CBRS

T-Mobile and AT&T countered Dish Network arguments on FCC rule changes for a 3.45 GHz auction (see 2103090034), aligning them more closely with citizens broadband radio service rules. Filings were posted Thursday in docket 19-348. Others also made arguments before Wednesday’s sunshine notice. T-Mobile cited “DISH’s history of enriching itself while delaying the deployment of spectrum and services.” Dish proposes changes “that would limit competition in the auction for that spectrum and … relax the proposed build out requirements in a way that would delay deployment,” T-Mobile said. The proposal “would enable DISH to acquire the spectrum at artificially depressed prices without any legitimate justification or demonstrated ability to put it to prompt use,” AT&T said. AT&T supported Dish arguments in favor of a “coherent spectrum-aggregation policy,” saying “every provider needs nationwide mid-band spectrum in large contiguous blocks to compete effectively.” Dish didn’t comment. OnGo Alliance representatives raised concerns about interference for CBRS band users, in calls with aides to acting Chairwoman Jessica Rosenworcel and Commissioner Nathan Simington. They discussed problems for CBRS environmental sensing capability providers from “uncoordinated” 3.45 GHz operations and the need for “coordination rules,” the group said. ARRL, which represents amateur radio operators, urged the FCC to allow amateurs to continue using 3.3-3.5 GHz, in calls with commissioner aides and staff from the Wireless Bureau, Office of Engineering and Technology and Office of Economics and Analytics. “Amateurs have applied their technical expertise -- much of it acquired through self-training -- to use the bits and pieces of spectrum in the 3400 MHz band that are not used by the primary operators,” the group said. Ericsson urged rethinking the proposed two-step out-of-band emission limit, in calls with Office of Engineering and Technology and Wireless Bureau staff. “It would force the development of unique, U.S.-only products for the 3.45 GHz band, and would preclude use of globally harmonized … base station equipment,” the company said. “Extending elements of the CBRS framework is the best way to make the 3.45-3.55 GHz band available to a wider variety of users and use cases,” the Open Technology Institute at New America told Rosenworcel aides.

Executives defended Verizon’s decision to go big in the C-band auction during an investor day presentation Wednesday. They pegged the total buy at $52.9 billion, including clearing costs. Verizon has been trying to add midband to counter T-Mobile, with its extensive 2.5 GHz holdings (see 2102250046). AT&T, the second-biggest bidder, has an analyst day Friday.

Citizens broadband radio service band use is accelerating, and Verizon is using the band in 70 metropolitan areas, RootMetrics reported Thursday, detecting no use by AT&T or T-Mobile. “CBRS spectrum will play an important role in the mobile network marketplace, boosting capacity for both 4G LTE and 5G networks in highly populated areas,” RootMetrics said. Main uses are for wireless capacity in urban markets, rural fixed broadband and private wireless networks, the report said.

The Dynamic Spectrum Alliance wants changes to draft 3.45 GHz auction rules that stress the importance of sharing, similar to those for the citizens broadband radio service band. CTIA urged the FCC to adopt the draft order and NPRM, with flexible-use licensees and "standard-power commercial use of the band.” Lobbying continued, with a vote scheduled for March 17 (see 2103090034). Filings were posted Wednesday in docket 19-348. “Adopt rules similar to the C-Band rules,” DSA said, suggesting as language to be added: “Nevertheless, we recognize the value of frameworks that foster innovation and opportunistic use, such as the CBRS rules, and we therefore commit to finding opportunities to adopt the CBRS framework elsewhere in the 3 GHz band.” The FCC proposes “an effective coordination regime modeled after the AWS-3 framework to facilitate coordination between new flexible-use licensees and incumbent federal operations, and it correctly avoids adding unnecessary complexity to 5G buildout by declining, for example, to authorize a use-or-share framework,” said CTIA and representatives from AT&T, T-Mobile, UScellular and Verizon, in calls with aides to all four commissioners. CTIA also sought tweaks. The association said the proposed two-step out-of-band emissions limit “would be unique to the 3.45 GHz band and to the United States, thereby requiring development of a radio specific to this band and risking slowing production and deployment.” CTIA urged instead "a -13dBm/MHz OOBE limit at the channel edge, which has proven successful in promoting deployment while protecting adjacent incumbents.” Executives from Comcast's NBCUniversal and Nexstar said the order correctly gives the five incumbent S-band digital Doppler weather radars “180 days to transition to the 2.9-3.0 GHz band after grant of new flexible-use Licenses,” which allows time “to procure, install, and test the new equipment necessary.”

Lobbying intensified before an expected Wednesday sunshine notice on what model FCC members should approve March 17 for auctioning frequencies at 3.45 GHz, filings showed. Cable and satellite stakeholders were among those seeking changes to the auction draft rules so that bidding resembles that used in bidding for citizens broadband radio service airwaves. Others seek for the regulator to stick with the C-band auction approach, which is what the original draft that recently circulated would do.

The FCC Wireless Bureau and Office of Engineering and Technology certified Key Bridge Wireless Tuesday as a spectrum access system administrator in the citizens broadband radio service band, the sixth SAS approved in the 3.5 GHz band. “We are making history with this innovative band,” said acting Chairwoman Jessica Rosenworcel.

The Wireless ISP Association asked the FCC to auction the upper 40 MHz of the 3.45 GHz band by county, rather than by partial economic area, in calls with aides to Commissioner Geoffrey Starks and Nathan Simington. Other groups also sought smaller license sizes (see 2103040061). WISPA would leave the remaining 60 GHz to be sold as PEAs. “Using county-based licenses for the upper 40-megahertz will promote greater participation in the auction by smaller providers interested in obtaining licensed mid-band spectrum for rural coverage,” WISPA said. T-Mobile urged 10 MHz rather than 20 MHz licenses and sought a simplified out-of-band emissions (OOBE) mask. Adopting citizens broadband radio service rules wouldn’t work, the carrier said. “While CBRS-style rules support lower-power operations and may have been appropriate for the 3.5 GHz band because of the need to protect incumbent radars and to address coexistence concerns, those circumstances do not apply to the 3.45 GHz band,” T-Mobile said: It wants a 40 MHz limit on buys by any bidder. New America's Open Technology Institute asked a Starks aide to model rules on those for CBRS: “CBRS is already proving that an integrated band with both licensed spectrum and shared [general authorized access], operating under common technical rules, promotes innovation, competition and more localized deployments by a wide variety of ISPs, enterprise and other institutions.” The “unique issues that led to lower power levels in the CBRS band are not present here, and allowing power levels comparable to C-band will maximize the efficient use of the 3.45-3.55 GHz band,” the Competitive Carriers Association said in a call with an aide to acting FCC Chairwoman Jessica Rosenworcel. Proposed aggregation limits “will invite greater participation in the auction and promote competition by ensuring at least three licensees in each market,” CCA said. Lockheed Martin raised interference concerns for its three primary radar manufacturing and test facilities in New York and New Jersey. Filings were posted Monday in docket 19-348.

Stakeholders suggested changes to rules for a 3.45 GHz auction, in recent calls with eighth-floor FCC staff. Public Knowledge asked the agency to allow shared use of spectrum not sold in the auction. Rather than selling the licenses in a future auction, the commission should add them to the citizens broadband radio service database and “permit general authorized access (GAA) pursuant to the CBRS service rules,” PK said in calls with aides to Commissioners Geoffrey Starks, Brendan Carr and Nathan Simington. “Extend the CBRS framework on a more permanent basis into the 3.45-3.55 GHz band,” the group said: “Doing this will ensure valuable spectrum will be used without leaving GAA dependent networks stranded when licensees deploy.” Rationalize the CBRS rules with rules for 3.45 GHz, Dish Network urged: “Such an effort could provide the Commission with a win-win outcome that raises revenue for the U.S. Treasury … while preserving the investment-backed plans of the many entities that successfully participated in the CBRS auction." Offer county-sized, 10-MHz licenses, consistent with the CBRS auction, Southern Linc asked a Carr aide and staff from the Wireless Bureau, Office of Economics and Analytics and Office of Engineering and Technology. “In addition to nationwide, regional and rural service providers, the licensing framework for the CBRS band drew participation from electric utilities and other private network operators with a pressing need for spectrum to support operations that play a crucial role in the US economy,” Southern Linc said. Filings were posted Friday in docket 19-348. The FCC is unlikely to backtrack from acting Chairwoman Jessica Rosenworcel’s approach on the auction (see 2102240063), Cowen’s Paul Gallant told investors Friday. “Although the agency is currently split 2-2, we doubt Chairwoman Rosenworcel would have circulated it unless it was going to be adopted,” he said: “It would set C Band-like rules rather than CBRS rules that helped Comcast and Charter win 3.5 GHz spectrum last year.”

Google, NCTA and 20 others urged leaders of the House and Senate Commerce committees Wednesday to address “current estimated costs to clear the 3.45 GHz band of federal users,” which “could jeopardize” FCC “ability to conduct a successful auction and meet its obligation to ensure that a wide variety of applicants have access to spectrum.” Commissioners vote March 17 on beginning an auction for early October (see 2102230065). NTIA in January estimated relocation costs “at more than $13.4 billion, meaning that the auction reserve price that bidders would have to meet in order for a successful auction would be nearly $15 billion, likely putting licenses out of reach for all but the three largest nationwide wireless operators,” stakeholders also including Comcast, Hewlett Packard Enterprise, Public Knowledge, the Rural Wireless Association and Wireless ISP Association said in a letter to Senate Commerce Chair Maria Cantwell, D-Wash.; ranking member Roger Wicker, R-Miss.; House Commerce Chairman Frank Pallone, D-N.J.; and ranking member Cathy McMorris Rodgers, R-Wash. “Wireless providers’ large financial commitments in the recent C-band auction and related build-out obligations make it all the more appropriate to encourage other sources of capital in a second mid-band spectrum auction in the same year.” Congress “should encourage the FCC to consider licensing policies akin to those adopted in the [citizens broadband radio service] CBRS band that could increase competition, lower costs for prospective new entrants, and better ensure that the benefits of 5G are enjoyed by all consumers,” the entities said. They want lawmakers to “work closely with NTIA, affected federal spectrum users, and the FCC to consider ways to refine and reduce the federal government’s relocation cost estimate.”

Rivada Networks withdrew an application at the FCC to be a spectrum access system administrator and environmental sensing capability operator in the citizens broadband radio service band, said a filing posted Friday in docket 15-319.