Washington, D.C., – The Rural Wireless Association, Inc. (“RWA”) filed Comments in response to several proposed changes to the rules governing Priority Access Licenses (“PALs”) in the Citizens Broadband Radio Service (“CBRS”) band. Viewed favorably by nationwide mobile wireless providers, possible changes to the PAL licensing rules include a longer license term with a renewal expectancy and larger geographic license areas. RWA is concerned that these changes would limit PAL spectrum access to all but the largest carriers, and allow those carriers to warehouse spectrum as they have done in other bands.

RWA opposes the use of Partial Economic Area (PEA) license areas – noting that they are too large and expensive for small carriers. RWA suggests using a hybrid approach in which PALs in urban areas are auctioned on a Metropolitan Statistical Areas (MSA) basis and in rural areas on a census tract basis using the boundaries of Rural Service Areas (RSAs). Alternatively, RWA would not oppose the adoption of county-based PAL licenses.

RWA also opposes the imposition of a ten-year license term with a built-in renewal expectancy, explaining that lengthy terms would allow spectrum to lie fallow in rural areas in contravention of federal law. RWA urged the Commission not to adopt a term beyond five years, and explained that license terms should correlate to license size. A five-year license term, for instance, would be appropriate for county-based licenses. If, however, the Commission is determined to adopt 10-year terms for PALs, which RWA opposes, then it should preserve the census tract license areas so that spectrum can be utilized in rural America.

“RWA looks forward to working with industry stakeholders and Commission staff to ensure that any future rule changes push rural broadband deployment forward – not back,” said Carri Bennet, RWA’s General Counsel. “Large-sized license areas and decade-long license terms are a recipe for spectrum lying fallow – an outcome harmful to rural America that the Commission should endeavor to avoid.”