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The commercialization of Citizens Broadband Radio Service (CBRS) in January 2020 has not only opened up new wireless spectrum for sharing, it has also enabled the rapid innovation and expansion of wireless communication technologies.

CBRS gives Wireless Internet Service Providers (WISPs) the ability to expand coverage and capacity, enter new markets, and deploy LTE-grade wireless services at price points comparable to Wi-Fi. With CBRS, WISPs finally have a high-speed, low-cost solution for serving customers in outlying communities and growing revenue through new high-performance wireless services.

To capitalize on these benefits and in order to be compliant with FCC regulations, many WISPs must migrate their operations from the existing Part 90 service (3650-3700 MHz) to CBRS Part 96 (3550-3700 MHz) before October 17, 2020.

Figure 1 shows Part 90 channels that were opened up for Part 96 sharing.

Fortunately, migrating to Part 96 is neither as costly, nor as difficult, as other wireless infrastructure upgrades. Due to the low-cost deployment model offered by spectrum sharing, WISPs are able to quickly realize ROI from their infrastructure investments. Meanwhile, CBRS deployment partners like Federated Wireless are available to help WISPs efficiently navigate the migration process and build new competitive advantages faster.
This white paper aims to help you navigate the migration process and give you a clear roadmap to successfully deploying new CBRS services.

The Business Case for Part 96 Migration

The American Broadband Wireless Access (BWA) industry is projected to serve up to eight million subscribers in 2021. This necessitates upgrades in terms of operations (the type of spectrum deployed) and solutions (high-speed Internet coverage for use cases like video surveillance and energy management).
We have condensed the current situation for WISPs—and the advantages you can reap by migrating to CBRS—into the figure below.

Figure 2 shows that migrating to Part 96 within the stipulated deadline grants positive short-term and long-term impacts

The Technical Considerations for Part 96 Migration

From a network architecture perspective, not very much is different between Part 90 operations and CBRS operations. CPEs (customer premise equipment) are still deployed on customer premises and provide network access through a base station.

General principles of radio frequency (RF) planning and design still apply in CBRS. The same tools you use to model the propagation and pathloss of your Part 90 sites apply to CBRS. Therefore, it does not require new tools to plan your CBRS equipment.

The differences between Part 90 and CBRS operations lie in the infrastructure required to share spectrum. Spectrum assignments must be obtained from a Spectrum Access System (SAS). A SAS administers use of the 3550-3700 MHz spectrum and enforces the Federal Communications Commission (FCC) Part 96 rules, and compliance to the rules and associated standards is certified by the FCC as well. The SAS is a cloud-based service accessible via a URL from any endpoint that has access to the Internet.

The Carmel Group. (2017). Ready for Takeoff: The BWA Industry Report 2017. Carmel: The Carmel Group. Retrieved from

https://www.carmelgroup.com/: https://carmelgroup.com/wp-content/uploads/2017/12/TCG_2017_BWA_Full_Report.pdf

Part 96 Migration Made Easy

Given its many benefits, migrating to CBRS is an easy decision for most WISPs. Yet, it comes at a time when WISPs face the additional challenges raised by Covid-19, along with tight budgets and a short transition period.

At Federated Wireless, our goal is to help WISPs like you capitalize on new shared spectrum opportunities as easily as possible. We have formulated a 3-stage roadmap and a high-level checklist to help you mitigate migration issues and effortlessly navigate the upgrade process.

The roadmap is separated into three stages (Pre-Migration, Migration, and Post-Migration), and each stage is supported by important components that must be addressed for a smooth transition.

Stage 1: Pre-Migration

Check License Status

Check the status of your Part 90 license at

https://www.fcc.gov/wireless/systems-utilities/universal-licensing-system. For most Part 90 licensees, the date by which they must transition to Part 96 is October 17, 2020.

For Part 90 licenses that were issued or renewed after January 8, 2013, the right to operate under Part 90 extends until October 17, 2020, regardless of when the license expires. For Part 90 licenses that were issued before January 8, 2013 and registered and received grandfathered status, the right to operate under Part 90 and protection of your equipment from harmful Citizens Broadband Radio Service.

If you have not registered your operations with the Universal Licensing System (ULS), you cannot register them now to automatically get GWBL rights.

Devices (CBSDs) interference will end on the transition deadline, which is when the license expires for most licensees.

Test Equipment

Once you’ve selected a CBRS radio vendor, test and certify all your equipment against factors like the ability to connect to a SAS, power limitations, RF operating range, and out-of-band emissions to ensure that they comply with Part 96 rules. Understand your equipment manufacturer’s current and future support of CBRS. In some cases, a software update of your current equipment will allow you to migrate to CBRS.

Look for a migration solution partner that performs interoperability testing and certification with base station/access point/eNodeB and CPE
vendors. We have over 40 radio partners who are pre-integrated with our SAS. You can see the full partner list at federatedwireless.com/partners/.

Understand Technical Landscape

Part 96 migration will be smoother with a thorough understanding of its rules and regulations. Check out resources for CBRS from WInnForum standards page and CBRS Alliance websites. This will enable you to create the technical landscape most suitable for your operations.

Our CTO and Operations teams at Federated Wireless are experienced at navigating the migration process and have resources available to help. We
also have a support portal and active community available with answers to questions at myfederated.federatedwireless.com.

Get Certified Professional Installer (CPI) Training

Training ensures that your team is ready to design, deliver, and manage your organization’s CBRS network. Good migration solution partners provide training for important aspects of CBRS like architecture, regulatory compliance, and CPI requirements.

The certification process is important as it ensures the integrity of equipment installation, thereby making an efficient use of the spectrum. We offer CPI training so that your team members can certify your outdoor CBRS radios as required by Part 96 rules. You can find more details at federatedwireless.com/certified-professional-installer/.

Stage 2: Migration

Activate SAS Subscription

A SAS subscription authorizes your CBRS radios to connect and operate on CBRS spectrum under full compliance with Part 96 rules. While you can choose your SAS provider independently, you can also partner with one through your radio vendors. At Federated Wireless, we charge a competitively priced monthly subscription fee per wireless link for access to CBRS spectrum services. Using that access, register your CBRS radio to your SAS account.

Choose a SAS provider with an active Environment Sensing Capability (ESC) network available to ensure dynamic interference protection from incumbent CBRS users, especially in coastal areas. The Federated Wireless Spectrum Controller combines SAS and ESC functionality in one solution and is available today. We provide an easy sign-up process to subscribe to our SAS myfederated.federatedwireless.com/customerregistration

Map Out Deployment Locations

Within your operating location, consider whether one or more Priority Access Licenses (PALs) are required to deliver wireless broadband service to your end users. In many rural areas, General Authorized Access will be sufficient to offer robust service. In more dense areas, you may want to supplement your service with PALs for combined stable operations.

Since CBRS is based on a “use it or share it” principle, every WISP will have enough spectrum to support future deployments

Create a Service Interruption Contingency Plan

Spectrum migration might cause service disruptions (e.g., slow or no connection) to your customers. Create a contingency plan to ensure that your customers have the connectivity they need throughout the migration process.

Federated Wireless can help you set up scripts for your network environment that allow you to smoothly upgrade your network.

Stage 3: Post-Migration

Test CBRS Network Elements

Examine how migrating to CBRS changes the way you operate in terms of tools and processes. You may need to test and alter existing firewall and Network Address Translation (NAT) policies for best operations. CBRS equipment and SAS have gone through extensive FCC certification trials, so you do not have to conduct more interoperability tests. If you do, focus your testing efforts on systems unique to your environment.

Ensure that all your network monitoring mechanisms are working well, and the Internet connectivity between CPE and the SAS, as well as between your radios and the SAS, is maintained. If you are operating in a coastal area, the SAS is required to suspend operation of specific channels sometimes to protect naval radar operation. Such interruptions may occur but can be mitigated by requesting grants for other channels in the band in order to continue service.

Federated Wireless operates and monitors your network 24x7. You may want to deploy additional alarm mechanisms to monitor your channels of operation and the status of operation of your radios.

Update Service Plan and Pricing

Determine how you will bill and charge customers for CBRS service

With 100 MHz of additional spectrum available, CBRS allows you to offer higher speeds and innovative services to customers willing to pay a premium over a standard service.

Part 90 to Part 96 Migration Checklist

Keep in mind that each migration process is unique and the order in which you address these items may ultimately vary depending on the specifics on your deployment.

Stage 1: Pre-Migration

Getting your fixed wireless operations ready for migration
Consider getting CPI training for your team so that they can certify that your outdoor CBRS radios comply with Part 96 rules.
Understand Part 96 rules before building the technical landscape most suitable for your operations.

Stage 2: Migration

Transitioning the bulk of your operations to CBRS
Create a contingency plan that can alleviate the effects of service disruption while you are migrating to Part 96.
Activate your SAS subscription. This will enable your CBRS radios to connect and operate on CBRS spectrum.
Map out deployment locations based on both GAA and PAL; consider supplementing your GAA with PAL in dense environments.

Stage 3: Post-Migration

Making sure that your newly migrated operations are functioning well
Test CBRS network elements (e.g. firewall, NAT policies, monitoring mechanisms) to ensure smooth operations.
Update your fixed wireless solutions based on expanded CBRS capability and determine how you will charge your customers.


Citizens Broadband Radio Service is poised to increase spectral efficiency, support the rapid growth of wireless data, and become the basis for more exciting communication technologies. With the right CBRS solution partner, you and your customers will benefit from a successful Part 96 migration.

At Federated Wireless, we are the partner of choice for all things CBRS. We are an industry pioneer with deep standards knowledge and a robust Spectrum Controller (SAS) platform with an integrated, standards-based ESC sensor network.

Contact us to get your free Part 96 migration assessment or to learn more about our CBRS solutions.

Frequently Asked Questions (FAQs)

About Citizens Broadband Radio Service (CBRS)

The unique differentiator of CBRS is that 150 MHz of the spectrum is shared among the three-tiered users through the SAS and ESC. This spectrum sharing mechanism is expected to be replicated in other bands in the future to support rising communication needs.

For those Part 90 licensees who have transition deadlines on October 17, 2020, your use of the 3650-3700 band will no longer be allowed under FCC rules. Operators desiring to continue operations in this band must register their BTS-CBSD(s) and CPE-CBSD(s) with a SAS.

Yes, you can request a waiver of the deadline from the FCC. The waiver request must show the following:

(1) the licensee’s good faith efforts to purchase, install, and test the necessary upgrades or equipment required to operate their networks pursuant to part 96 prior to the transition deadline.

(2) the unique or unusual circumstances that prevented them from completing the part 96 transition by October 17, 2020. and

(3) the specific steps—including the time required to complete those steps—that the licensee will take to complete its transition expeditiously..

There are two categories of equipment for CBRS which are Category A CBSDs and Category B CBSDs.The former is lower powered (maximum 1 Watt) that must be installed indoors at or below six-meter Height Above Average Terrain (HAAT). The latter is high powered (maximum 50 Watt), can only be operated outdoors (no height limit), and must be installed by a CPI. In addition, any Category A device that is installed above the height limit and/or unable to geolocate requires CPI.

From a network architecture perspective (e.g. RF planning and design, propagation and pathloss tools,CPEs), not very much is different between Part 90 and CBRS operations. The unique differentiator lies in the infrastructure used to obtain and share spectrum (SAS/ESC).

About the Spectrum Access System (SAS)

It is an automated frequency moderator that dynamically manages spectrum and interference between the three tiers of access:

Tier 1: Incumbent users such as the federal government, fixed satellite service (FSS), and GWBLs who are protected until their current licenses expire. Incumbents have the highest priority and receive full protection against interference from Tier 2 and 3 users.

Tier 2: Priority Access License (PAL) users are those who have acquired spectrum in a specific county through auction. They must protect and accept interference from Tier 1 users but receive protection against Tier 3 users

Tier 3: General Authorized Access (GAA) users are licensed-by-rule and have access to the full spectrum when not in use by the users from the first two tiers. They must protect Tier 1 and 2 users from interference and accept interference from them

It is a sensor network that detects radar activity from the Department of Defense (DoD) and transmits that information to the SAS for dynamic shared spectrum management. Today Federated Wireless provides the only nationwide ESC network, giving full access to 150 MHz of spectrum in most locations.
The Federated Wireless Spectrum Controller (SAS/ESC) is a cloud-based service accessible via a URL from any endpoint that has access to the Internet.

The operations information that the SAS needs to dynamically manage the spectrum include CBSD-ID, antenna characteristics (e.g. height and location), EIRP capability, and potential interference levels. User data and other personally identifiable information (PII) like customer names will not be collected and shared.

About Federated Wireless

Founded in 2012, Federated Wireless has long led the industry in development of shared spectrum CBRS capabilities. The company took a lead role in the formation of the CBRS Alliance, was the first to complete a wide range of trials with its Spectrum Controller, and deployed the industry’s first nationwide ESC network.

Federated Wireless has an open, neutral approach to CBRS deployments and is committed to making each deployment successful. When you choose Federated Wireless, you will have access to a complete ecosystem of partners, a powerful SAS/ESC platform, and a dedicated 24/7 support portal. Federated Wireless also offers an online training course that can help you become a CPI in accordance with FCC rules.

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