Google, Other Companies Back CTIA Proposed Changes to Rules for 3.5 GHz Band

The commission approved an order creating the new Citizens Broadband Radio Service (CBRS) in the 3550-3700 MHz band at its April meeting, after years of debate (see 1504170055). The comments were filed in docket 12-354.

Changes sought by SIA restricting power levels in the band “would unnecessarily constrain 3.5 GHz operations, including by reducing the coverage areas of 3.5 GHz small cells,” Verizon said. Instead, the FCC should allow the use of higher power levels in the band to enable the use of “reasonably-sized” small cells, Verizon said. “Contrary to SIA’s assertion, technical rules enabling economically viable 3.5 GHz operations -- including increased power limits -- are fully consistent with protecting earth stations from harmful interference.”

Verizon said it operates multiple earth stations, but views SIA’s objections as premature. The power levels that would be allowed by the FCC are much lower than those used by existing small cell facilities, the carrier said. “Verizon, and others, propose power limit increases that would partially close the size gap so that 3.5 GHz cells would be closer in size to (but still much smaller than) typical existing small cells.”

Efforts by NTIA and federal agencies to facilitate shared use of the 3.5 GHz band are helpful, T-Mobile said. “Nevertheless, the rules should be changed to even better promote investment, so that the 3.5 GHz band can become a meaningful component of the Nation’s wireless ecosystem.” T-Mobile sought longer license terms for the priority access licenses that will be offered as part of the regime for the band. The FCC should also increase the permitted the out-of-band emission and equivalent isotropically radiated power (EIRP) limits allowed and eliminate conducted power limits, T-Mobile said.

Google also took aim at SIA and other objections to the 3.5 GHz rules, saying they appear aimed at impeding the rollout of the CBRS rather than addressing legitimate interference concerns. “The Commission’s rules for the 3.5 GHz band balance two chief goals: they protect incumbent operations while enabling innovation and investment in the band,” Google said.

Qualcomm supported the tweaks sought by CTIA. The FCC needs to allow emissions measurements to be made using a root mean square detector and permit average power measurements, as CTIA requests, Qualcomm said. “This modification is fully consistent with many other licensed and unlicensed operations covered by FCC rules that have been in place for decades,” the company said. “Without it, mobile deployments will be forced to operate with substantially less power, which impacts system performance.”

Federated Wireless, which offers the kind of spectrum access system which will be used in 3.5 GHz sharing, supported calls for higher power and EIRP limits in the band. Federated noted that CTIA, Motorola, Nokia and Verizon have sought higher power limits. Federated Wireless earlier reported on the “growing industry interest” in the band. The company said the National Advanced Spectrum and Communications Test Network announced its first spectrum sharing project in partnership with Federated Wireless, the National Institute of Standards and Technology, NTIA and the Department of Defense. The project involves the test of an environmental sensor capability (ESC) for an SAS, the company said. “The initiation of testing and validation of the ESC marks an important milestone for stakeholders in the Citizen’s Band proceeding, as the ESC validation will help to accelerate certification of SAS solutions and continue the momentum toward shared use of the band.” The company said it plans to launch other pilots in Q4 “focusing on utilization of SAS and ESC technology with different partners.”