Google Tells FCC It Shouldn't Change 3.5 GHz Rules; Carriers Disagree

Google opposes proposed changes CTIA and T-Mobile sought to rules for the 3.5 GHz shared band, saying the FCC needs to keep its eye on stability. Verizon supported the CTIA petition over that of T-Mobile, consistent with its earlier stance (see 1706200081). Comments were due on the petitions Monday, and dozens filed in docket 12-354, as the FCC considers changes to rules for the Citizens Broadband Radio Service. Commissioner Mike O'Rielly discussed the rules Tuesday (see 1707250049).

“Rules have converted underutilized spectrum that could not support a traditional clear-and-auction approach into a band with more varied and intense interest than any other pending deployment,” said Google and parent Alphabet. Hospitality providers, energy producers, rural broadband companies and others are interested in the band, Google said. “Based on this extensive industry experience, it is clear that the FCC can best maintain and promote investment in the CBRS band by (1) preserving stable rules on which investors can rely, and (2) allowing all categories of commercial users to pursue the technologies and business plans they believe will succeed,” Google advised. Adopting the changes sought by CTIA or Verizon would violate those principles, it said.

Verizon countered that carriers will invest only in the priority access licenses (PALs) that will be auctioned under the FCC plan if the rules are modified. “As CTIA describes in its petition, the remarkably short license terms, lack of an expectation of license renewal, and unmanageably undersized geographic license areas risk not realizing the full potential of the licensed portion of the band,” Verizon commented. "The Commission should make these narrowly targeted changes quickly, and doing so will not -- and should not -- delay or otherwise compromise deployment of CBRS.”

The Dynamic Spectrum Alliance also urged stability, citing investments already made before the band opens. “Resist arguments to change the current PAL structure to one that would be favorable to only one class of entity -- the large nationwide wireless carriers, at the expense of all other entities,” DSA commented.

Qualcomm sided with the carriers, saying the band should get widespread use for small cells. “Rules place undue limits on the 3.5 GHz band PAL licenses and penalize operations with channels wider than 10 MHz even though the penalty has nothing to do with adjacent band operations,” Qualcomm said. The current rules impose too tough emissions limits on channels wider than 10 MHz, the company said.

New America’s Open Technology Institute and Public Knowledge slammed the petitions in comments not yet posted: The proposals "to tailor licensing rules to closely fit the carriers’ wide-area business model will needlessly foreclose localized, innovative and potentially competing new users and uses that will benefit both consumers and the business community."