The Competitive Carriers Association (CCA) is asking the FCC to consider adding a new category of devices in the 3.5 GHz Citizens Broadband Radio Service (CBRS) that would operate at a higher power than what’s currently allowed.
The CCA proposal calls for a Category C of radios that operate at a maximum equivalent isotropically radiated power (EIRP) of 62 dBm/10 MHz and user equipment that operates at 26 dBm. Similar to other proposals made to the FCC, this one would apply to both the General Authority Access (GAA) unlicensed users as well as those operating under Priority Access Licenses (PALs).
Technically, the proposals are focused on Citizens Broadband Radio Service Devices, or CBSDs, which are the infrastructure/radios, such as small cells and pico cells, that are coordinated by the Spectrum Access System (SAS) administrators.
CCA, which represents many of the regional and smaller wireless operators in the U.S., said rules for higher power devices in the CBRS band would increase the number of use cases supported by CBRS, including 5G macro cells, while continuing to protect incumbents in the band.
During a speech at the American Enterprise Institute last month, FCC Commissioner Brendan Carr said he’s all for the FCC seeking comment this year on increasing the power levels for CBRS operations in the 3.5 GHz band. Increasing the power levels would help align the U.S. band with international standards and create efficiencies for mid-band 5G builds in the U.S. that could span the 3.45 GHz to C-band spectrum ranges, he said.
As of now, the FCC has two classes of CBRS access points: Category A with a maximum EIRP of 30 dBm/10 MHz and; and Category B with a maximum EIRP of 47 dBm/10 MHz.
CCA told the commission that due to the relatively low EIRP of CBRS compared to other bands, if CBRS is deployed at macro cell locations, there will be a coverage gap between CBRS devices and existing mid- and low-band licensed bands, including the C-band. Power limits in CBRS are 25-28 dB lower than the power allowed in the adjacent bands, the organization said.
AT&T has been an early advocate for allowing a higher power Category C for CBRS. Dish Network, the second highest bidder in the CBRS PAL auction after Verizon, also is making the case for higher power levels, saying it would enhance the utility of adjacent bands as well.
Dish has even proposed a new Category D, where a SAS could authorize devices at power levels up to 72 dBm/10 MHz.
Dish also told the commission that at various stages of the commission’s efforts to write CBRS rules, parties such as CTIA, Federated Wireless, Google, Nokia, Qualcomm, T-Mobile and Verizon have argued the benefits of higher power for CBRS.
However, in more recent filings, T-Mobile has criticized Dish’s proposals for higher power in CBRS, saying there’s no basis for changing the CBRS rules, which were adopted, as is, to protect the operations of the Department of Defense (DoD).
What about the OnGo Alliance?
The OnGo Alliance represents a lot of different companies in CBRS and isn’t likely to take a position on whether higher power levels are good or bad. However, OnGo Alliance President Dave Wright said if the commission is going to revisit the issue of higher power in the band, they really ought to make it part of a more comprehensive review of the CBRS rules.
There’s now almost two years of commercial deployment in the band, and given what the FCC, DoD and National Telecommunications & Information Administration (NTIA) are pursuing for the 3450-3550 MHz band, with much higher power levels and significantly less restrictions, “we would like to have a conversation about the federal incumbent protection requirements in CBBRS,” he told Fierce. For example, they’ve been extremely effective, but are they being overly cautious?
“We feel like if the commission is going to, to a certain extent, open Pandora’s Box on revisiting rules, they ought not just look at the higher power EIRP,” but also look at protection requirements, incumbent informant capability (IIC) and probably a few other things at the same time, he said. This could be accomplished through something like a Public Notice or Notice of Inquiry.