CBRS Update - December 2017

There has been another delay in the release of the updated 3.5GHz band. This time, a newly proposed change could drastically impair the ability of rural last-mile providers ability to use the 3550-3700MHz band. What is termed as Citizen Band Radio Service (CBRS) could end up in the hands of the Tier-1 carriers if T-Mobile and CTIA get their way.

After two years of rule making and a unanimous reaffirmation in April 2016, a 4-1 vote, the FCC recently adopted a T-Mobile and CTIA NPRM (Notice of Proposed RuleMaking) aimed at changing a number of rules. The FCC document can be found here: http://bit.ly/wisp-cbrs-update-dec2017

Essentially, the FCC is looking to again seek comments on the following: • License Areas - Do away with the current Census Tract areas and adopt larger geographical areas such as Partial Economic Areas (PEAs) and/or Counties. • Secondary Markets - Allow disaggregation (partitioning) of PALs. • Auction of PALs - Allow licensees to bid on specific channels and remove the limit of 4 PALs per license. • License Term - Increasing term from 3 years to 10 years and implement a renewal process based on performance. • SAS Privacy - Require SAS administrators to keep device registration confidential. • Emission Limits - Relax sideband limits to accomodate larger channel sizes. (i.e. 20MHz)

In our opinion, the proposed changes will take what once was a promising “Citizens Band” for small operators to use in Rural America for that costly “last mile” and turn it into an “innovation band” for the carriers to use for their small cell initiatives in urban areas. By increasing term length and expanding the licensed areas, the value of each license will increase dramatically, which would reduce the smaller providers’ ability to afford these licenses.

Please submit, or encourage your trade associations to submit, a comment on this NPRM on behalf of small carriers. These comments are due by 12/28/2017. To submit comments on this please visit https://www.fcc.gov/ecfs/filings.

When submitting, reference “GN Docket No. 17-258” The official posting of this NPRM can be found in the Federal Register here: http://bit.ly/2j13DFY

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