In light of the recent releases from the FCC on the 3 GHz frequency band, we have posted several items to hopefully clarify what's going on, and address concerns from our customers.
You can read all about this band and the upcoming changes at the FCC Website here. There are many links to the various documents, and I encourage you to check it out.
There is a short summary of our interpretation of the changes here along with the initial set of questions we think customers have about these changes. I have copied those below, and invite you to post additional questions in this thread so we can get answers and hopefully make the adoption of these new rules less painful (even helpful) to many of you.
1
Q: After adoption of FCC 15-47 (April 17, 2015), can I still apply for a 3650 MHz nationwide license under Part 90, subpart Z?
A: No new 3650 MHz nationwide licenses are expected to be granted under the existing rules. PALs will be granted under the new rules once the SAS comes online.
2
Q: Are my existing sites protected?
A: Yes, any sites that you have registered on or prior to April 17, 2015, will be protected under the Grandfathered Wireless Protection Zone, which the FCC will establish around only those base and fixed stations that are registered by applications filed in ULS on or before April 17, 2015 and are constructed, in service, and in full compliance with the rules by April 17, 2016. This licensee will enjoy interference protection within this zone until the end of the 3650-3700 MHz transition period. After that, operations can continue under GAA provided that the equipment complies with all applicable rules other than the new requirement for Part 96 devices that the equipment be operable across the entire band. In other words, the Part 90 equipment must, among other things, communicate with the SAS.
3
Q: If I already have a license (FCN #), can I register new sites?
A: Yes, you can continue to register new sites, and these location registrations will be reviewed and approved by the FCC. The requirement is that equipment is deployed, in service and in full compliance with the rules within 1 year of registration approval of a given site. These newly registered sites do not qualify for Grandfathered Wireless Protection Zone protection.
4
Q: If I have equipment deployed already, and the sites are not yet registered, can I still register these sites?
A: Yes. The FCC is continuing to accept registrations.
5
Q: When will the SAS come online and who will administer this?
A: The FCC intends to issue a Public Notice requesting proposals from entities that seek to administer an SAS, but the exact timing has not been addressed.
6
Q: How long can we continue to use equipment that is not approved under the new rules?
A: At this time, the FCC hasn’t expressly set a deadline by which Part 90-certified equipment can no longer be sold or marketed.
7
Q: When will the initial PAL auctions occur?
A: It’s not expected for quite some time. The FCC intends to adopt a supplemental Notice of Proposed Rulemaking to develop the record on changes to the Part I rules to award PALs using competitive bidding. Once the comment cycle is completed and the FCC has made a determination on how to proceed, it would then announce application procedures and a filing window for participation in the PAL auction.
So, if I'm understanding this correctly, us 3.65 license holders can still register new base station sites (pending FCC approval) today but it won't be protected when the FCC moves to rearrange the whole band into CBRS. Our existing basestation sites (prior to April) have been "grandfathered" and will be protected for the remaining term of the license. I guess for me the language is very vague - like "you can still register sites". Well, I'm making the assumption that means basestation and subscribers sites or...?
Keep in mind the language above is our language and not the FCC's language or a lawyer's language... we're trying to help our customers better understand our view of what the FCC is saying.
That said, when you update "site registration" on the FCC site, you can add Base Station sites (i.e. additional AP locations). To my understanding, this implies a certain radius of area to which you can add subscribers.
The "protected contour" that is afforded to incumbents is only for sites that were registered on or before April 17, 2015. Anything after that will not be added to that "protected contour".
One more point to make is that even when 3650-3700 begins to be managed by CBRS, there will be no PALs issued in these frequencies, so GAA will continue to operate (which is similar in nature to today's Part 90 rules). That is, even though site s that are registered after April 17th are not "protected" status, they will still be allowed to operate under GAA as they do today.
Regarding item 3, registering new sites, " The requirement is that equipment is deployed, in service and in full compliance with the rules within 1 year of registration approval of a given site."
Regarding item 3, registering new sites, " The requirement is that equipment is deployed, in service and in full compliance with the rules within 1 year of registration approval of a given site."
Which rules? I'm assuming Part 90 Z rules???
Correct... this question refers to registering new sites under your existing license (which is Part 90 subpart Z).
Seeing as the SAS is not yet operational, we don't yet know how to register or obtain license to operate under the new rules.
As of April 2015 the FCC is no longer granting 'NN' aka 3.65 non-exclusive nationwide lite-licenses anymore. The citizens broadband radio services (CBRS) is currently being drafted to replace it. You can read more about this here.
The above site has a nice summary of what's happening as well as links to other documents and information.
Yesterday (April 28th), the FCC Open Meeting met and voted to approve the revised technical rules of the CBRS band. The link to the press release is here.
In summary, there were several open issues that were resolved:
1) There is a higher power level for non-rural Category B CBSDs (and additional flexibility in out-of-band measurement rules).
2) Streamlined PAL rules, and allowing a PAL applicant to obtain a license even if it's the only applicant for rural census tracts (i.e. there no longer needs to be two interested parties).