WISPA objects to 3.5 GHz rule changes proposed by CTIA, T-Mobile

rural (Pixabay)
WISPs want to use the 3.5 GHz band for rural broadband, among other uses.

Calling proposals to change the rules associated with the 3.5 GHz Citizens Broadband Radio Service (CBRS) “ill-conceived,” the Wireless Internet Service Providers Association (WISPA) told the FCC in no uncertain terms that it is not OK with delaying access to the band.

CTIA and T-Mobile in particular have asked the FCC to change the 3.5 GHz rules to make them more attractive to investments by wireless operators. Others, however, including WISPA, Google, Boingo Wireless and Microsoft, have urged the commission to reject major changes to the rules that would upset the three-tier structure or risk delays in commercial rollout.

“It is clear that the proposals from CTIA and T-Mobile would put the CBRS band out of reach for anyone other than large carriers,” said Mark Radabaugh, chairman of WISPA’s FCC Committee, in a release. “Shifting to larger geographic areas for Priority Access Licenses will exacerbate and perpetuate today’s last-mile problem – large mobile carriers will acquire spectrum covering large geographic areas, but only deploy in the portions of those areas where demand and density satisfy their business models. What rural America needs is licensed spectrum that entrepreneurial companies can acquire and deploy in to connect the unconnected.”

WISPA, which represents the interest on hundreds of smaller fixed wireless broadband providers and their vendors, strongly supported the adoption of the CBRS rules, viewing the band as a critical resource for deploying broadband in rural areas where wireline solutions are not cost-effective. And WISPA members have made substantial investments in equipment that can be used in the CBRS band, so they view any changes to the rules as the mobile industry is proposing as undermining their investments.

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CTIA and T-Mobile each have argued in favor of 10-year license terms with a “renewal expectancy,” along with Partial Economics Area (PEA) license areas for Priority Access Licenses (PALs). “Taken together, these proposals would put PALs out of reach for smaller companies that simply cannot afford to compete at auction with large mobile wireless carriers for essentially permanent licenses covering hundreds of thousands of people and thousands of square miles,” WISPA stated in its filing.

WISPA also blasts T-Mobile for “brazenly” making statements about how improving the 3.5 GHz band for licensed use is the best way to encourage investment in the spectrum and for making comparisons to 5G initiatives in other countries, which are “entirely unavailing.” Unlike other countries, in the United States the 3.5 GHz band is shared with earth station licensees and ground-based and shipborne military radar systems, thus necessitating the use of Spectrum Access System (SAS) and Environmental Sensing Capable (ESC) administrators.

“Neither CTIA nor T-Mobile has made the case that changing a licensing system—and evicting all other use cases in the process—is a requirement of 5G,” WISPA said.

“In sum, the petitioners have not and cannot make the case that converting the licensing scheme to a ‘5G-only’ band will promote the public interest,” the group said. “While there may be benefits associated with 5G at some point in the future, that does not mean that the CBRS band should be de facto re-designated to a single-purpose band, and that other use cases and associated consumer benefits should be displaced or ignored.”

CTIA has argued that with 3.5 GHz being the only mid-band spectrum in the pipeline in the U.S., the mobile industry needs a licensing framework that facilitates investment, cements the U.S. lead in 5G and maintains its position as the global leader in wireless.

For its part, T-Mobile has said that designating the entire band for PAL use will not diminish the opportunities for General Authorized Access (GAA) use. The “uncarrier” says that consistent with the current rules, GAA users will still be able to access all 150 megahertz when it is not in use by PAL licensees and will have access to any part of the 3.5 GHz spectrum that is not held by PAL licensees.

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