While some smaller entities—and bigger ones like Google and GE—say certain proposed changes to the Citizens Broadband Radio Service (CBRS) only favor the big wireless carriers, T-Mobile argues that the proposed changes in front of the FCC are actually beneficial to a diverse set of players.

Last year, T-Mobile asked the commission to take another look at how the CBRS 3.5 GHz band is structured, mainly around the size of Priority Access License (PAL) geographical areas and duration of the licenses. CTIA also made a similar bid, and the FCC late last year drew up a Notice of Proposed Rulemaking (NPRM) seeking public comment.

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A slew of entities have filed comments critical of the proposed changes, but T-Mobile and its wireless operator brethren in the U.S. are standing firm. They say that things have changed so much in the past couple years as 5G has emerged that the commission has an obligation to re-examine its rules when they’re no longer serving the public interest.

And the assertion that changing the rules will strand investments in the band—investments that were made based on the understanding of how the rules were formulated? T-Mobile says the FCC should reject claims by the Wireless Internet Service Providers Association (WISPA) and others that the changes will do that.

“No investments made in reasonable reliance on the current rules will be stranded as a result of the Commission’s proposals,” T-Mobile said in its Jan. 29 filing. “The only meaningful investments in the band were made by the entities that may act as a SAS or ESC. Those investments, as well as any investments in technology, will be preserved.”

T-Mobile also said that the larger license sizes it favors will not foreclose use of the 3.5 GHz band by smaller providers. In fact, larger license areas would maximize deployment by providers of all sizes, and on top of that, it’s more spectrum efficient. In larger licensed areas, it is less likely that there will be another licensee’s CBRS device nearby, providing additional flexibility to site devices near the border with full power.

The “uncarrier” also asserts that smaller license areas will make it more challenging for the Spectrum Access System (SAS) administrators to manage the spectrum, in part because channels will be reused less frequently. And with less channel reuse, that means fewer channels will be vacant for potential General Authorized Access (GAA) operations.

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Federated Wireless, one of the companies positioning to serve as a SAS administrator, reiterated its desire to see the commission move ahead on the CBRS band and get final certification of SAS administrators and Environmental Sensing Capability (ESC) operators done by June 30, 2018.

As soon as GAA operations commence, CBRS users will be able to provide consumers up to 150 MHz of additional bandwidth. “Consumers and businesses in unserved and underserved locations, in rural areas, and in buildings and campuses that lack robust, high-quality connections, all will benefit,” Federated said in its filing (PDF).

But Federated also acknowledged the divide among stakeholders about whether secondary market mechanisms will work for CBRS, and it says the SAS administrator will serve several important secondary market functions that are not available in other bands, which should encourage and facilitate frictionless leasing.

In addition, there are fail-safes inherent in CBRS spectrum because of multiple PAL licensees and access to GAA spectrum, supporting more flexible, shorter-term leases, which will encourage licensees to lease their spectrum while protecting the opportunities of the lessee.