AT&T (NYSE: T) wants to make sure the FCC knows that it is not happy with a proposal for a Priority Access License, or PALs, scheme as outlined in an FCC document on the 3.5 GHz band plan.
AT&T representatives have been meeting with members of FCC commissioners' staff to discuss the 3.5 MHz band and the importance of making changes as outlined by CTIA in a Petition for Reconsideration of the 3.5 GHz licensing framework. AT&T supports CTIA's request for changes that are "necessary to increase interest and investment in the band," including modification to the proposed PAL licensing terms and renewal rules and modification of what's known as the "N-1" auction process.
Joan Marsh, VP at AT&T, pointed out in a blog post earlier this week that the PAL approach as outlined has been broadly rejected by wireless operators for several reasons, including the fact that PAL licenses will come with a "ridiculously short" three-year license term with no mechanism for renewal.
"Wireless operators seeking to provide new QoS-driven services in the band will be disproportionately impacted, as will prospective users in rural areas, where demand may be even more limited but where there is a clear need for the types of high-quality services that a PAL licensee can provide," she wrote. "In addition, the development of a 3.5 GHz ecosystem will likely be hampered if potential PAL users are discouraged from participation in the band, particularly as the same equipment will likely be used for both general access and PAL use. Active PAL participation can only enhance development and deployment efforts."
Probably even more troubling, she added, is "the fact that some now look at this newly-minted sharing framework – which is still totally unproven from a business, technical and data security perspective – as a template for other bands, including the high GHz bands being considered as suitable for 5G use. Many have specifically advocated that the 3.5 GHz rules be adopted for 28 GHz or 37-39 GHz, a position which most wireless operators also oppose."
Last July, CTIA submitted a Petition for Reconsideration for the FCC's order on the proposed 3.5 GHz band rules, urging the commission to reconsider policies around PALs and out-of-band emission (OOBE) limits. CTIA said the power limits should be increased to allow for meaningful indoor and outdoor coverage.
Google (NASDAQ: GOOG) also weighed in on the OOBE limits, supporting CTIA's request and noting that Google's own propagation testing indicates the OOBE requirements can be relaxed as proposed by CTIA without material increased risk of harmful interference.
For more:
- see this AT&T blog post and this filing
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