Most 3650 MHz Operations Must Be Transitioned to CBRS by October 17, 2020

The majority of 3650 MHz licenses will expire on October 17, 2020, and most 3650 MHz operations, which currently are conducted under Part 90 of the Federal Communications Commission (FCC) rules, must be discontinued or transitioned to Citizens Broadband Radio Service (CBRS) operations under Part 96 of the rules
by October 17, 2020.[1] The original transition deadline was April 17, 2020, however, in March, the Wireless Telecommunications Bureau (Bureau) granted a
blanket extension to allow Part 90 3650 MHz operations an additional six (6) months to transition to Part 96 CBRS operations. Citing the unpredictability of and the need for connectivity during the COVID-19 pandemic as the main reasons for the extension, the Bureau believed extending the transition period until October 17, 2020 would allow sufficient time for licensees to complete their transition.

The Bureau specified that licensees seeking a further extension of the transition period, beyond October 17, 2020, should file new individual waiver requests that “plead with particularity the facts and circumstances which warrant such action.” If you are currently operating a legacy 3650 MHz system that is not otherwise authorized to operate beyond October, 17, 2020, and you anticipate that you will require additional time to transition your operations to comply with Part 96 rules, please contact Greg Whiteaker, greg@hermanwhiteaker.com, Clare
Andonov, candonov@hermanwhiteaker.com, or Hilary Rosenthal, hrosenthal@hermanwhiteaker.com, for more information on filing an individual waiver request with the FCC prior to October 17th.