March 12, 2015 — Interestingly Google, of all entities, in a recent filing, said that FCC’s spectrum sharing plan for the 3.5 GHz band “threatens to fragment the management of shared 3.55 GHz spectrum in a way that both reduces the protection of incumbent systems and limits the opportunities for sharing unused priority-access (PA) spectrum.”
Google has long maintained that “it does not aspire to become a “network operator at scale.” However, it seems that it has more than just a passing interest in spectrum issue. While it does not openly admit it, there is widespread expectation that this is what the company plans to do, similar to positions by Disney, ESPN, WalMart and Best Buy, to enter wireless by reselling carriers’ services under their own brands. However, whether or not that is their plan is a discussion for another day. But their filing is a vector to another issue – bandwidth warehousing. And if they care, maybe there is reason to take a good look.
Under the FCC’s April 2014 Further Notice of Proposed Rulemaking (FNPRM), the commission is looking at allowing spectrum sharing to 3550-3650 MHz spectrum, and is considering extending the service to 3700 MHz.
The FCC platform is a three-tiered access and sharing model that would be comprised of priority-access licensees (PALs), federal and nonfederal incumbents, and general authorized access (GAA) users — who are, basically, the unlicensed (Wi-Fi) users. PALs, such as mobile operators, would most likely use the spectrum for multiple applications, including mobile broadband and small-cell operation.
To make a long story short, this does seem to raise the specter of spectrum warehousing, which would not bode well for small cells at this frequency. Why? Because part of the proposal calls for having a centralized spectrum manager, or Spectrum Access System (SAS), assign channels dynamically. If information regarding actual use by PALs could be withheld from the SASs, entities could easily prevent other operators from using the shared resource by reserving PAL spectrum, failing to use it, and failing to disclose their nonuse. Seems like a loophole to me.
And Google is not alone. The WiMAX Forum urged the commission to not include 3.65-3.7 GHz spectrum in its CBRS regulatory plan, at least not until the FCC’s spectrum-sharing techniques could be successfully employed over a few years.
Let’s hope the FCC listens.
Ernest Worthman is the editor of Small Cell Magazine.