DoD’s latest spectrum proposal is not good for CBRS

  • The DoD’s plan calls for moving CBRS from the 3.55-3.65 MHz part of the band to the lower 3 GHz, according to a New Street analysis
  • That’s similar to what AT&T proposed last fall – a plan that was met with loads of opposition from the CBRS community
  • New Street analysts said they don’t think the DoD proposal represents anything close to a done deal

AT&T floated a proposal last fall to move the Citizens Broadband Radio Services (CBRS) from the middle of the 3 GHz band to the lower part of the band, and it looks like the Department of Defense (DoD) is on board with that plan, according to New Street Research (NSR) analysis.

Under its proposal, AT&T called on the Federal Communications Commission (FCC) to move CBRS from 3.55-3.7 GHz to the 3.1-3.3 GHz band, upending CBRS so that wireless carriers like AT&T could move in – after bidding and paying for it through an auction, which would help pay for the relocation of the incumbents.

The DoD's spectrum plan, which is being circulated around Washington, D.C., would move CBRS licensees from the middle part of the band to the 3.1-3.4 GHz band, freeing up 100 MHz of spectrum to be auctioned, according to New Street. 

It’s not unheard of for the government to reallocate spectrum from one set of users to a different set of users – it did it that when moving broadcasters out of the 600 MHz to make way for mobile users. But it’s hard to come up with an example where the government changed the license terms of one set of users in favor of a competitor in another set of users, said NSR analyst Blair Levin in a report for investors Thursday.

“While the exclusive-use spectrum providers would see this as government exercising its eminent domain rights as it has traditionally done, CBRS users, particularly cable, would see this as the equivalent of a government exercising its eminent domain rights to condemn and tear down a Costco to give the land to a Walmart,” he wrote.

It also raises the question in future auctions about the value of a license if the government can exercise its power to change the rights under that license, Levin noted.

CBRS use cases

Sometimes called the experimentation or innovation band, CBRS involves a three-pronged spectrum sharing model that protects DoD incumbents – mostly along U.S. coastlines – but lets non-traditional entities use the spectrum. Currently, users in the CBRS band include entities like John Deere, venues such as the Dallas Fort-Worth (DFW) Airport and vendors like Nokia for its U.S. private networking business.

It’s also used by dozens of wireless internet service providers (WISPs) to provide internet connections to homes and businesses, many of them in more rural areas without a lot of choice in service providers.

WISPA President and CEO David Zumwalt told Fierce that AT&T has been trying to position CBRS as a fallow band, “and it’s anything but. It’s really the first band that I’m aware of where spectrum sharing has been attempted and proven to work and the adoption within our industry has been huge,” with more than 400,000 devices deployed, he said.

“Relocation of CBRS is a very unpopular prospect for our members because they’re using it actively and it’s proven to be a very successful band to use,” Zumwalt said Thursday. 
 

Fierce reached out to the DoD for comment and will update this story if we hear back.

AT&T declined to comment.

John Dooley, managing director at the Jarvinian Spectrum Opportunity Fund, noted that the CBRS spectrum is sandwiched between the 3.45 GHz band and 3.7 GHz bands, which are both used by AT&T. “Bridging the two into a single band represents a real potential benefit for carriers,” he told Fierce.

“However, aside from the DoD issues with radar that impact a bulk of the U.S. population along the coasts, moving the already significant user based of Band n48 to a new band in the lower 3 GHz range would be extremely disruptive,” Dooley said. “This band is already used by a large diversity of critical systems, large and small.”

Besides moving CBRS, Levin said the Pentagon’s spectrum plan would make 640 MHz of spectrum available for auction through the following steps:  

  • Vacating DoD systems in the 1300-1350 MHz and the 1780-1850 MHz bands to free up 120 MHz
  • Having the FCC clear 220 MHz in the upper C-band for auction
  • Vacating DoD systems in the 5850-5925 and 7125-7250 MHz bands to create 200 MHz of spectrum for auction

Not a done deal

It’s worth noting that the DoD’s proposal isn’t anywhere near a done deal. Efforts are underway in Washington, D.C., to pass a budget reconciliation bill and timing of the public release of the DoD proposal is likely tied to that. Expectations are high that the reconciliation bill will include auction reauthorization for the FCC that it’s lacked for several years.

However, Levin said he believes it’s unlikely the DoD spectrum plan will be represented in or required as part of this upcoming reconciliation bill.

“We think that bill will reauthorize general spectrum auction authority and require the FCC to auction a minimum amount of spectrum, but it will not specify the bands to be auctioned,” he said. “But the DoD offering a proposal may play into how advocates discuss scoring auction proceeds with the Congressional Budget Office.”

The wireless industry has been fighting for years to get the DoD to give up some spectrum in the lower 3 GHz, and CTIA believes there’s a way to do that while preserving the nation’s security, specifically in the 3.3-3.45 GHz portion of the band. But the DoD proposal doesn’t contemplate that.

CTIA shared the following statement in response to a query from Fierce: “To meet consumer demand and continue leading the world in 5G and innovation, America needs a pipeline of full-powered, midband licensed spectrum. The solution needs to include key global 5G bands controlled today by the federal government.”