FCC Extends Transition Deadline for Licensees in 3650-3700 MHz Band

Licensees in 3650-3700 MHz Band Given
6 Month Extension to Transition to Part 96


Yesterday, the Wireless Telecommunications Bureau (“Bureau”) of the Federal Communications Commission (“FCC” or the “Commission”) granted a blanket extension (“Extension”), on its own motion, to extend the deadline for certain Part 90 licensees in the 3650-3700 MHz band to transition to Part 96 operations until October 17, 2020.  Citing the unpredictability of and the need for connectivity during the COVID-19 pandemic as the main reasons for the extension, the Bureau believes extending the transition period by six (6) months will allow sufficient time for the Part 90 licenses that were set to expire by April 17, 2020 to complete their transition to Part 96 Citizens Broadband Radio Service.  The Extension permits existing licensees in the band that had a transition deadline between April 17, 2020 and October 17, 2020 to continue operating consistent with their current grandfathered or non-grandfathered status during the extended transition period.  Additionally, the Bureau announced it will suspend acceptance and processing of new site registrations for all Part 90 wireless broadband licenses from this point forward.  The extension will have no impact on the auction of Priority Access Licenses, scheduled to begin in June of this year.

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.” In order to obtain a further extension beyond the new transition deadline, the a licensee should describe (1) the efforts taken to purchase, install, and test Part 96 compliant upgrades or equipment prior to October 17, 2020; (2) the unique or unusual circumstances that prevented transition prior to the deadline; and (3) the specific steps the licensee will take and the amount of time needed to complete its transition.

If you are currently operating a legacy 3650 system and you believe that you will require additional time beyond October 17, 2020 to transition your equipment to comply with Part 96 rules, please contact us for more information on filing an individual waiver with the FCC at a time closer to the new transition deadline.