Industry Sees Improvement in FCC’s 3.5 GHz Framework, Seeks More Revisions

The FCC should move ahead with its plan for a three-tiered framework for managing users on the 3.5 GHz band, Verizon Communications said in a filing Friday. The FCC has proposed managing spectrum sharing on the band through the Spectrum Access System. The Priority Access Licenses-based framework would give incumbent government users the highest tier of access, followed by a tier for priority access licensees and a lower tier for general access users.

A successful sharing plan “is most likely to emerge if the Commission pursues an incremental approach under which it dedicates part of the band to the ambitious Multi-Tier Framework, while also reserving some of the spectrum for a different regime (a ‘Transitional Framework') that supports shorter-term deployment of existing technologies,” Verizon said in its filing. A transitional framework sub-band would help the FCC “kick-start the investment in the infrastructure, device ecosystem, and SAS database management techniques needed for the ultimate success of the Multi-Tier Framework,” Verizon said. The telco said it knows the SAS framework will “inevitably create substantial uncertainty” because it’s a new and complicated plan and will require new control and security technologies to manage general access devices’ emissions (http://bit.ly/1d1bpUI).

AT&T said it generally supports the proposed framework, saying it believes it’s important for the FCC to continue pursuing an expansion of services eligible for the priority access tier “to facilitate rapid deployment by commercial operators and others who require quality of service.” The FCC needs to give more clarity to its plan for the priority access tier because “potential licensees might be reluctant to incur the substantial capital investments needed to deploy small cell systems and other innovative broadband facilities without more certainty that their investments would not be stranded,” AT&T said. The general access tier should be unlicensed, because making it “licensed by rule” would “extend a narrow exception to statutory licensing authority much farther than Congress intended,” the telco said (http://bit.ly/1kk3BjM).

T-Mobile US said it believes the FCC’s revised framework is an improvement but also wants the FCC to re-examine the two-tiered License Shared Access approach for the band. “Even with the modifications proposed in the Revised Framework, the two-tiered LSA approach continues to be the least complex and most effective way to promote full deployment of the 3.5 GHz Band,” the carrier said. If the FCC decides to move ahead with the three-tiered framework, it should make “several changes that will enhance the utility of the spectrum and make the Commission’s administration of the band less complex,” T-Mobile said. The FCC should make priority access licenses available on a multiyear basis, with multiyear licensees subject to buildout requirements, the carrier said. The commission should also make a consistent 60 MHz available for priority access use and ensure general access users only get access when it’s unassigned or affirmatively unused, T-Mobile said. SAS should be limited to identifying spectrum availability for priority and general access users, rather than also being able to modify the technical or operational parameters of a priority access licensee’s network, the carrier said. The FCC should adopt rules requiring full utilization of the 3.5 GHz band and should include the entire band on its revised framework, T-Mobile said. The commission should not limit priority access licensees’ base stations to a 24 dBm transmit power limit, and should give general access users interference protection “within the confines of their facilities,” T-Mobile said (http://bit.ly/18dIXlb).

Google believes the revised framework “provides a promising foundation for diverse service opportunities in the 3.5 GHz band,” but also wants to see improvements. The FCC should set rules for commercial use quickly, rather than waiting for answers to all pending questions, Google said. The commission should implement a licensing model for the band that takes “full advantage” of SAS’s capabilities and resolve technical issues “in a manner that maximizes opportunities for innovation, minimizes the costs of licensing and deployment, and protects incumbent operations,” Google said (http://bit.ly/II7d2V). Microsoft said the FCC should reserve at least 50 MHz on the band for general access users “and allow GAA devices to operate on an unlicensed basis, providing GAA with the flexibility that is necessary to develop and refine new wireless technology.” The FCC should also “fairly structure” the priority access licensing system, Microsoft said (http://bit.ly/1aGMBPf).

The Telecommunications Industry Association said it’s “broadly supportive” of the FCC’s revised framework, but also wants the FCC to “actively consider” the LSA and Authorized Shared Access approaches and “not act prematurely in a manner that would foreclose their eventual adoption.” The Priority Access Licenses proposal “could enhance the 3.5 GHz Band’s attractiveness to a broad range of users with QoS requirements, including mobile operators, which in turn will help drive the scale necessary for the development of an end-to-end ecosystem,” TIA said. The framework also needs more clarification “regarding the extent to which a PAL approach would permit underutilized spectrum to be employed for unlicensed uses,” the group said. TIA said it believes the FCC “should permit long term evolution of the 3.5 GHz band and not depend solely on current technology assumptions, especially assumptions about future technology or regarding potential unlicensed use” (http://bit.ly/IPyr83). CEA said it supports the revised framework’s three-tier model and wants the FCC to expand access to the priority access tier to “any prospective licensee who meets the basic qualifications for holding Commission licenses.” The commission should also give general access users access to unused priority access spectrum, CEA said (http://bit.ly/1jvivpF).

PCIA and its subsidiary The HetNet Forum said it wants the FCC to expand the priority access tier to “a broader class of users and exercise caution in deciding which geographic data-set to utilize.” PCIA also encouraged the commission to “adopt flexible, technology-neutral rules to give innovators the opportunity to determine the best applications and equipment for this band” (http://bit.ly/II1EBl). The Wireless Internet Service Providers Association supports many of the framework’s proposals and concepts, “but to truly optimize the public interest benefits that can be achieved, the focus of this proceeding must be expanded to promote the deployment of higher-power operations in rural areas.” WISPA “urges the Commission to adopt rules that enable the twin benefits of higher power operations in rural areas and small cells in non-rural areas,” and wants the FCC to use census tracts as its baseline geographic licensing units. If the FCC decides to combine the 3550-3650 MHz band with the 3650-3700 MHz band, “existing 3650-3700 MHz licensees must be assigned Priority Access status to protect their existing operations,” WISPA said. “Existing licensees should have five years from launch of the SAS to transition to the new rules” (http://bit.ly/1gd8mOR).