Industry Groups Tell FCC to Leave CBRS Rules Unchanged
Wednesday, January 17, 2018 | Comments

Several mission-critical communications entities filed comments with the FCC rejecting most proposed changes to 3.5 GHz Citizens Broadband Radio Service (CBRS) rules.

Last year, the FCC requested comment on changes to the rules governing the second service tier, known as priority access licenses (PAL), of the band’s three-tier framework. Current PAL rules are helpful to spectrum-strapped critical infrastructure industry (CII) entities, while large carriers had requested changes that would benefit them.

The FCC’s proposed changes would include longer license terms with the possibility of renewal, larger geographic license areas, and modifications to the rules governing license auctions, secondary market transactions and certain technical criteria. The FCC proposed other changes it said would facilitate the implementation of U.S. 5G networks in this band, the FCC said last October.

The telecommunications subcommittee of the American Petroleum Institute (API) and the Regulatory and Technology and Technology Committee of the Energy Telecommunications and Electrical Association (ENTELEC) filed joint comments that said several proposed changes that, if adopted, will significantly reduce the utility of the CBRS band for CII companies.

API and ENTELEC said the acronym adopted by the FCC confirms that the rules were focused on “citizens,” not large carriers. The groups said the proposed changes would make the CBRS band another primary spectrum resource that will be purchased by large telecommunications carriers.

Maintaining small, licensed geographic territories; auctioning smaller blocks of spectrum; and retaining a significant portion of spectrum for general access licensees will all enable CII entities to compete with large carriers for valuable broadband spectrum. The groups said the FCC had correctly addressed the cost barrier of licensed access in its current rulemaking stance for CBRS by limiting the geographical limits to census tract areas more in line with private holdings that are more efficient for CII operations.

The Enterprise Wireless Alliance (EWA) agreed with API and ENTELEC and said the FCC should resist efforts to convert 3.5 GHz into a band in which only the major nationwide carriers will be likely to secure opportunities.

To that end, the Utilities Technology Council (UTC) specifically opposed extending the term of PALs to 10 years from three years and expanding the size of the geographic area of PALs to partial economic areas (PEAs), arguing in its comments that extending the term and expanding the geographic areas of PALs will make it difficult for smaller entities such as utilities to afford to acquire PALs.

For the same reason, UTC said the FCC should avoid auctioning PALs and specifically should not auction PALs in rural areas where there is only one applicant. UTC would support partitioning and disaggregating licenses, particularly if the commission decides to adopt longer license terms and larger geographic areas for PALs.

UTC also believes that allowing bidders to select frequencies of operation would make inefficient use of the band. Instead, UTC supports continuing to require spectrum access system (SAS) administrators to assign the same channels to licensees that hold PALs in contiguous geographic areas, as well as to require them to assign contiguous channels in areas where the same licensee holds multiple frequencies.

Finally, UTC questioned the need to change the emission limits to accommodate wider bandwidth operations. If the commission relaxes the limits, UTC urges the FCC to require PALs to comply with more stringent emission limits near the 3.65 –3.7 GHz band so that those incumbent grandfathered wireless systems in that part of the 3.5 GHz band are protected from interference at least during the extent of the transition period.

Motorola Solutions and Southern Linc also agreed, saying any revised licensing framework for the CBRS should preserve access opportunities for deploying localized, private broadband networks through the continued use of smaller-sized service areas for PALs.

“The current CBRS licensing framework will, without any further change, fully accommodate and enable the deployment of new technologies and services that are still being developed — such as 5G and other next-generation technologies — alongside this variety of current and potential use cases,” Southern Linc said in its comments. “Accordingly, there is no need for the commission to ‘pick winners and losers’ by adopting new rules intended to promote a single technology and use case while effectively dissuading others.”

The New York City Mayor’s Office of the Chief Technology Officer filed comments stating that the current framework of three-year licenses covering census tracts will most effectively spur investment in 5G networks while encouraging universal access to those advanced services. “The city does not believe the commission’s proposals, especially regarding increasing the geographic areas of PALs will achieve the desired result,” the comments said. “The city asks that the commission strengthen its current PAL regime by instituting strong performance requirements and encouraging a robust secondary market, while maintaining the current three-year licenses at the census tract level.”

Union Pacific was divided, asking the FCC to implement a longer, renewable PAL license term along with reasonable performance requirements but said census tracts are the appropriate geographic license area. Union Pacific said the FCC should allow secondary market transactions to help ensure diverse, efficient and intensive use of the band, although it cautioned the FCC from relying on the secondary market as a replacement for smaller geographic license areas and robust competition. The railroad company also said the FCC should eliminate the requirement for public disclosure of device registration information to minimize security risks and protect competition.

More details on the 3.5 GHz band is available in “The Potential of CBRS for CII” in the September 2017 print issue of MissionCritical Communications.

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