It has long been observed that politics makes strange bedfellows, and a recent FCC filing shows that trend continues. In this case, Google (NASDAQ:GOOG), AT&T (NYSE:T) and Verizon (NYSE:VZ) partnered to express their views to the FCC regarding commercial operations in the 3.5 GHz band, which is envisioned for use in small cell deployments.
According to the ex parte filing, submitted on Google letterhead, on March 13, representatives of the three companies met with members of the FCC's Wireless Telecommunications Bureau, Office of Engineering and Technology and Public Safety & Homeland Security Bureau. At issue was the FCC's proposal to open the 3550-3650 MHz band for sharing between government and commercial users.
Rival telcos AT&T and Verizon, as well as Internet giant Google, whose partnership with telcos is perhaps best characterized as one of coopetition, joined to support the three-tiered sharing framework proposed by the President's Council of Advisors on Science and Technology (PCAST) for the 3.5 GHz band.
Notably, AT&T's support for the 3.5 GHz spectrum-sharing scheme laid out in the July 2012 PCAST report represents a significant departure from the telco's original reaction to the plan.
In August 2012, Joan Marsh, AT&T's vice president of federal regulatory, wrote on the company's Public Policy Blog that PCAST had failed to show how or why its recommended model of shared, secondary, unlicensed access over a small cell network would attract capital for network rollouts. "A shared access system with limited licensing rights, no renewal expectancies and the prospect of service pre-emption by the primary government user creates a challenging environment for the commitment of investment dollars," she wrote.
In their recent FCC meeting, Google, AT&T and Verizon also discussed ways, unspecified in the ex parte filing, that the FCC might structure the 3.5 GHz spectrum-sharing framework to enable experimentation and substantial use by general authorized access (GAA) devices for the Citizens Broadband Service. However, the companies said this must be done "while also providing sufficient certainty to encourage licensed operators to invest quickly in the band."
The trio also said they back broad eligibility in the priority access tier; use of a spectrum access system to manage interference protection; and lightweight auction mechanisms where necessary to resolve mutually exclusive requests for priority access reservations.
As outlined in a December 2012 Notice of Proposed Rulemaking (NPRM), the FCC's proposed 3.5 GHz Citizens Broadband Service will be covered by a three-tier authorization mechanism and managed by a geolocation-enabled dynamic spectrum access database modeled upon existing TV white spaces databases. The three proposed tiers of operation are: incumbent access (federal and grandfathered licensed FSS 3.5 GHz band users), priority access (hospitals, utilities and public-safety entities) and general authorized access (the general public).
In August 2013, Google and AT&T also submitted a joint letter to the FCC regarding the 3.5 GHz band, in which they argued that commercial operations should not be relegated to the third tier. At the time, they argued the commission "should establish broad eligibility for the secondary exclusive tier," opening it up to "any applicant that commits to a substantial service requirement."
That argument was echoed in the most recent filing by the companies and Verizon.
- see this FCC filing
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FCC: 3.5 GHz will become the small cell band
AT&T shreds PCAST's shared spectrum vision