The Wireless Internet Service Providers Association (WISPA) doesn’t like a lot of things about what T-Mobile and CTIA are asking for in proposed 3.5 GHz rule changes, but it really, really doesn’t like T-Mobile’s “ham-handed attempt” to eliminate General Authorized Access (GAA) channels.
WISPA, which represents more than 800 wireless internet service providers, says T-Mobile garnered no support for its attempt to eliminate the GAA channels in the 3550-3700 MHz band and permit Priority Access Licenses (PALs) in the 3650-3700 MHz band. Such a change would enable PAL facilities to cause interference to the 3650-3700 MHz operations that become post-transition GAA, the association says, adding that those commercial operations, which began as far back as 2008, would inevitably be forced off the air as consumers stop receiving reliable service.
T-Mobile and CTIA are pressing the FCC to consider changes to the 3.5 GHz Citizens Broadband Radio Service (CBRS) band, saying circumstances have changed since the commission initiated the proceeding in 2012 and changes are necessary for the U.S. to remain competitive in the race to 5G.
WISPA disagrees. "It is simply disingenuous for T-Mobile to claim that eliminating GAA channels in the entire 3550-3700 MHz band and introducing PALs into a band that the Commission intentionally and rightfully preserved as a ‘no-PAL zone’ is not ‘major,’” WISPA said in its filing with the FCC.
Many of WISPA’s members provide fixed wireless broadband service to rural areas that would otherwise lack broadband access or choice—places traditional mobile carriers tend to avoid due to lack of population and paying customers. WISPA says many of its members have invested significant funds to deploy service in the 3650-3700 MHz band with the expectation that a software upgrade will enable the use of the same equipment throughout the 3550-3700 MHz band. “Thousands of rural Americans are already the beneficiaries of the burgeoning CBRS ecosystem,” the group said.
However, “the damaging effects of T-Mobile’s myopic and destructive proposals—which garnered no record support—are contrary to the public interest and must be rejected from further consideration by this Commission.”
“No other commenter, not even T-Mobile’s mobile carrier competitors, supported T-Mobile’s destructive plan to eliminate GAA channels throughout the 3550-3700 MHz band,” WISPA said. “Verizon, AT&T, and U.S. Cellular each carefully crafted their respective Comments to avoid any discussion of T-Mobile’s proposal. Five trade associations representing the mobile wireless industry—including of course CTIA itself—refused to endorse T-Mobile’s plan to eliminate GAA channels.”
WISPA also said the mobile industry is gunning for a 5G-only kind of use for the band, which initially was dubbed the “innovation band” and was imagined as supporting multiple kinds of services. Indeed, “while the mobile industry is focused on using CBRS for cellular network and 5G deployment, a number of diverse parties noted the benefits that the existing licensing rules will create for other use cases such as urban venues and critical infrastructure industries,” the group said.
For its part, T-Mobile says that claims that its proposal “would eviscerate the GAA tier,” “shut out many small and rural providers” or result in “extremely limited” GAA use are unfounded. “Specifically, GAA users will still be able to access the spectrum when it is not in use by PALs, as is provided for in the current rules, and where spectrum is not purchased, it will be available for GAA operations,” the “uncarrier” said in its reply comments to the FCC.
And CTIA said that claims that CTIA’s proposed changes would somehow upend significant GAA investment made in reliance on the current rules “are unfounded.” The targeted rule changes proposed by CTIA are designed only to increase the incentives for investment in PALs “while in no way affecting GAA users’ access to the CBRS band,” the association said.
“The CTIA proposals do no harm to investors in GAA business models, who will enjoy the same opportunity for access to the 3.5 GHz band as they do under the current rules. Further, the rule changes proposed by CTIA would not change the flexible nature of CBRS, contrary to the claims of some commenters that any such changes will dictate that 3.5 GHz becomes a '5G-only' band. The CBRS would continue to welcome any technology that meets the band’s technical requirements,” CTIA told the FCC.
Editor's Note: Article updated Aug. 10 to reflect WISPA's membership of more than 800 companies, not 70 as previously reported. Seventy is the number of WISPs that filed comments in opposition to the mobile industry proposals.