I am delinquent in making this post but still thought it appropriate to shre with the Community, and in particular the US members, Cambium Networks' response to the FCC's Notice of Proposed Rule Making (NPRM) Promoting Investment in the 3550-3700 MHz Band, Notice of Proposed Rulemaking and Order Terminating Petitions (GN Docket No. 17-238) (issued Oct. 24, 2017).
In addition to supporting the WISPA led and filed reponse, Cambium Networks collaborated with the Regulatory and Technology Committee of the Energy Telecommunications and Electrical Association (“ENTELEC”) and the Utilities Technology Council (“UTC”) and submitted Comments to address the FCC’s proposed changes to certain rules governing the Priority Access Licenses (“PALs”) that will be issued for the Citizens Band Radio Service (“CBRS”) in the 3550-3700 MHz Band (“3.5 GHz Band”).Â
Our position was essentially that the FCC must stay the course and award PALs based on census tracts, rather than adopting the NPRM proposal to force applicants to bid on much larger and more costly Partial Economic Areas (“PEAs”).  Mandating the use of such large coverage areas will foreclose participation by many localized entities or otherwise will force such entities to make uneconomic and spectrally inefficient bids to obtain rights to a coverage area that far exceeds their needs and their footprint. As a result, investment in the 3.5 GHz Band spectrum would be limited to a very few well-funded participants at the expense of localism and new competition.
Our full response is attached for your viewing pleasure.
Scott