CCA says county-sized license areas for LMDS would hurt small and rural carriers

With the FCC set to vote on new rules for millimeter wave spectrum on July 14, the Competitive Carriers Association (CCA) and T-Mobile US still have a lot of concerns they want addressed.

CCA and several of its members met with legal advisers to Commissioners Ajit Pai and Mignon Clyburn last month to discuss a list of concerns about Chairman Tom Wheeler's proposal to free up more spectrum for 5G. For one thing, CCA objected to a proposal to change incumbent LMDS license sizes from Basic Trading Areas (BTAs) to counties or Partial Economic Areas (PEAs), which would hurt small and rural carrier licensees especially.

CCA also argued that small carriers facing increased buildout requirements would likely fail to comply and thus lose their licenses. Central Texas Telephone Cooperative (CTTC), for example, currently serves 19 counties within its two BTA licenses and being forced to build out networks in each of those 19 counties is untenable given technological and practical constraints.

CTTC's territory spans 3,200 square miles with fewer than two customers per square mile and therefore it doesn't make sense to install points of presence (POPs) or links per the proposed buildout requirements. "A rural carrier should not be forced to deploy needless infrastructure to keep its license when it has already invested financial and human resources deploying and meeting its expected buildout requirement," CCA said in a recent filing (PDF).

CCA explained that the proposed new license sizes don't make sense from a technological perspective. Even if a rural carrier wanted to deploy a mobile network in a rural, flat county on LMDS spectrum, the necessary technology simply doesn't exist given LMDS spectrum's limited propagation capabilities, the group said. Nationwide carriers may use LMDS spectrum for terrestrial mobile uses, but rural and regional users will likely continue to use LMDS for backhaul and point-to-point services for some time.

C Spire is exploring new equipment and plans to begin testing new technologies within the next few months in the mmWave spectrum based on its current license parameters. Changing the license sizes now would put competitive carriers like C Spire in the position of having to decide between "stranding their investment or keeping their license at an unreasonable cost," the group explained.

With regard to sharing in the 37-37.6 band, CCA called the 37 GHz the "crown jewel" of the proceeding because it represents greenfield opportunity. While all but a modest amount of the 28 and 39 GHz bands are already licensed, the 37 GHz band is not, and is the only spectrum that could be fully auctioned for new services.

CCA argued this spectrum should be licensed for commercial use to achieve the greatest financial and technological value. "The Commission should not use an untested sharing approach in this band if the FCC wants to lead in 5G deployments," it said.

T-Mobile, meanwhile, has noted that licensing a portion of the 64-71 GHz band will drive greater investment in technology development and deployment that will facilitate greater use of unlicensed portions of the band.

Interestingly, on the topic of cybersecurity requirements, CCA told the commission that many competitive carriers simply buy the best network equipment that they can get access to, from the one or two equipment manufacturers willing to create bespoke equipment needed to operate their networks. It's likely small carriers assume security measures are built into their equipment or that they are relying on assertions by an equipment manufacturer to that effect.

Equipment manufacturers in the business of constructing and selling network infrastructure, not carriers, are in the best position to provide security information, according to CCA. "If the Commission wishes to gain insight into the security practices of competitive carriers, they should seek that information from the equipment manufacturers," the group said.

For more:
- see this CCA filing (PDF)

Related articles:
FCC to make 4x more licensed, 'flexible use' spectrum available in Spectrum Frontiers move
T-Mobile: AT&T/EchoStar proposal threatens success of terrestrial use at 28 GHz
AT&T, T-Mobile, Verizon respond to satellite's 28 GHz sharing concerns

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