Battle for CBRS Spectrum

There is a huge battle brewing at the FCC over the use of CBRS spectrum. The pieces are starting to fall in place to possibly auction the spectrum for use by cellular carriers.

The idea of putting the spectrum up for auction has been discussed for several years, but the topic went into high gear last year when AT&T asked the FCC to open a formal docket to explore the idea. AT&T’s request was opposed by a diverse set of industry stakeholders, and the FCC didn’t take any action on the AT&T request.

One of the stumbling blocks to the AT&T request is that this spectrum is used by the military, primarily by the Navy. The Department of Defense just removed that hurdle and is circulating a spectrum plan where it would relocated its functions being handled by CBRS spectrum to the 3.1-3.4 GHz band.

The other new change is that Congress now seems gung-ho to reauthorize FCC spectrum auctions as a way to meet budget goals. During newly-passed House version of the new budget is an assumption that new spectrum auctions will be able to raise $88 billion. That claim seems high since the FCC has only raised a total of $233 billion from spectrum auctions since the process began in 1991.

For a new spectrum auction to raise a lot of money, a lot of spectrum has to be made available. The DoD proposal has the military freeing up 640 MHz of spectrum, including freeing up use in 1300-1350 MHz, 1780-1850 MHz, 5850-5925 MHz, and 7125-7250 MHz. DoD also proposes that the FCC clear 220 MHz in the upper C-band for auction. The FCC has already been considering auctioning off the AWS-3 spectrum bands that include 1695-1710 MHz, 1755-1780 MHz, and 2155-2180 MHz.

If the FCC goes along with AT&T’s and DoD’s proposed plans, it will be a huge windfall for cellular carriers over other spectrum users. CBRS spectrum is used today for a wide variety of functions, including rural broadband, manufacturing, industrial and enterprise private networks, transportation and logistics connectivity, and school and library access. I wrote a recent blog about how John Deere was using the spectrum to create a private network for its factories in Illinois and Iowa.

A spectrum auction would require the auction winner to fund existing users to relocate to another spectrum band, but doing so is disruptive, and in many cases would not result in a one-for-one functional swap.

The FCC would also be setting a new precedent by relocating CBRS spectrum users who won the use of the spectrum in the last few years. For the FCC to change its mind about the spectrum should make any spectrum winner nervous that the FCC won’t defend existing spectrum licenses.

Anybody who has been following the industry has noticed a big uptick in discussions about how the U.S. is again losing the 5G battle to the Chinese. I’ve never found anybody able to tell me what that means, and the last time this language was used was part of a ploy by carriers to put pressure on the FCC to hold more spectrum auctions. It looks like history is repeating itself.

The most interesting thing about these spectrum battles is that the cellular carriers mostly want more spectrum to be able to compete for home broadband service. I think we should be having the policy discussion if that is in the long-run national interest. It makes sense to deploy unused spectrum in rural areas to provide broadband in places where people don’t invest in fiber networks. But spectrum is a limited resource, and I think it’s a valid question to ask if we should be using valuable spectrum to bring a third competitor to urban markets that already have fiber and cable ISPs. I went back and reviewed the original goals for 5G, and competing for home broadband was never mentioned as a goal.

John Deere’s Private 5G Network

FierceNetwork recently published an article talking about the private 5G network implemented by John Deere for it’s campuses and factories. Having a secure private wireless network is allowing the company to implement 5G technology onto the manufacturing floor.

The company got started on this solution when it spent $546,000 to buy CBRS PALs licenses in 2021 in five counties in Illinois and Iowa, that included its headquarters in Rock Island County, Illinois. John Deere has more than twenty facilities in the five counties.

The key to making this work was the exclusive use of spectrum, meaning that Deere can always rely on the wireless bandwidth free of interference or use by others. That assurance allows the company to establish a wireless network to communicate directly with manufacturing equipment in its factories.

It’s taken four years for the company to make the transition to wireless broadband, with the company having to find a 5G interface for each piece of equipment. Jason Wallin of John Deere is quoted that the company adopted an 80-10-10 model where 80% of broadband needs are covered by the private 5G networks, 10% by WiFi, and 10% with hard-wired Ethernet. The company says it is spending $1.7 million this year on updated smart tools to take advantage of the wireless network.

The company was quoted in 2021 about seeking the same wireless solution in its other factories around the world. But adopting this in other locations would require working with a cellular license holder to somehow carve out spectrum for each factory.

The creation of 5G private networks was one of the original big promises for 5G. There have been some notable examples of private 5G networks created around the world for Airbus, Shanxi Coking Coal, Group, Tesla, Lufthansa Technik, and NEC. However, this has not been the booming business for cellular carriers they hoped for. If you look back at industry press five years ago, you’d see the carriers touting this as a major opportunity. However, like other business lines based on 5G, the performance badly underperformed the expectations. The John Deere example showed a corporation that found it better to buy the spectrum and tackle this on its own rather than partnering with a carrier.

The CTO of John Deere says the company expects to use the newly created wireless network far into the future. This sounds like a relatively small investment to gain the benefits of fully automating the factory floor by connecting all machinery to an integrated network.

Is There a Spectrum Shortage?

I’ve regularly seen editorials and blogs that claim that the U.S. is far behind in providing spectrum to wireless carriers. The purpose of these articles seems to be to lobby the FCC to make more cellular spectrum available, particularly mid-range spectrum. That’s spectrum between 1 GHz and 6 GHz, which is the sweet space for 5G cellular coverage. Spectrum in this range is perfect for mobile cell coverage – the spectrum penetrates foliage and other impediments and also carriers for a decent distance of a few miles from cell towers.

Part of the reason for the recent spate of articles is that the FCC has lost the ability to hold spectrum auctions. In March 2023, Congress declined to renew the agencies ability to hold auctions, which has been the common way to decide how to allocate spectrum – to those who are willing to pay the most to use it.

A common claim made is that the U.S. is far behind China, which is the bogey-man for everything wireless. I recall an op-ed in the Wall Street Journal that claimed that China has 245 5G base stations per 100,000 people, Europe has 103, and the U.S. has only 51. While this may be true, this is more of a case of the willingness of U.S. cell carriers to invest in new cell towers and sites. In U.S. cities, cellphone download speeds are regularly reported to be over 100 Mbps download, and cell carriers here don’t see any reason why they need to beef up speeds more than that.

The main difference between the cellular networks in U.S. compared to the rest of the world is that a lot more people here rely on landline broadband and WiFi for their broadband needs versus using the cellular networks. In pars of the world where wireless carries a much larger share o broadband, it’s far more important to have robust wireless networks.

I’ve seen a lot of wireless experts that claim that the big U.S. foray into FWA wireless is due to carriers finding a way to monetize the excess spectrum that cell carriers already own. It’s an interesting choice of how to use spectrum, because from a monetary perspective, cell carriers are selling a gigabit of FWA broadband at a tiny fraction of what they charge for a gigabit of cellular broadband. It doesn’t make sense that carriers would pursue FWA so aggressively if they were feeling spectrum constraints.

Another reason why U.S. cellular carriers have excess spectrum capacity is that the many projected uses for 5G that were touted a decade ago never materialized. They had originally predicted that a lot of the devices in our homes and outdoor sensors would all be subscribed to cellular – but it never happened. In the home, everything moved to free WiFi, which became overabundant when ISPs increased home broadband speeds, and the FCC released a gigantic pile of new WiFi spectrum in the 6 GHz band. Connecting outdoor sensors to cellular never took off because it required deploying batteries that have to be replaced.

This is not to say that we won’t ever have a shortage of spectrum. The use of wireless broadband is growing at a faster pace than home broadband. While it’s still only a tiny fraction of all broadband usage, the inexorable impact of annual growth will mean that new spectrum will be needed.

One of the biggest controversies with mid-range spectrum is that much of it is use by various parts of the military and government. The process of relocating government users to different spectrum bands is costly and takes many years. Government users often make a convincing case why they should be allowed to continue to use the spectrum they have.

If there is any place where there is a spectrum shortage, it’s in rural America. This is not due to a lack of available spectrum – but of spectrum that they owners are willing to share. Carriers generally buy spectrum to satisfy their needs in urban areas. Bands of spectrum that might be full and business in a city likely sit fallow and unused in rural areas where there is no demand. There are huge amounts if mid-range spectrum that are not in use in most rural markets.

Cellular carriers could share spectrum. We see that happening with CBRS where spectrum holders in rural areas are required to allow others to use the spectrum when it’s not in use. But spectrum owners won’t do this voluntarily because it adds to their costs. The FCC has to act to require spectrum sharing on any given band of spectrum. In FCC filings, the cellular carriers argue strongly against requiring more sharing – and they would like to curtail what is already allowed.

Pushing Back Against Municipal Broadband

As a cautionary tale to any city that provides broadband, the incumbent ISPs are always going to push back on city initiatives. The following is a story from the summer that slipped off my radar. The city of Tucson, Arizona, launched a free wireless network to bring broadband to students in homes without broadband. As would be expected, the incumbent cable company, Cox Communications, fought against the city-provided broadband.

The city recognized the need for the network when it got requests for over 7,000 wireless access points from students during the pandemic. The city decided that the best long-term solution to the large numbers of unserved students was to create a private network using CBRS spectrum. We tend to think of municipal wireless networks as slow, but the city’s network rivals the broadband speeds offered by other cellular carriers in the city.

The city is using 4G LTE technology, which provides for the same indoor coverage as received by cell phones. The city identified 20 square miles of the city with the greatest number of students without home broadband. The initial network consisted of 40 small cell sites, and there are plans to add more. Broadband is received in the home through a typical cellular receiver and a SIM card that identifies the network. Broadband speeds are more than adequate to support a single student with download speeds over 50 Mbps and upload speeds over 3 Mbps. This network avoids the problem of having multiple students in a household sharing the network because it provides a receiver for each student.

The network has some interesting features. It supports basic network slicing which gives the school board the ability to prioritize school broadband traffic over other uses by students. The city is now looking at how to use this network for smart city purposes since the network provides broadband everywhere. The city is considering using the technology for monitoring the water system (critical infrastructure in arid Tucson), for providing ubiquitous broadband in parks, for connecting to all firefighters and other first responders, and for controlling traffic lights.

As might be expected, Cox Communications, the incumbent cable company, pushed back against the city network. When the wireless network was first discussed publicly, Cox made a proposal to provide 10 Mbps broadband to students in some selected parts of the city. When told that the wireless network would be delivering speeds of at least 50 Mbps, Cox countered that it would also be able to match the higher speed. But the first Cox offer is typical of most cable company low-income broadband programs – the speeds offered are far slower than what is delivered to a basic broadband customer.

Cox also sent a letter to the Tucson city council that warned about the problems that would be caused by broadband competition from the city. The letter included the same refrains we have seen elsewhere. The city shouldn’t be competing against the public sector. Cox warned that the city would have a hard time maintaining its new network. Cox also offered to partner with the city to build broadband in parts of the city not reached by Cox (with the city paying for the expansion).

I’m not sure that we should expect incumbents to act differently. As the cable company, Cox has a virtual monopoly on broadband since Cox largely competes only against DSL – and monopolies always fight to maintain monopoly power. Cable companies fight against all competition. They try every trick in the book to delay new commercial ISPs from building networks. But cable companies roll out a full press against city initiatives because they hope there is a political pressure point that will cause the city to reconsider. They know it’s a smart tactic because there are many cities that have canceled broadband plans after heavy lobbying by the incumbents.

In this case, the city didn’t back down and has launched the first phase of the wireless network. This became much easier for the city to finance after it received ARPA money from Congress that can be used to pay for broadband infrastructure. I am positive that the city will derive huge benefits from this network far past the day when the pandemic is behind us.

CBRS Auction Winners

The FCC held a recent auction for the  3.5GHz Citizens Band Radio Spectrum (CBRS). The auction went for 76 rounds and raised over $4.5 billion for the FCC. This auction was unique in that spectrum was licensed at the county-level awarding up to seven licensed 10 MHz channels in each county. Each PAL (Priority Access License) is good for 10 years.

CBRS spectrum can be used in several applications. The spectrum has good field operating parameters and falls in the middle between the two existing blocks of spectrum used for WiFi. This makes the spectrum ideal for rural point-to-multipoint fixed wireless broadband since it can carry a decent amount of bandwidth for a decent distance. The best aspect of this spectrum is that it’s licensed and will largely be free from interference. For the same reasons, this is also a good spectrum for cellular data.

The biggest winner in the auction was Verizon which spent $1.89 billion on the spectrum. The company landed 557 PALs licenses in 57 counties. The company needed this spectrum to fill-in mid-range spectrum for 5G. Verizon has also recently announced a fixed cellular broadband product for rural homes and this spectrum could provide an interference-free way to deliver that product from rural cell sites.

As expected, Dish networks was also a big winner and will be paying $913 million for CBRS spectrum. As the newest nationwide cellular carrier, the company needed this spectrum to fill in the holes in the cellular spectrum it already controls. The other traditional cellular companies were a no-show. AT&T didn’t buy any of the CBRS spectrum. T-Mobile only purchased 8 PALs licenses in six counties.

The largest cable companies scored big in the auction. Charter bought $464 million of spectrum, Comcast is paying $458 million for spectrum, and Cox purchased $212 million of spectrum. As the newest entrants in the cellular business, Comcast and Charter have been buying wholesale cellular broadband from Verizon – this spectrum will let them shift to their own cell sites for a lot of cellular traffic. There is also speculation that cable companies might be planning on using the new spectrum to launch a fixed-wireless product in the rural areas surrounding their cable properties. Both Charter and Cox have entered the upcoming RDOF auction that is awarding $16.4 billion for rural broadband and the companies might be planning on using this spectrum to cover any areas they can win in that reverse auction.

One of the smaller cable companies, Midcontinent Communications, spent over $8.8 million for PALs licenses. Midco already won sizable rural grants to deploy 100 Mbps broadband in Minnesota and the Dakotas. This spectrum will help the company meet those grant pledges and perhaps allow it to pursue RDOF grants.

There were a few other large bidders. One was Nextlink which provides fixed wireless broadband today in Texas, Oklahoma, Kansas, Nebraska, Iowa, and Illinois. Windstream purchased over 1,000 PALs and the traditional telco is likely going to replace aging rural copper with wireless service, while also possibly be expanding into new service territories with fixed wireless. SAL Spectrum LLC won 1,569 PALs. This company owns numerous other blocks of spectrum and it’s not clear who the user of this new spectrum might be.

The biggest news is that the auction allowed smaller bidders to win licensed spectrum. There were 228 different winners in the auction, most of which are small WISPs, telcos, and electric cooperatives. These entities benefited by the FCC’s willingness to auction the spectrum at the county level. Most previous wireless spectrum was allocated using much larger footprints, which kept small bidders from acquiring spectrum.

FCC Modifies CBRS Spectrum Rules

The FCC adopted Report and Order 18-149 that modifies the rules for using the 3.5 GHz spectrum band known as the Citizens Broadband Radio Service or CBRS. This is a huge swath of spectrum covering 150 MHz between 3550 and 3700 MHz. This order initiates the process of activating the spectrum for widespread use. This spectrum sits in the middle between the two WiFi bands and has great operating characteristics for wireless broadband.

The FCC plans to auction 70 MHz of the spectrum in June 2020 while authorizing the remaining 80 MHz for public use. In all cases, the spectrum must be shared with the military, which gets priority access to the spectrum at any time.

The spectrum also must be shared among users – something that will be monitored by authorized SAS administrators. The FCC named five administrators in the docket: Amdocs, CommScope, Federated Wireless, Google, and Sony. The administrators must report back to the FCC after 30 days to report how their software is handling the tracking and sharing of the spectrum.

The FCC changed their original plans for the auction and use of the spectrum that was originally proposed in 2015. The size of a license footprint is now set at the county level rather than the smaller census blocks. Licenses will now be issued for 10 years with a provision to renew instead of 3 years. Small businesses and rural bidders can get bidding credits. The FCC is also establishing a secondary market by allowing license holders to sell or lease the spectrum to others.

Of most interest to rural carriers are the bidding credits. Small businesses with gross revenues less than $55 million will get a 15% bidding credit. Very small businesses with annual gross revenues under $20 million will get a 25% bidding credit. Rural carriers with less than 250,000 customers will get a 15% credit. There will be additional credits given for serving tribal lands.

Much of the public comments in the docket centered on the size of the service areas. The FCC had originally considered using census blocks, reasoning that rural carriers could pursue reasonably small licenses for offering rural fixed wireless. The cellular carriers wanted much larger areas referred to as partial economic areas (PALs). The FCC finally chose a license size in the middle, using county borders.

The spectrum in each county will be auctioned off in seven 10-MHz bands. Any bidder will be limited to using no more than 4 of the bands, or 40 MHz of spectrum. Interestingly, the ability to lease spectrum from others might mean that a wireless carrier could put together even a bigger swath of the spectrum.

The auction is going to be interesting to watch to see who shows up to bid. The cellular carriers have said that this spectrum is key to their mid-band 5G plans. The industry was already anticipating this order and this spectrum is already built into the new iPhone and a few other devices. The cellular carriers have plans to heavily use the 80 MHz of public spectrum, and they will certainly also chase the licensed spectrum in urban counties. We’ll have to see if they have any need or interest to pursue the licensed spectrum in rural counties, where one might think that the public bands of CBRS ought to satisfy their needs. If the big companies pursue the rural bands, they can drive prices up, even considering the rural company bidding credit.

Spectrum licenses have historically been awarded for much larger footprints and it will be interesting to see how awarding spectrum at the county level will impact the auction. There are already rural carriers using the public portions of the spectrum for fixed wireless service. What is unknown is how much the cellular carriers will also use the public spectrum in rural places, perhaps making the public band too crowded for getting the best use of fixed wireless. WISPs will likely prefer licensed spectrum if they can get it affordably since there will be zero interference. We’ll also have to see if many WISPs will have the financial wherewithal to pursue licensed spectrum.

One of the most interesting aspects of the order is allowing spectrum buyers to lease or sell spectrum. I fear this provision will attract speculators to the auction, which could drive up the cost of buying spectrum and also then drive up the cost of leasing the spectrum. But this also might give small ISPs that couldn’t qualify for the auction the ability to use licensed spectrum.

Another Spectrum Giveaway?

It looks like the FCC might finally be ready to move forward with a plan for Citizens Band Radio Service (CBRS). In what seems to be the repeated theme of the current FCC, the rules for awarding the spectrum heavily favor the big carriers.

The FCC has been wrestling with the disposition of this spectrum for years and it’s not hard to understand why. The spectrum sits between the two current WiFi bands and is ideal for data transmission. This band of spectrum would be a huge boon for rural broadband. The 150 megahertz of spectrum could be leveraged to greatly increased fixed wireless data speeds from WISPs. If the spectrum was fully made available for rural fixed wireless broadband we could see foxed-wireless data speeds increased to hundreds of Mbps.

But the spectrum is also ideal for 5G cellular data. This is the kind of bandwidth that cellular carriers need in urban areas if they are going to try to boost cellular speeds to the target of 100 Mbps set by the 5G standards. Additionally, the width of this band of spectrum makes it ideal for communicating with huge numbers of IoT devices using the 5G capability of slicing spectrum into tiny or large bands as needed for an individual application.

This is obviously not an easy decision for the FCC which is why the determination of how to use the spectrum has dragged on for years. They’ve had a wide range of proposal in front of them for how to allocate the spectrum. The big cellular companies have always urged having an auction for the spectrum with licenses covering large geographic areas as has been done with most other cellular spectrum.

The small wireless carriers and rural broadband advocates have been urging a solution that would provide bandwidth for rural broadband while also satisfying the needs of the urban 5G carriers. They’ve lobbied for licensing at least some of the spectrum to areas as small as a census blocks while also promoting spectrum sharing so that multiple license holders can coexist on the spectrum. Under their plan both the rural WISPs and the cellular carriers in towns could use the spectrum, with little overlap.

It looks like we’re nearing the end of the debate and as usual, the large carriers appear to have won. FCC Commissioner Michael O’Rielly recently released a document that proposes to auction the spectrum off with the license footprints defined as county boundaries. Another boon to the big ISPs is lengthens the term of the licenses from 3 years to 10 years and allows licenses to be renewed. He’s also proposing that county bids can be ‘packaged’, allowing bidders to go after multiple counties with one bid. His article makes it sound like the spectrum will be released next year, so I have to assume that a majority of FCC Commissioners are on board.

He makes his plan sound like a compromise between the interests of small and large wireless providers. However, we know from past practice that the big wireless carriers will buy all of the spectrum in counties with any sizable population centers and remove those counties from the market for smaller carriers. It’s even unlikely that WISPs will win many licenses in mostly rural counties since there are usually well-heeled speculators that buy spectrum with the hopes of selling it for more later.

The FCC could have chosen to deploy this spectrum in a way that could have helped to solve the rural broadband gap. We know that the availability of bandwidth drops off rapidly at the edge of towns and cities. This means that for most of rural America the best broadband solution for now is fixed wireless. The proposal to license spectrum by census block was somewhat complicated, but it would have made this spectrum available in rural America where it is badly needed.

We know that cellular carriers don’t share or license their spectrum to others. There is a lot of existing licensed spectrum owned by the cellular carriers that sits empty and unused in rural America. The FCC is squandering away another opportunity to provide the bandwidth needed to provide robust broadband in rural areas. The cellular carriers will buy most of the CBRS spectrum and will use it to enhance cellphone broadband in towns and cities – an admittedly great use of the spectrum. Yet two miles outside of towns the spectrum will sit unused, when it could be providing 100 Mbps broadband to the residents there. It’s frustrating and perplexing that the FCC won’t require spectrum sharing in places where the license holders aren’t deploying it – not only for CBRS spectrum, but for all licensed spectrum.