What are Protection Sites?
by Sprint 4G Rollout Updates on Sunday, July 24, 2011 at 10:01am
You keep reading around S4GRU about "Protection Sites." But what are protection sites, you ask?
Sprint broadcasts it's 4G WiMax signal on 2.5GHz-2.65GHz (along with it's partner Clear/Clearwire). That's up to 150MHz of spectrum (variable by market). More than any other carrier in the country.
Before 2007, 2.5GHz-2.65GHz was allocated by the FCC as EBS and BRS spectrum (Educational Broadband Service/Broadcast Radio Service). EBS was used by any public education organization free of charge on a first come, first served basis. However, this spectrum was relatively little used. At it's peak, only 100 education institutions actually utilized the spectrum for educational purposes. Most actually leased their spectrum to Clearwire for their pre-WiMax network.
This was deemed a huge waste of spectrum by the FCC (and it was). When you consider the entire population of the U.S. and the total data capacity of the EBS spectrum, it was not even 1/100th of 1% utilized!
In 2004, the FCC decided to reallocate the EBS/BRS spectrum for mobile internet and gave notice to the EBS/BRS license holders that in 2007 they would be repurposing the spectrum. EBS license holders could reapply with the broadband carriers in the 2007 reallotment. It was a confusing mess. In reality in the way it was structured, EBS spectrum winners were subleasing spectrum from the schools and universities. BRS spectrum licenses were purchased outright.
In 2007 the EBS spectrum went out for bid. Two bidders ended up with the lion's share of the 150MHz of spectrum...Sprint and Clearwire. Sprint ending up with 60MHz of nationwide coverage. Clearwire with 90MHz of nationwide coverage. One of the conditions to the bidders is a clause called "Minimum Coverage Standards."
For the EBS Spectrum, the FCC breaks up the 50 States and U.S. Territories into approx. 500 Basic Trading Areas, or BTA's (In other wireless spectrum, they use CMA's, or Cellular Market Areas). They use these to manage licenses for EBS spectrum. Licenses for each BTA are good for 10 years upon issuance. At 10 year intervals, they need to be renewed. At renewal, service provided is evaluated by the FCC. 99% of all renewals are approved. Some carriers have spectrum in all the BTA's (or CMA's). Some only have regions. Some have regions in one set of spectrum and other regions in other sections. It can be very messy and confusing to track FCC licenses.
In 2008, Sprint and Clearwire received FCC approval and merged their EBS/BRS spectrum holdings into a singular holding of the 150MHz block and formed the joint-venture company Clear.
Back to the Minimum Coverage Standards. The FCC mandated that a minimally acceptable amount of coverage be in every BTA by May 1, 2011. Clearwire started rolling out protection sites in earnest in early 2011. However, did not meet the Minimum Coverage Standards in all BTA's by May 1st, and started filing for extensions.
FROM CLEARWIRE 2010 ANNUAL REPORT:
The FCC also clarified the procedure by which BRS and EBS licensees must demonstrate minimum acceptable service, and required them to demonstrate minimum service by May 1, 2011. Minimum service showings demonstrate to the FCC that a licensee is not warehousing spectrum. If a BRS or EBS licensee fails to demonstrate minimum service by May 1, 2011, its license may be canceled and made available for re-licensing.
For our spectrum, we believe that we will satisfy the substantial service requirements for all owned and leased licenses associated with each of our commercially launched markets, whether Pre-4G or 4G. For licenses covering areas outside of our commercially launched markets, we are in the process of executing a (Protection Site Plan) to comply with the minimum service requirement by the deadline. Our ability, however, to meet the minimum service deadline for every owned or leased license in areas outside of our launched markets is uncertain, and we will likely seek waivers or extensions of the deadline from the FCC in some circumstances.
Any winning bidder who did not provide minimally acceptable service within a BTA, will be subject to having the license revoked and the original license holder will be unable to ever regain it.
This is very strong language about revocation. Minimum acceptable coverage to the FCC for this spectrum is:
- 30% of the BTA's Population Has Useable Service, or...
- 50% of the Geographical Area (Square Mileage) of the BTA has Useable Service.
Sprint/Clear 4G Basic Trading Area (BTA) Map showing all 500 BTA's in the U.S. The ones in green have at least (1) Sprint/Clear 4G tower in operation. The ones in white have no Clearwire service in operation.
In the map above, you can see all the 500 BTA's in the United States. What Sprint/Clear have decided was to put up at least one tower every in every BTA in the country. So in 2011, they broke from the conventional rollout. They are deploying "Protection Sites" in all the BTA's. These are sites intended to keep the FCC at bay with the intention of trying to meet minimum acceptable service to maintain licensing.
It appears that in larger population BTA's (250k+), they are deploying more than one protection site to meet the 30% population coverage minimum.
Sprint/Clear are well on their way to being complete with the BTA Protection Site rollout before the end of 2011. They are averaging about 7 to 10 towers per week. So largely the areas in white will all be filled in green in short order. There will be a few exceptions. BTA's that have Clearwire's Pre-WiMax technology (like Reno, Dayton and Anchorage) will not receive protection sites. They already meet the FCC Minimum Coverage Requirements as the Pre-WiMax is broadcast on the same 2.5GHz spectrum.
Most likely, the FCC will not give Sprint/Clear any grief over the minimum service clauses because they are attempting to do something. The clause is largely to prevent people from buying the spectrum and just sitting on it as an investment. The FCC really wants it just to be used. Most likely, the extension for Minimum Coverages will be given.
The service requirements on the 700MHz spectrum are far more stringent than they were on the 2.5GHz spectrum. Verizon, AT&T and MetroPCS have less time to roll out. And the terminology used in it's FCC licensing doesn't have vague words like "minimum acceptable", but rather "substantial coverage."
