T-Mobile Arguments on Proposed Auction of 3.65 GHz Fall Short

July 28, 2017

The Enterprise Wireless Alliance (EWA) has filed comments in response to Petitions for Rulemaking seeking changes to rules governing the 3550-3700 MHz Citizens Broadband Radio Service (CBRS) filed by CTIA and T-Mobile USA, Inc. Both propose changes favorable to Priority Access License (PAL) licensees, providing them with longer license terms and larger auction areas. EWA does not object to the Petitions regarding those matters. However, it opposes the T-Mobile recommendation that the Federal Communications Commission (FCC) auction the entire band for use by PAL licensees. This recommendation includes the 3650-3700 MHz band, which is intensively used by government, business, industrial and critical infrastructure users, many of which are members of EWA.

The Alliance responded that it “understands that, from the perspective of a carrier, it always will be preferable to have access to the largest possible licensed allocation. The Commission, on the other hand, is responsible for balancing the interests of multiple parties, both incumbents and prospective new entrants.” In an earlier decision, the FCC determined the public interest would be best serviced by allowing the band to be shared with unlicensed General Authorized Access users but not PAL operations. Nothing in the current Petition from T-Mobile warrants disturbing this finding. A substantial number of comments were filed opposing the T-Mobile proposal to auction the 3.65 GHz band.

About the Enterprise Wireless Alliance

The Enterprise Wireless Alliance is an FCC-certified frequency advisory committee and leading advocate for business enterprises, private carrier operators, wireless sales and service organizations and private wireless equipment vendors. EWA provides spectrum acquisition strategies, frequency coordination, license preparation, license management and associated reporting services. Visit www.enterprisewireless.org for more information.

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Triangle Security and Communications
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P&R Communications
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A Beep, LLC
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Midland Communications
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Mobile Communications America