FCC Resources - NPRM on Transforming the 2.5GHz Band – Reply Comments Presented to FCC

On September 7th, NEBSA and CTN, on behalf of their respective associations (or memberships), have filed Joint Reply Comments to the FCC which addressed and responded to numerous important EBS issues in the Notice of Proposed Rulemaking (NPRM) on Transforming the 2.5GHz Band.

Click here to read the Joint Reply Comments.

This follows the August 8th, action of NEBSA and CTN, on behalf of their respective associations (or memberships), 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.

We are also providing a summary of important points in the Joint Comments below filed on August 8th.

NEBSA will continue to closely monitor developments related to the NPRM and the 2.5 GHz band and keep our members informed.

Thank you for your support!

Lee Solonche
Executive Director, NEBSA


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.