even 60 seconds "could have significant adverse effects on FSS operations, including the potential to undermine safe satellite operations," SIA said. The FCC also should put in place a geolocation requirement to give reliable CBSD location information and "abandon the idea of relying on 'professional' installers to ensure the accuracy," the group said.