Four CBRS SAS Administrators Authorized for Commercial Use;

3650 Transition Period Ending;

PALs Auction Scheduled for June 25, 2020

Docket No. 15-319

___________________________________________________

On Monday, January 27, 2020, the Federal Communications Commission’s (“FCC”) Wireless Telecommunications Bureau and Office of Engineering and Technology authorized four Citizens Broadband Radio Service (“CBRS”) Spectrum Access System (“SAS”) Administrators, CommScope, Federated Wireless, Google and Sony, to make their SAS available for commercial use. With this authorization, we anticipate that the approved SAS Administrators will open up General Authorized Access (“GAA”) use in the band and that commercial deployment in CBRS is imminent. The FCC is scheduled to auction Priority Access Licenses (“PALs”) in the band on June 25, 2020. Auction participants will be eligible to bid on up to four of seven total 10 MHz PALs per county.

Grandfathered 3650 licenses will be protected from CBRS operations within their grandfathered wireless protection zones until the expiration of their transition period. Please note that non-grandfathered 3650 licenses will not be protected from CBRS interference. Under the FCC rules, grandfathered 3650 licensees are required to transition their operations to Part 96 rules by April 17, 2020 or the expiration of their license, whichever is later (with the exception that the transition period for licenses issued after January 8, 2023 will end April 17, 2020). As you may know, the Wireless Internet Service Providers Association (“WISPA”) and Utilities Technology Council (“UTC”) filed a waiver of the FCC’s 3650 Transition rules, requesting that the transition window for all grandfathered 3650 licensees be extended through January 8, 2023, the date on which the last 3650 license transition period expires. Their waiver has now been pending with the FCC for over a year. We have heard that the FCC is unlikely to grant WISPA and UTC’s blanket waiver but may entertain individual waivers.

Accordingly, if you are currently operating your legacy 3650 system and are unable to transition your equipment to Part 96 by April 17, 2020, or by the expiration of your license’s transition period, we strongly encourage you to file an individual waiver with the FCC asking for additional time to operate your existing 3650 system. Please contact Clare Andonov at [email protected], Dee Herman at [email protected], and Greg Whiteaker at [email protected] for more information on the process for filing a waiver or if you would like for us to prepare the waiver on your behalf and for more information on the upcoming PALs Auction.