On Second Thought: Citizens Broadband Radio Service Rules Draw Eight Petitions for Reconsideration
Petitioners' suggestions are all over the map.
We reported last May on the FCC's adoption of preliminary rules for the Citizens Broadband Service at 3550-3700 MHz. Under those rules, a control database and automated frequency assignment mechanism, dubbed the Spectrum Access System (SAS), will assign frequencies to users on the fly in three priority levels: Incumbent Access, consisting primarily of currently authorized users; Priority Access, for operation under auctioned licenses; and General Authorized Access, whatever is left over. Everyone acknowledges that making this complex system work in real time will be a major undertaking at the very edge of technical feasibility.
In light of the cutting-edge nature of the FCC's system, we might have expected some interested parties to be not entirely satisfied with what the FCC came up with. And sure enough, the FCC has announced receipt of eight petitions for reconsideration raising a range of concerns. The petitions, though, do not seek to revive earlier challenges to the three-priority structure, or the controversies about who should qualify for each priority. The wireless companies no longer insist that the band be auctioned for their exclusive use. The petitions all accept the basic premise of the new rules, while pressing for a wide range of adjustments.
The eight petitioners, and a brief summary of the respective petitions, are as follows. (Cautionary note: These are just the headlines; anyone with a serious interest in this proceeding should consult the separate petitions for full details. And yes, for your convenience we're providing links to each of the petitions. You're welcome.)
CTIA - The Wireless Association wants longer license terms for Priority Access with an expectation of renewal, a change in auction procedures, and higher power coupled with higher out-of-band emissions.
Verizon seeks higher power limits.
Motorola Solutions, Inc., supported by the Wireless Innovation Forum, also wants higher power, plus technical changes to the SAS and to the criteria for protecting Priority Access users in the 3500-3700 MHz segment.
Nokia Networks offers specific ideas for fine-tuning several of the technical rules.
The Satellite Industry Association wants several changes to improve the protection of incumbent satellite earth stations in the band.
The National Association of Broadcasters opposes allowing professional installation as a substitute for automated geolocation built into the device.
Jon M. Peha, a professor at Carnegie Mellon University (and a former FCC Chief Technologist), questions the wisdom of the rule under which the FCC will neither conduct a Priority Access auction nor award a license if there is only one applicant for a license area.
Comments on these petitions will be due 15 days after the FCC's public notice is published in the Federal Register, and replies 10 days after that. We will announce the dates here as soon as the Federal Register has spoken.