City and Port of Los Angeles argue for keeping existing framework for CBRS

Add the City and Port of Los Angeles to the list of entities arguing for the FCC to resist making wholesale changes to the Citizens Broadband Radio Service (CBRS) rules for the 3.5 GHz band and instead keep them as they were agreed upon in 2015.

The entities that want to keep the existing rules see the proposed changes as just benefiting a few: major wireless operators, to the detriment of smaller stakeholders that the original CBRS rules were supposed to foster. Wireless operators have called for larger licensed areas and 10-year license terms, which would make the spectrum more attractive and predictable for their investment purposes. Smaller companies, however, argue that larger license areas make it harder for them to invest.

The FCC voted on CBRS rules in 2015 but Republican Commissioners Ajit Pai and Michael O’Rielly were not happy with the way they were structured, and once Pai became chairman, he asked O’Rielly to lead an effort to re-examine the rules, which led to a Notice of Proposed Rulemaking (NPRM) last year that has been the subject of public comment. It is not known when the full commission will vote on the issue, but some speculate it could be March or April.

In its comments to the commission, the City of Los Angeles said smaller license areas allow for more focused uses of spectrum. For example, a shift from the current census tract licensing scheme to Partial Economic Areas (PEAs), or even, as some have proposed, to counties, would “drastically increase the prices of licenses exponentially,” from covering neighborhoods and single-site locations of several thousand people to one of the largest metro areas in the nation.

“Instead of providing affordable access to high-capacity spectrum for schools, hospitals, industrial facilities and competitive wireless broadband providers, among other applications, PALs in the Los Angeles area would cover millions of individuals, even at the county level, making licensed spectrum in the 3.5 GHz band entirely inaccessible to all but the deepest of pockets,” the city said.

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While the largest wireless operators are asking for licenses based on PEAs, other entities like Comcast are suggesting they be based on counties, making them more attractive to investors both large and small and ensuring that the 3.5 GHz band remains accessible for non-traditional participants and innovative business models.

But the City of Los Angeles is “deeply concerned” that long and perpetual license terms, combined with license areas as large as counties or PEAs, will ensure that small operators, individual enterprises and local institutions like schools, libraries and harbors, do not have access to Priority Access License (PAL) spectrum.

Los Angeles isn’t the only big city showing concern for CBRS. In December, the City of New York said it had an interest on behalf of all its residents, businesses and visitors and as a major consumer of wireless services. The city said the current framework of three-year licenses covering census tracts would most effectively spur investment in 5G networks while encouraging universal access to advanced services.

Meanwhile, the Port of Los Angeles is the nation’s largest and busiest container port, handling 9.3 million container units in 2017, according to the Port’s filing. Increasing, the shipping industry is looking to leverage big data and industrial IoT platforms to achieve better efficiencies. The Port said it’s pioneering the use of advanced data sharing across port stakeholders and having predictable access to 3.5 GHz spectrum is key to developing and deploying these technologies.

“We ask that you do not change the CBRS rules by increasing the geographic areas covered by Priority Access Licenses (PALs) from census tracts to Partial Economic Areas (PEAs),” the Port of Los Angeles wrote. “Furthermore, we are concerned with a proposed increase in license terms to 10 years. Such changes would impede industrial loT utilization and delay the innovation that ports and the shipping industry are on the cusp of delivering.”

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General Electric also weighed in and focused its comments on the industrial IoT, saying it wants to keep the census-tract licensing plan for the benefit of localized, secure private LTE networks in industrial and critical-infrastructure environments and other enterprise settings.

The existing CBRS licensing framework, for the first time, will enable new entities to control their own networks and get access to licensed, interference-protected spectrum by actively participating in 3.5 GHz PAL auctions, GE said.

The company also said that virtually the only parties that favor a shift to PEA-based licensing in the 3.5 GHz band are the major wireless carriers and their main trade association, CTIA.

Under the proposed changes, carriers would be in a position to outbid any other parties for PEA or other large geographic-area licenses, according to GE, and once they get the spectrum, the major carriers would turn CBRS into just another generic, commercial wireless band to be integrated into their multiband networks to bolster wide-area mobile offerings in select locations where additional capacity is needed. “In this scenario, CBRS could no longer be considered an ‘Innovation Band,’” GE said.