fightingTwo organizations representing mobile wireless service providers have sent a letter to the FCC with what they called a “compromise proposal” for the planned auction of citizens band radio service (CBRS) licenses in the 3.5 GHz spectrum band.

The compromise CBRS proposal comes from CTIA – The Wireless Association and the Competitive Carriers Association (CCA) and calls for priority access licenses (PALs) to be issued by metropolitan statistical areas (MSAs) in the top 306 cellular market areas (CMAs) and for county-based licenses in the remaining 428 CMAs.

The stakes are high. CBRS spectrum and the many applications it can enable is being debated as everything from a rural broadband savior to a necessary part of a winning 5G strategy. Current plans call for CBRS licenses to be issued on a census tract basis but major wireless carriers have been lobbying for larger license areas.

The Wireless Internet Service Providers Association (WISPA) opposes the CTIA/ CCA proposal. WISPA represents companies that hope to use CBRS spectrum to support fixed wireless service in rural areas. WISPA argues that its members need licenses for small geographic areas and many members would not be able to afford licenses based on larger geographic areas.

CBRS Compromise Proposal
According to CTIA and CCA, the CBRS compromise proposal would reduce more than 74,000 license areas and more than 500,000 licenses to roughly 2,700 license areas and 19,000 total licenses, which would reduce auction complexity.

In their letter to the FCC, CTIA and CCA argued that MSA licenses in larger urban areas will “promote investment across those markets and will largely eliminate the border interference issues posed by census tract licensing in urban areas.”

Outside the major metro areas, the use of county-based licenses would “address interest by many stakeholders for small license sizes for rural deployments, without the administrative burdens that census tract licensing creates.” Licenses for approximately 83% of the U.S. land mass would be auctioned in that manner, according to CTIA and CCA.

WISPA doesn’t agree with the other associations’ assessment.

“With 24 million Americans still unconnected to the digital economy, there is no higher priority at the FCC than finding ways to bridge the digital divide,” said WISPA President Claude Aiken, in a prepared statement. “Fixed wireless technology is the most cost-effective way to make FCC-benchmark broadband service available to unserved consumers, and census tract licenses in the CBRS band are crucial to the future of fixed wireless service in rural America.

“WISPA is thus disappointed that efforts are continuing to shove aside the interests of rural America, take over the ‘innovation band,’ and turn it into a ‘same ol’ thing’ band.”

Larger carriers would likely need to purchase numerous smaller licenses to achieve the coverage they desire, but according to WISPA this should not be a problem. A WISPA letter to the FCC cited CBRS rules that require spectrum access systems (SASs) to assign geographically contiguous PALs held by the same licensee to the same channels in each geographic area, to the extent feasible.

Border Interference?
CTIA and CCA said their solution would “largely eliminate border interference issues posed by census tract licensing in urban areas,” which would require licensees to “severely limit power levels and substantially increase network infrastructure and deployment costs.”

WISPA said concerns about border interference expressed by mobile wireless providers are based on an incorrect interpretation of CBRS band rules.

The PAL licenses that will be auctioned in the CBRS band are for up to 80 MHz of spectrum. Unlike with some previous auctions, plans do not call for moving existing users off the spectrum. The spectrum is already in use for military radar, and a SAS will be used to prevent broadband providers from using the spectrum in exclusion zones near military bases and along coastlines where the spectrum is in use by the military.

Another difference between the CBRS band and some other spectrum bands is that unlicensed users will be able to use any portion of the CBRS band where it is not in use by licensed or incumbent military users. Because of that, “there is no obligation to prevent signals from leaving one’s PAL area,” WISPA argued in its letter.

According to WISPA, [i]f a licensee were to have a [CBRS] device operating near the edge of its licensed PAL area, such that the signal extended outside of the PAL area, the signals from [CBRS devices] whose service contours form the [PAL protection area] would be treated as [unlicensed] users outside of the PAL area.”

WISPA also said the FCC has “made clear that neighboring PAL holders are permitted to enter into private contracts that will be enforced by the SAS.”

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