Twenty-six organizations and alliances in the US with active interests in private and shared cellular for enterprise usage have jointly written to the Federal Communications Commission (FCC) and the National Telecommunications and Information Administration (NTIA) to hail the “success” of the Citizens Broadband Radio Service (CBRS) spectrum sharing model, to date, and to press for “new spectrum options” to further “power the 5G economy”.
The letter is a forecful response to a controversial CTIA report earlier this week (November 15) from telecoms lobby group CTIA, which attacked the efficacy of spectrum sharing, via a direct takedown of CBRS, as a basis for future spectrum releases in the US. The CTIA report, authored by Recon Analytics, claimed CBRS has “low utilization, low market demand, and a dearth of innovative use cases”.
In response, the new pro-CBRS letter – addressed to FCC chair Jessica Rosenworcel and NTIA administrator Alan Davidson, and seen by Enterprise IoT Insights – states that over 285,000 CBRS base station devices are now live on CBRS airwaves, at 3.55-3.7 GHz in the US. The total has been reached in just three years, they declare, since the FCC opened the band for shared and private cellular usage – and compares with 69,543 new radio deployments by public mobile operators in the same period, and 418,887 in the “entire 40-year history” of public cellular in the US.
In other words, new CBRS cell sites are going-in three times (300 percent) faster than the rate of public network expansion. The numbers also undermine any kind of shaky counter-argument that public cellular is an upgrade exercise, originally, on the grounds the three-year CBRS count is two thirds (69 percent) of the 40-year total for commercial cellular – even if it is, so far, an apple-and-orange measures of (mostly) 4G micro and 5G macro cells.
The signatories are mostly CBRS familiars from the telecoms space, such as Airspan Networks, Amazon, Celona, Charter Communications, Comcast, Cox Communications, Federated Wireless, Hewlett Packard Enterprise, Mavenir Systems, Motorola Solutions, and Pollen Mobile. A handful of parties with more traditional ‘vertical’ interests have also signed, notably agricultural giant Deere & Company and real estate firm JBG SMITH Properties.
The education sector (blurring with the healthcare and the municipal realm) is also represented, by the American Library Association, the Purdue Research Foundation, and the Schools, Health & Libraries Broadband Coalition (SHLB). The letter states that the whole of US industry “support[s] an inclusive approach to spectrum policy”; it recites use cases for CBRS networks variously in manufacturing, farming, logistics, education, and healthcare.
This gang of CBRS champs also urge the FCC and NTIA to follow the CBRS model for future spectrum releases, on the grounds that it is efficient. In total, 228 organizations have won priority-access (PAL) licenses at auction, which is “almost 10 times the number of winning bidders in the exclusive-use 3.45 GHz band”, the letter states. The general-access (GAA) portion of the CBRS band hosts nearly 900 different users, across many sectors, it says.
The CBRS model has made the US appear progressive, and worth following, the letter declares. It suggests Brazil, Germany, France, Japan, Sweden, and the UK have all followed the US lead with mid-band ‘vertical’ spectrum. “The US has shown the world,” they write. “In light of other countries’ moves toward greater spectrum sharing, the US should extend its leadership by nurturing and growing CBRS.”
The letter concludes: “The CBRS allocation has fulfilled its promise as the ‘innovation band’ in an incredibly short period of time. The framework should be advanced for future spectrum allocations, including in the lower 3 GHz band, to enable greater competition, innovation, efficiency and American leadership. Thank you for continuing to support a spectrum policy that demonstrates America’s inventive spirit at its finest.”
The letter is copied in full below.
Last month, Kelly Hill, executive editor at RCR Wireless, summed up: “Conversations on spectrum policy are shifting focus to renewing the pipeline of airwaves under consideration for future use, both for 5G and as-yet-unstandardized 6G systems.” Federal agencies are also reconsidering how to shape the spectrum pipeline, wrote Hill, and where spectrum sharing may help to “bolster commercial spectrum access”.
Hill quoted the NTIA at a panel discussion at the Spectrum Policy Symposium in Washington D.C. “There are not a lot of easy bands left, if any, and we need better tools to be able to innovate our way through it,” said the NTIA. A report from Coleago Consulting, from July last year, said average urban needs for mid-band spectrum (around 1.5-7.125 GHz) would be over 2,000 megahertz by 2025-2030, and as high as 3,690 megahertz in rich cities.
The same article also cited a study by Analysys Mason, commissioned by CTIA, which ranked the U.S. ahead of 15 global markets for licensed low-band and unlicensed mid-band provisions, but eleventh of 15 for licensed mid-band spectrum availability.
Meanwhile, the FCC has launched an inquiry into the use of up to 550 megahertz of spectrum at 12.7-13.25 GHz. The 12-13 GHz range falls into the “high midband”. The FCC has said it is “ideally suited for mobile broadband use as it is already allocated for terrestrial mobile services on a primary basis domestically.” It has extended an existing freeze on new operations in the band.
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November 17, 2022
Dear Chairwoman Rosenworcel and Administrator Davidson,
Wireless spectrum is essential to America’s future technology leadership, industrial might, and global competitiveness. That’s why a remarkably broad swath of companies and organizations – representing manufacturing, automotive, agriculture, energy, retail, commercial real estate, communications, media, and supply chain industries, as well as schools, libraries, and civil society groups – support an inclusive approach to spectrum policy. America needs a balanced policy that considers the needs of an extraordinarily diverse range of spectrum stakeholders who are investing in advanced networks to power the “5G economy”.
As we consider new spectrum options that can be made available to serve the American people, we urge you to build on the demonstrated success of the Citizens Broadband Radio Service (CBRS) spectrum sharing model. The innovative CBRS licensing framework has driven innovation in the next generation of wireless networks. These networks advance investment, protect critical U.S. leadership and security by enabling ongoing Department of Defense (DoD) and Federal missions in shared bands, drive innovation and competition, and maximize efficient use of the limited yet essential spectrum resource. Every day, more devices, services, and organizations require access to a wider array of spectrum resources. Implementing approaches that promote a wide variety of advanced communications applications will powerfully advance the public good.
Spectrum Sharing Advances Investment
The Federal Communications Commission (FCC) first authorized commercial equipment in the CBRS band just three years ago and completed its auction of shared licenses just two years ago. In that short timeframe, CBRS is now being used throughout the country with over 285,000 CBRS base station devices (CBSDs) already deployed in under three years. For comparison, the commercial wireless industry has built 418,887 cell sites over its entire 40-year history. (During the same three-year period that CBRS has been active, cellular providers built 69,543 cell sites – of which more than 10,000 use CBRS.) As further evidence of a dynamic equipment ecosystem, the FCC has certified 187 different CBRS base station models and 496 different end user client devices, ranging from traditional smartphones and IoT modules and gateways to security cameras, barcode scanners, and building management sensors. Use of the CBRS band is vibrant and growing at an impressive pace.
Spectrum Sharing Drives Innovation
The CBRS framework provides users with flexibility to choose from the broadest range of technologies and service models, driving innovation and competition in the private wireless market. Because CBRS spectrum is accessible to a wide variety of operators, it provides options for operators in suburban, rural and remote areas that are not adequately served by traditional carriers, while also enabling private network users to customize networks to meet their needs.
CBRS is emerging as the home spectrum band for a myriad of advanced wireless use cases. For example:
– CBRS-powered networks are improving the efficiency of supply chains, warehouses, and critical seaports.
– CBRS is enabling advanced manufacturing techniques that enhance worker productivity and safety, helping – American firms maintain their competitive edge.
– Farms are using CBRS to increase efficiency, yields, and cost savings.
– Transportation and shipping hubs are using private networks to support automated-guided vehicles moving cargo and to improve real-time logistics through faster wireless communications.
– Schools and libraries are using CBRS to close the digital divide and homework gap for underserved communities.
– Hospitals are using CBRS to triage and monitor patients, including by connecting outdoor hotspots to indoor networks, so nurses can test and triage patients outside the hospital setting.
– Airports, entertainment venues, and stadiums are using private CBRS networks to improve the guest experience by providing additional and dedicated bandwidth for venue operations.
These and many other use cases demonstrate that CBRS networks – along with complementary technologies like industrial automation, artificial intelligence, precision agriculture, and edge computing providers – are essential to enabling an enterprise technology stack that propels American innovation and advanced industrial practices.
Spectrum Sharing Spurs Competition
CBRS enables “converged” delivery models that both compete with and bolster traditional wireless network services provided over exclusively licensed spectrum. It is also proving complementary to Wi-Fi. No single private entity or industry should hold the key to an enterprise, university, or other entity’s ability to access the public airwaves needed to deploy an innovative, purpose-built network. The CBRS framework helps ensure that does not happen. This competition drives still more innovation, creating a virtuous cycle.
Spectrum Sharing Maximizes Efficiency of a Limited Resource
CBRS uniquely combines auctioned and non-auctioned authorizations into a single frequency band, maximizing the scale of the equipment ecosystem to the benefit of many different types of users. The FCC conceived of the CBRS shared-license model to allow the DoD to avoid band clearing (and its associated costs) and continue its critical operations while also allowing a wide variety of commercial operators to use spectrum in the same band. This tiered spectrum sharing model ensures the protection of America’s national security interests while allowing other users to make the most of a critical resource.
Both the auctioned (Priority Access License, or PAL) and non-auctioned or licensed-by-rule (General Authorized Access, or GAA) portions of the CBRS bands have demonstrated substantial success. The PAL auction resulted in 228 diverse winning bidders – almost 10 times the number of winning bidders in the exclusive-use 3.45 GHz band. PAL winners included wireless internet service providers and electric utilities, cable operators, and nationwide and regional mobile network operators. The GAA portion of the band hosts nearly 900 different users, including factories, cities, school districts, hospitals, research centers, schools, public libraries, utilities, and other critical infrastructure. Most importantly, unused PAL spectrum does not lie fallow, and can be efficiently put to use by GAA spectrum users.
That all of these different user types can “cohabitate” in a single spectrum band is an achievement to be celebrated and replicated. At the same time, as new technologies and techniques become available to make the CBRS automated dynamic sharing regime even more efficient, it provides a framework for iterative improvement over time.
Spectrum Sharing Is Internationally Recognized
CBRS has become a model for spectrum sharing around the world. Recognizing the value of midband private 5G networks, other countries are also working to make spectrum available in new ways for new users and uses. For example, Germany, France, the United Kingdom, Japan, Brazil, Sweden, and other countries have all designated substantial amounts of shared midband spectrum for private and local networks.
– In Germany, the Frankfurt Airport is working toward deploying a private 5G network to “control data and voice communication autonomously.”
– In Japan, Sony is working to deploy internet service that will minimize “service disruptions caused by heavy traffic” in certain residential complexes.
– In the U.K., Verizon is using shared midband spectrum to develop a private 5G wireless network for the Associated British Ports.
– In Europe, CEPT is studying CBRS-like dynamic sharing of low/medium power networks with satellite systems in the 3.8-4.2 GHz band.
With CBRS, the United States has shown the world that spectrum can be made available without requiring inefficient allocations for a wide variety of different uses. In light of other countries’ moves toward greater spectrum sharing, the United States should extend its leadership by nurturing and growing CBRS.
Conclusion
The undersigned parties believe that the CBRS allocation has fulfilled its promise as the “innovation band” in an incredibly short period of time. The framework should be advanced for future spectrum allocations, including in the lower 3 GHz band, to enable greater competition, innovation, efficiency and American leadership. Thank you for continuing to support a spectrum policy that demonstrates America’s inventive spirit at its finest.
Sincerely,
Airspan Networks
Amazon.com Services LLC
American Library Association
CalChip Connect
Celona Inc.
Charter Communications, Inc.
Comcast Corporation
Cox Communications, Inc.
Deere & Company
Dynamic Spectrum Alliance
Federated Wireless
Hewlett Packard Enterprise Company (HPE)
HRMavenir Systems, Inc.
JBG SMITH Properties
Midcontinent Communications
Motorola Solutions, Inc.
NCTA – The Internet & Television Association
Open Technology Institute at New America
Pollen Mobile LLC
Public Knowledge
Purdue Research Foundation
Shure Incorporated
The Schools, Health & Libraries Broadband Coalition (SHLB)
US Ignite
Weavix
WISPA
