FCC Resources - NPRM on Transforming the 2.5GHz Band – Reply Comments Due September 7, 2018

On August 8th, NEBSA and CTN, on behalf of their respective associations (or memberships), have filed Joint Comments to the FCC which addressed numerous important EBS issues in response to the Notice of Proposed Rulemaking on Transforming the 2.5GHz Band.

NEBSA urges membership to be involved by joining a group filing reply comments (you should check with your FCC attorney about that), or by filing your own individual comments in support of the positions taken by the NEBSA and CTN Joint Comments.

If you decide to file on your own, there are two “online” methods of doing so.   One method allows for a short message to be filed directly to the FCC's Electronic Comment Filing System (ECFS).  The other method allows prepared written comments which are then uploaded to the ECFS.

Should you wish to make reference to a particular issue in the filing, we are also providing a summary of the key points addressed in the NEBSA-CTN filing.   We also encourage licensees to include a brief statement showing how EBS is benefiting your institution and community in any supporting comments.  

If you have further questions about the Reply Comment process or how you can support NEBSA, please contact

Thank you for your support!

Lee Solonche
Executive Director, NEBSA

Filing Reply Comments

File a Short Written Message:

One method is to type in a short message of support directly into the FCC’s Electronic Comment Filing System (ECFS).  To do so, you would go to and type in “18-120” in the Proceedings line and choose “Transforming the 2.5 GHz Band” in the resulting drop down menu.  Type in the requested contact information and type in your message in the box called “Brief Comments.”  Click on “Continue to the review screen” to make the filing.

File Prepared Written Comments:

The second method is to prepare written comments which will then be uploaded to the ECFS.  To do so, you would go to and type in “18-120” in the Proceedings line and choose “Transforming the 2.5 GHz Band” in the resulting drop down menu.  Type in the requested contact information and upload your comments in the appropriate box.  Click on “Continue to the review screen” and then make the filing.

Summary of Joint Filing

The National EBS Association and the Catholic Technology Network, on behalf of the EBS community, have filed Joint Comments in response to the FCC’s Notice of Proposed Rulemaking on “transforming” the 2.5 GHz band.  These comments make the following important points:

  • Current EBS Flexible Rules Are Successful.  The FCC has already created a flexible regulatory regime for EBS that has fosters educational use and a robust secondary market for commercial broadband services.  The FCC’s forward-looking policies have ensured that commercial wireless carriers have ample spectrum for 5G services.  At the same time, these policies have provided private funding and resources for education without reliance on federal assistance or other government funding.   EBS does not need “fixing” – it needs “finishing.”  
  • Geographic Service Areas Should Be Expanded.  Existing EBS licensed GSAs should be expanded to align with those of other wireless services and natural educational boundaries.  
  • New EBS Licenses Should be Issued to New Local Educational Entities Without Auctions. New EBS licenses should be issued through a process that avoids auctions.  The FCC should limit participation in the filing windows to Tribal Nations and local educators who currently do not hold EBS licenses.  This will permit the benefits of EBS to extend to a host of new educational entities.      
  • Existing EBS Licensees and Services Should Not be Disrupted.  Given the success of the existing EBS regulatory model and the ongoing reliance on that model by educators and wireless carriers, the Commission should ensure that new rules adopted in this proceeding do not disrupt current licensees and leasing arrangements.  
  • EBS Should Not be Commercialized.  EBS licenses should not be sold to commercial entities. Licensed EBS spectrum is already being used efficiently for both educational and commercial purposes.  There is simply no need to eliminate current EBS eligibility restrictions in order to facilitate more intensive use of the band.  
  • Educational Usage Rules Can be Updated.  A modernized method of measuring educational usage might make sense.  However, it has been difficult to develop alternate metrics given the differing uses of EBS spectrum by individual licensees.    
  • Lease Term Limits Should be Retained. The FCC should retain the current 30-year limit on EBS lease terms so that educational licensees have a reasonable opportunity to reevaluate lease terms, benefits, and partner relationships over time.   
  • Reasonable Performance and Renewal Requirements Should Apply to EBS.  Performance and renewal standards for newly issued EBS licenses should be the same as those for current licenses.  The recently adopted harmonized wireless renewal standards could be applied to EBS with an appropriate safe harbor for licensees meeting EBS substantial service requirements.