On August 16, 2024 the Federal Communications Commission (“FCC” or “Commission”) issued a Notice of Proposed Rulemaking and Declaratory Ruling, (“NPRM”) soliciting comments on a variety of issues concerning operations in the 3.5 GHz band. Based on ex parte communications, the proposed rule changes that are of most interest to 3.5 GHz operators and equipment manufacturers concern raising the power levels of 3.5 GHz base stations, i.e., Citizens Band Service Devices (“CBSDs”), and end-user equipment (“UE”).
Currently, the FCC has two classes of CBSDs: Category A (indoor use only) with a maximum EIRP of 30 dBm (dBm/10 MHz) or 1 Watt; and Category B (outdoor use) with a maximum EIRP 47 dBm (dBm/10 MHz) or 50 Watts. End-user devices are limited to a maximum EIRP of 23 dBm or 200 mW.
The Commission notes that, due to the relatively low EIRP levels of CBRS compared to that of adjacent bands, e.g., 3.45 GHz and 3.7 GHz, if CBRS is deployed at macro cell locations, there will be a coverage gap between CBRS devices and existing mid- and low-band licensed bands. Power limits in the 3.5 GHz band are 25-28 dBm lower than the power allowed in the neighboring bands. The FCC seeks comment on its proposal to level the playing field by adding one or more classes of higher power CBSDs.
The FCC also seeks to increase the power limit of UEs from 23 dBm to 26 dBm (398.11 mW). The Commission states that the proposed increase will benefit U.S. operations, as it would correspond to the global standards of the 3rd Generation Partnership Project (“3GPP”).
The FCC also seeks comments on various other proposed rules concerning:
- improving protection of federal 3.5 GHz users;
- enhancing offshore CBRS deployments;
- tweaking out-of-band emissions limits;
- updating spectrum access system (“SAS”) connectivity;
- mandating Time Division Duplex (“TDD”) coordination procedures;
- protecting Fixed Satellite Service (“FSS”) earth stations;
- whether professional installation should still be required for CBSDs; and
- whether critical users such as hospitals, public safety organizations, and local governments should be granted special interference protection in a limited portion of the unlicensed General Authorized Access (“GAA”) spectrum tier for indoor use within their buildings.
The comment deadline is 30 days after the NRPM is published in the Federal Register; reply comments are due 60 days after publication.
The CommLaw Group Can Help!
The CommLaw Group is happy to assist your business with deploying efficient and productive operation in the 3.5 GHz band, as well as guiding you through the myriads of authorization, marketing, and installation rules for CBSDs. We will also work with you on submitting comments in this proceeding. The 3.5 GHz band is a gold mine for those who wish to implement wireless broadband, particularly on a local level. The FCC’s rules are constantly evolving, and now is the time to make your voice heard so that the new rules will benefit you.
CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS
Jonathan Marashlian – Tel: 703-714-1313 / Email: jsm@CommLawGroup.com
Michael Donahue – Tel: 703-714-1319 / Email: mpd@CommLawGroup.com
Ronald E. Quirk – Tel: 703-714-1305 / Email: req@CommLawGroup.com
