June 19, 2017

By: Kara Romagnino

On June 16, CTIA asked the FCC to adopt limited, common-sense reforms to enable more investment and innovation in the 3.5 GHz band—a swath of spectrum that is critical to deploying next-generation 5G networks.

These reforms are important because if we get our spectrum and wireless infrastructure policy right, 5G is forecast to be a $500 billion shot in the arm to America’s economy, creating three million jobs and enabling smart city solutions that could produce $160 billion in benefits and savings for communities across the country.

Nations around the world are accelerating the development and deployment of 5G by streamlining access to bands like 3.5 GHz. China, for example, is testing 5G already and has allocated 300 MHz of 3.5 GHz band spectrum for 5G use. With 3.5 GHz as the only mid-band spectrum in the pipeline in the U.S., we need a licensing framework that facilitates investment, cements our lead in 5G and maintains our position as the global leader in wireless.

The 3.5 GHz Framework

In 2015, the FCC proposed a three-tier experimental sharing framework to govern the 3.5 GHz band. In that framework, existing government users like the U.S. Navy would occupy Tier 1, license holders (to be determined by auction) would occupy Tier 2, and those seeking opportunistic use—similar to unlicensed bands—would occupy Tier 3.

While we have long supported the FCC’s efforts to free up more spectrum for mobile broadband in the 3.5 GHz band, we believe that three simple changes will incentivize investment and bring additional clarity for licensees while maintaining the three‑tier structure, ensuring the experiment is a success, and not delaying access to the band.

Specifically, CTIA recommends:

• Incentivizing Investment with Longer License Terms . The FCC should extend the existing three-year license terms to standard, 10-year terms and provide licensees with an expectation of license renewal. In the highly competitive wireless market, significant resources, time and capital are needed for successful network buildout—particularly in a new band where standards need to be developed and new equipment needs to be certified and produced. A three-year license term is insufficient for the investment needed to make the 3.5 GHz band a success.
• Simplifying Use with Larger Geographic License Areas . The FCC should issue license terms based on larger Partial Economic Areas (PEAs), not Census tracts. A spectrum auction based on 74,000 Census tracts would make it much more difficult for providers to build out wireless networks. By contrast, PEAs can meet the FCC’s goal of balancing intensive, efficient use of spectrum while allowing targeted deployments that can be aggregated for larger network footprints. The 600 MHz auction proved that PEAs create opportunities for large and small providers alike. They represent a more manageable approach for the 3.5 GHz band as well, simplifying auction complexity, reducing interference and lowering administrative burdens for all stakeholders.
• Strengthening Privacy and Property Rights with Enhanced Protections . The FCC should enable Spectrum Access System (SAS) Administrators to protect the privacy of 3.5GHz device users, by not allowing public disclosure of users’ registrant information. SAS Administrators can efficiently and effectively manage the sharing regime without disclosing this content. The release of this information, even if individual licensee identities are concealed, could raise competitive and personal privacy concerns.

With these reforms, 3.5 GHz users will be better positioned to make this framework successful. Federal government incumbents will receive priority protections, winning licensees will receive incentives to bid and deploy, and opportunistic-based users will be able to innovate in the band at low cost. Most importantly, the wireless industry can begin to build out the infrastructure for this critical band of spectrum.