FCC Seeks Comments on Waiver Request to Extend 3650 Grandfathered Transition Period

Docket 18-353

The Federal Communications Commission (FCC) has released a Public Notice requesting comments on a request filed by the Wireless Internet Service Providers Association (WISPA) and Utilities Technology Council (UTC) for waiver of FCC rules which limit the duration of protection afforded grandfathered 3650 licenses until April 17, 2020 or the expiration of their license, whichever is later.  During that period of time, existing 3650 licensees are required to transition their operations to the new Part 96 Citizens Broadband Radio Service (CBRS) rules.

In their petition for waiver, WISPA and UTC argue that an extension of this transition period is merited due to delays in opening the 3.5 GHz band for commercial use under the Part 96 CBRS rules.  Specifically, WISPA and UTC request that the transition window for all grandfathered 3650 licensees be extended through January 8, 2023, the date on which the last 3650 license expires.  Comments on this request are due December 12, 2018 and reply comments are due December 24, 2018.

In light of the delays finalizing the CBRS rules and implementing Part 96 standards, we think an extension would be appropriate and beneficial for grandfathered 3650 licensees. If you have any questions, or would like assistance in filing comments in support of this waiver, please contact Dee Herman at dee@hermanwhiteaker.com, Greg Whiteaker at greg@hermanwhiteaker.com, or Clare Liedquist at cliedquist@hermanwhiteaker.com.