Memos, Resources

Grandfathered Filings Deadline

July 7, 2017

Citizens Broadband Radio Service (CBRS)

Grandfathered Protection Zones Filing Window and Procedures Announced

On April 7, 2017, the FCC released its Public Notice, DA 17‐340, in which the FCC has opened the four
month filing window for Part 90 licensees to submit the required supplemental information in order to
define their Grandfathered Wireless Protection Zones. The deadline for filing an application to secure the
Part 90 Grandfathered Wireless Protection Zones is August 7, 2017.

Background: The Federal Communications Commission (FCC) expanded the existing 50MHz of shared
spectrum in the 3650‐3700MHz (NN Service1) band by 100MHz. Combined, 3550‐3700MHz, makes
150MHz of spectrum available and has formed the new Citizens Broadband Radio Service (CBRS) band.
The FCC released its Report and Order, FCC 15‐47, in which it defined the CBRS band, introduced the CBRS
governing Part 96 rules, and sunsets the existing Part 90 rules.

As of the adoption date of FCC 15‐47, April 17, 2015, the FCC began no longer granting new non‐exclusive
nationwide (NN) Service licenses. Existing NN Service operators’ networks filed with the FCC prior to the
April 17th date, and operational by April 17, 2016, are considered Grandfathered Wireless Broadband
Providers and will receive interference protections from CBRS operations within a Grandfathered Wireless
Protection Zone for a term of five years or the remainder of their license term, whichever is longer. New
Part 90 base stations can be registered under an existing NN Service license, but these new stations will
not extend Grandfathered Wireless Protection Zone or be afforded interference protections outside the
established Grandfathered Wireless Protection Zone.

In August of 2016, the FCC released its Public Notice, DA 16‐946, in which the FCC defined the proposed
methodology for determining the protected contours for Grandfathered Part 90 licensees. DA 16‐946
details a two‐prong approach in defining the Part 90 for each eligible registered base station, as follows:

  • Sectors supporting unregistered Customer Premises Equipment (CPE) devices will receive a
    5.3km (3.29 miles) radii, confined to the azimuth and beamwidth of the antenna, as previously
    registered with the FCC.
  • Sectors supporting registered CPE devices will receive a radii sufficient to encompass the
    furthest registered and supported CPE device, confined to the azimuth and beamwidth of the
    antenna, as previously registered with the FCC.

If you have any questions or require assistance with the Grandfathered Protection Zone filings, please feel
free to contact any of the following VPS staff members for assistance:

Brian Bell, P.E. at (605) 995‐1767 or
Kristy Szabo at (605) 995‐1786 or

Download the full VPS Memo Grandfathered Filings Deadline here.