Deployment Enables Commercial Operations in the So-Called "Innovation Band"

Commercial operations in the 3.5 GHz band, referred to as the Citizens Broadband Radio Service (CBRS), are now possible following Federal Communications Commission (FCC) action on January 27, 2020, certifying and approving operations of four spectrum access providers. Specifically, the FCC released a Public Notice (PN) announcing the certification and approval of four Spectrum Access System Administrators (SAS providers) who will provide the essential spectrum mediation and access functions that are critical to the success of the spectrum sharing regime in this band.

The Wireless Telecommunications Bureau and the Office of Engineering and Technology determined that the SAS providers’ operations comply with current rules and authorized full commercial deployment conditioned on continued compliance with the FCC's rules and guidance.


Authorizing full commercial deployment on the CBRS band frees up valuable mid-band spectrum for a range of potential use cases, including deployment of advanced wireless services, enhanced broadband connectivity for both mobile and fixed wireless networks, and the deployment of private LTE networks for stadiums, conference centers, hotels and similar venues. Also, this development marks the nationwide debut of the unique, three-tiered sharing framework that is the hallmark of this band.

As explained in our prior advisory, this novel spectrum access framework assigns user rights based upon whether the spectrum user is an incumbent operator, licensed operator, or general authorized (i.e., licensed by rule, or quasi-unlicensed) operator.


SAS – Mediating Shared Spectrum Use

The SAS providers play a central role in mediating the spectrum access rights among all three classes of users. By using sophisticated algorithmic-based databases and sensing systems to dynamically assign CBRS spectrum to authorized users in any of the three tiers, the SAS accommodates higher priority users while simultaneously maximizing the amount of spectrum in use at any given time.

Incumbent operators receive protection from both licensed and unlicensed operators, while licensed operators receive protection from unlicensed operators.

SAS Initial Commercial Deployments Demonstrated Compliance and Viability of SAS Functions

This Commission action follows the FCC’s recent decision to approve "initial commercial deployments" (ICDs) for five SAS providers. Prior to this approval, the SAS providers submitted laboratory testing reports demonstrating their ability to comply with the CBRS rules in support of their ICD applications. The ICD phase marked the very beginning of commercial deployment in the band, albeit in limited geographic areas.

After operating their systems for 30 days, the SAS providers were able to send reports using data gleaned during ICD, which the FCC reviewed in coordination with the Department of Defense and the National Telecommunications and Information Administration.

This information played a critical role in the FCC’s certification that authorizes the SAS providers to make their SAS available for commercial use on a nationwide basis for a five-year term. As a result, the SASs are now able to mediate spectrum use between unlicensed users (known as General Authorized Access (GAA) users), PAL licensees and a variety of incumbents (including federal and previously authorized non-federal users) across the United States, Hawaii, Guam, and Puerto Rico.

Next Steps

In addition to the unlicensed and incumbent users, the SAS providers are also expected to mediate spectrum use by priority access license (PAL) holders. These so-called PAL licenses are expected to be issued later this year in the FCC’s designated Auction 105 – which is scheduled to begin on June 25, 2020.

The Commission plans to auction up to 70 MHz of spectrum in 10 MHz channel blocks in each county-sized market area, reserving a total of 80 MHz for GAA use per market. Through this auction, more than 22,000 PAL licenses will be available nationwide. These licenses will be effective for 10-year terms, with renewal rights at the end of the term.

At present, the Commission is considering several open questions regarding other aspects of the auction mechanics, discussed in our prior advisory. The Commission is expected to issue a PN in the near future that announces its resolution of those issues and the various procedures that must be filed by prospective auction participants.

Regulators, the industry and analysts will be closely following the emerging CBRS ecosystem and the viability of the spectrum-sharing framework in the CBRS band. Indeed, the Commission is already considering utilizing a spectrum-sharing framework in other bands, such as 3.1-3.5 GHz and 6 GHz, and may add 500 MHz of C-band spectrum to the list. At the same time, the NTIA very recently issued a report concluding that there are "viable options" for instituting a spectrum-sharing framework in the 3450-3550 MHz spectrum band.