Most Commenters Want Only Limited Changes to 3.5 GHz CBRS Rules
NAB raised concerns about interference if the FCC makes technical changes to rules for the 3.5 GHz citizens broadband radio service (CBRS) band. Other commenters said the FCC should minimize changes to the rules approved three years ago. The FCC approved the initial 3.5 GHz NPRM in 2012 (see 1212130044), setting up an experimental three-tiered access and sharing model made up of federal and nonfederal incumbents, priority access licenses (PALs) and general authorized access users. In October, commissioners agreed to seek comment on revising the rules (see 1710240050).
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“While NAB fully supports the Commission’s proposal to retain the -40 dBm/MHz conducted power limit above 3720 MHz, the NPRM’s proposals to allow additional emissions into the 3700-3720 MHz portion of the C-band lack a sound technical basis and would create increased and unacceptable interference,” the association said. The sole argument for relaxing emissions limits is the desire of wireless companies to employ wider bandwidth channels without reducing power, NAB said. “Simply put, the bandwidth of in-band signals should not affect the potential for interference to adjacent services,” NAB said in comments in docket 17-258. “The desire for wider bandwidth channels does not change the laws of physics, or previous FCC findings, with respect to protection from harmful interference to operations in adjacent bands.”
The Enterprise Wireless Alliance joined commenters saying the FCC shouldn’t increase the geographic size of the PALs offered for auction by the FCC. The alliance said the FCC shouldn’t “over-correct in fine-tuning the novel regulatory structure adopted” for the band. “The FCC should resist efforts to convert it into a band in which only the major nationwide carriers will be likely to secure opportunities,” EWA said.
Ruckus, which has a product line of equipment for the band, called on the FCC to finalize rules as quickly as possible. The FCC shouldn't approve rule changes that would “limit access to the Priority Access or General Authorized Access tiers to only certain types of users, or reduce the fundamental opportunity for access at either tier,” Ruckus said. “If enacted, such changes would undermine the global leadership that the United States has shown with CBRS in the introduction of a highly innovative three-tiered sharing framework, supporting a flexible allocation of spectrum for both exclusive and permissive access and supporting a wide variety of use cases.”
Comcast said the FCC should license the PALs on a countywide basis and said the license terms should be extended from three to seven years. But Comcast also raised interference concerns. “Proposals to relax emission rules or raise power limits could increase interference with adjacent-band operations and disrupt the balance among various users of the 3.5 GHz Band,” Comcast said. The band offers great promise, Comcast said. “Comcast already is participating and investing meaningfully in the 3.5 GHz Band,” the company said. “Comcast has been a full member of the CBRS Alliance since October 2016 and has assembled a dedicated technical team to participate in the group and contribute to its work.”
Charter encouraged the FCC to adopt “licensing areas no larger than counties” and impose performance requirements “if it extends PAL license terms and adopts a renewal expectancy.” Charter also was enthusiastic about the band. “The 3.5 GHz Band is an important component of Charter’s wireless strategy as the company is in the process of transitioning its wireless network from a nomadic WiFi network to one that supports full mobility by combining its existing WiFi assets with multiple 4G and 5G access technologies to deliver seamless connectivity for consumers,” the company said. “Charter views the 3.5 GHz Band as a critical element of this.”
Microsoft sought six-year license terms for the PALs but said the FCC should mostly leave the Obama era rules as they are. “In adopting census tracts, the Commission recognized the importance of increased flexibility, efficiency and targeted deployment,” Microsoft said. “The proposal to increase the size of the geographic license area would undermine the Commission’s goals and the public interest. Further, there have been no changes in the technology or the market in the 2.5 years since the CBRS rules were adopted that warrant an increase in the defined license area.”
“Larger license areas, long-term licenses and non-competitive renewal would convert the CBRS band from a flexible, small cell band that facilitates the widest possible variety of users and use cases, including rural broadband customized local enterprise solutions, into yet another band designed for the sole use and benefit of three or four national mobile carriers,” said New America‘s Open Technology Institute and Public Knowledge in joint comments. The Rural Wireless Association said the proposed changes aren’t needed to encourage investment in the band.