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'Far-fetched Proposal'

AT&T Gets Little Support for Proposed Remaking of CBRS Band

AT&T and CTIA urged that the FCC rethink citizens broadband radio service rules and questioned the band's success, filing reply comments to an August NPRM (see 2411070032). But most commenters said the FCC should only tweak the band. CBRS advocates largely defended the model as a sharing success story. Interest in the proceeding was strong, with more than two dozen reply comments posted as of Friday.

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AT&T kicked off the discussion about making major CBRS revisions in October, suggesting the current CBRS allocation at 3.55-3.7 GHz should be expanded and relocated to 3.1-3.3 GHz (see 2410090037). The former CBRS band would then be auctioned for licensed, full-power use.

The world has changed since the FCC developed the CBRS rules, AT&T noted in comments posted Friday in docket 17-258. “Deemed at the time an unlikely candidate for commercial mobile deployments, the 3.5 GHz band seemed like a low-risk candidate for experimentation with a novel three-tiered dynamic sharing framework,” AT&T said: “Mid-band spectrum between 2.5 GHz and 6 GHz, long overlooked, soon came to be understood as foundational building blocks for 5G deployments.” CBRS, meanwhile, “has underperformed relative to expectations.”

CTIA said CBRS is no substitute for the full-power licensed spectrum carriers need. “Any action by the Commission should account for the market realities regarding use of the CBRS band,” the group said. The biggest users of CBRS spectrum are wireless ISPs, which were already using part of the band before the rules were finalized, and traditional wireless carriers “to augment capacity for wide-area deployments,” CTIA said: These deployments “are no substitute for licensed, full-power spectrum.” The record shows the band “has yet to realize the vision of small cell deployments called for by some commenters.”

But T-Mobile said the FCC should make major changes only after developing “a full technical record” on the extent and character of CBRS deployments today. “The Commission cannot reasonably evaluate proposed changes that would fundamentally alter the character of the band without engaging in thorough consideration of technical data and ensuring all stakeholders have a meaningful opportunity to debate that data in the record.”

Verizon supported higher CBRS power limits and relaxed out-of-band emissions limits but opposed other changes proposed in the NPRM. As such, Verizon appeared lukewarm to AT&T’s calls for sweeping changes. “Comments calling for a wholesale reexamination of the 3 GHz band offer far-reaching concepts but should not slow down the real and tangible progress the Commission can make here in response to the NPRM,” the carrier said.

The Wireless ISP Association supported only “targeted, modest [rules] changes,” including higher power levels for end-use devices and relaxed OOBE limits. The FCC should reject AT&T’s “far-fetched proposal to re-configure the band … through an expensive and unnecessary incentive auction followed by a disruptive equipment change-out.”

Major carriers want to “transform the band into something that the Commission never intended, or seek windfall profits from their Priority Access Licenses by transforming them into conventional large-cell mobile licenses,” WISPA said: Higher power levels may be useful to carriers but not for “other use cases that can operate at lower power to provide targeted capacity small cells, or to serve their rural community, private network or IoT.”

The Open Technology Institute at New America told the FCC it should resist the push to remake the band. “The record is clear that while some mobile industry commenters seek to fundamentally change the purpose of CBRS by authorizing very high-power use tailored to their business model, the vast majority of CBRS users strongly oppose higher power limits,” OTI said. Opposition is especially strong from smaller users that rely on general authorized access spectrum “and who have, according to NTIA, deployed by far the vast majority of [CBRS devices] in reliance on the Commission’s 2018 rules.”

The OnGo Alliance, which promotes CBRS use, said AT&T’s proposal is “well beyond the scope of the current NPRM, and therefore should not be considered in this proceeding.” Failure to dismiss the proposal “could create significant market uncertainty for the expanding CBRS ecosystem,” the alliance said. It also noted that the lower 3 GHz band is already under study, as the national spectrum strategy directs, and through the DOD-run Partnering to Advance Trusted and Holistic Spectrum Solutions process.

“CBRS deployments show that demand for the flexibility CBRS enables is increasing, as operators rely on CBRS to provide localized capacity and tailored deployments,” NCTA said. Making sweeping changes to the broader 3 GHz band “would strand billions of dollars of investment … and harm consumers, undermining an effective spectrum sharing framework that has fostered innovation and competition.”

Federated Wireless supported rules tweaks that reflect changes since the rules were approved but called CBRS a success. “It is clear from the record that the Commission’s innovative sharing and licensing framework has succeeded in achieving its two primary objectives, namely protecting incumbent users while supporting the introduction and growth of a wide range of diverse users, use cases and business models,” Federated said: Growth has come from “both consumer-oriented broadband services” and “private wireless networks supporting a wide range of industrial, municipal, educational, and mission-critical use cases.”