The Daily Ex Parte, July 14, 2025
CTIA w/ Comm. Trusty, WISPA on CBRS, INCOMPAS on Submarine Cable Landing, Public Knowledge & NCAI on Tribal Licensing Window
Filers
Alliance for Automotive Innovation
CTIA
INCOMPAS
Public Knowledge, National Congress of American Indians
WISPA – The Association for Broadband Without Boundaries
Alliance for Automotive Innovation
Proceeding(s): 18-89, 21-232, 21-233
Date of Meeting: July 9, 2025
Date Disseminated: July 14, 2025
Participants:
Alliance for Automotive Innovation:
Hilary Cain (Senior Vice President, Policy),
Sarah Puro, and
Tara Hairston
Federal Communications Commission (FCC):
Adam Chan (National Security Counsel, Office of the Chairman)
Summary of Discussion:
Representatives from the Alliance for Automotive Innovation met via teleconference with counsel from the FCC Chairman's office. The discussion centered on the FCC's proposal to update its Covered List. This action is in response to a final rule adopted by the Department of Commerce's Bureau of Industry and Security (BIS). The BIS rule restricts specific transactions that involve connected vehicle hardware or software provided by entities controlled by China or Russia. The meeting served as a forum to discuss the FCC's proposed update in light of the Commerce Department's determination.
Source: NOTICE OF EXPARTE, Alliance for Automotive Innovation, https://www.fcc.gov/ecfs/document/107112054005658/1
CTIA
Proceeding(s): 25-59, 25-70, 25-71, 13-185, 25-117
Date of Meeting: July 10, 2025
Date Disseminated: July 14, 2025
Participants:
CTIA:
Ajit Pai (President & CEO),
Scott Bergmann (Senior Vice President, Regulatory Affairs)
Federal Communications Commission (FCC):
Commissioner Olivia Trusty;
Krista Senell (Chief of Staff and Senior Counsel to Commissioner Trusty);
William Holloway (Legal Advisor to Commissioner Trusty)
Jessica Kinsey (Legal Advisor to Commissioner Trusty)
Summary of Discussion:
Representatives from CTIA met with Commissioner Trusty and her staff to advocate for the FCC to move quickly to allocate additional licensed spectrum for wireless services, with a focus on the Upper C-band and AWS-3 bands.
The discussion was framed by the recent passage of the "One Big Beautiful Bill Act," which restored the FCC's general spectrum auction authority. CTIA emphasized that this law provides a critical roadmap for auctions needed to meet growing consumer demand and secure U.S. leadership in 5G and future wireless technologies.
Key points discussed include:
Upper C-band (3.98-4.2 GHz) (GN Docket No. 25-59): CTIA urged the FCC to take prompt action, as the new law mandates that this spectrum be auctioned within two years. They argued for the FCC to swiftly propose rules to open as much as 220 megahertz for full-power terrestrial wireless use. CTIA noted that the successful market-driven approach used for the initial C-band transition can serve as a model for the Upper C-band. They also stressed the importance of the FCC working with other federal stakeholders to ensure coexistence with radio altimeter operations, in line with a 2027 congressional deadline.
AWS-3 Spectrum (GN Docket Nos. 25-70, 25-71, 13-185, AU Docket No. 25-117): CTIA expressed strong support for auctioning the remaining AWS-3 spectrum inventory. They called for the swift adoption of final procedures for Auction 113, highlighting it as the first FCC spectrum auction in several years. CTIA also noted that proceeds from this auction are intended to help secure America's network infrastructure, aligning with the national security goals of both the FCC and Congress.
Overall, CTIA's message was that establishing a robust pipeline of full-power licensed spectrum is essential for U.S. consumers, businesses, economic growth, and national security.
Source: [NOTICE OF EXPARTE, CTIA, https://www.fcc.gov/ecfs/document/107142348715956/1]
INCOMPAS
Proceeding(s): 24-523, 24-524
Date of Meeting: July 9, 2025 and July 10, 2025
Date Disseminated: July 11, 2025
Participants:
From INCOMPAS:
Staci Pies,
Christopher L. Shipley, and
Taylor Abshire (Attorney and Policy Advisor)
From DC Blox:
Alan Poole (General Counsel) (participated in the July 10 meeting only)
From the FCC:
On July 9, 2025, participants met with:
William Holloway and Jessica Kinsey, Acting Legal Advisors to Commissioner Olivia Trusty.
On July 10, 2025, participants met with:
Adam Chan, National Security Counsel to Chairman Brendan Car.
Summary of Discussion:
Representatives from INCOMPAS and DC Blox held two virtual meetings with staff from the offices of Commissioner Olivia Trusty and Chairman Brendan Car to discuss the Notice of Proposed Rulemaking (NPRM) concerning the Review of Submarine Cable Landing License Rules and Procedures (OI Docket No. 24-523) and the Amendment of the Schedule of Application Fees (MD Docket No. 24-524).
The discussion mirrored arguments INCOMPAS previously submitted in its filed comments and reply comments for these proceedings. INCOMPAS affirmed its members' commitment to strengthening U.S. national security through thorough security practices and by aiding federal initiatives to protect Americans' data.
The core of their advocacy urged the FCC to modernize the submarine cable licensing framework with three specific goals:
Increase Information Sharing: Foster better information exchange across different government agencies.
Create Regulatory Certainty: Establish clear and predictable rules for licensees.
Protect Investment: Safeguard the significant investments made by submarine cable operators in what they term "critical infrastructure."
Source: [NOTICE OF EXPARTE, INCOMPAS, https://www.fcc.gov/ecfs/document/107111297304910/1]
Public Knowledge, National Congress of American Indians
Proceeding(s): 25-70, 25-71, 13-185
Date of Meeting: July 9, 2025
Date Disseminated: July 14, 2025
Participants:
Harold Feld and Nat Purser of Public Knowledge (PK), and
Geoffrey Blackwell of the National Congress of American Indians (NCAI)
FCC:
Anthony Patrone of Chairman Carr's office
Summary of Discussion: Representatives from Public Knowledge (PK) and the National Congress of American Indians (NCAI) argued for the creation of a dedicated Tribal licensing window (TLW) in the upcoming AWS auction and future spectrum auctions. They asserted that such a window is a crucial part of the FCC's federal trust responsibility to Tribal Nations, which includes upholding tribal sovereignty and ensuring Tribes have a meaningful opportunity to acquire spectrum rights for economic development, public safety, and cultural preservation.
The key arguments presented were:
Federal Trust Obligation and Overcoming Barriers: A dedicated TLW would acknowledge the unique legal status of Tribes and help them overcome the significant administrative and financial barriers that prevent their participation in traditional spectrum auctions. This would provide access to airwaves needed for modern communications infrastructure, particularly in underserved Tribal areas.
Precedent and Potential: The filers pointed to the success of the prior 2.5 GHz tribal licensing window as a model. Citing analysis from the Institute for Local Self-Reliance, they noted that 176 distinct Tribal areas could qualify for AWS-3 licenses under expanded eligibility rules. Given the robust use of the 2.5 GHz opportunity, they anticipate significant network growth if a similar window is established for AWS-3.
Public Safety Imperative: Direct spectrum access is critical for Tribal public safety. It would empower Tribal governments to implement the FCC's new "Missing and Endangered Persons" alert system on their own lands, addressing the disproportionate rates of violence and disappearance in Native communities. Furthermore, it would enhance their ability to prepare for and respond to natural disasters like floods and fires, to which Tribal lands are often more vulnerable.
Rebuttal to Arguments for Delay: PK and NCAI argued that creating a TLW for the AWS auction would not cause undue delay. They stated that much of the foundational work, such as creating maps for eligible Tribal lands, is already complete. They also noted that Tribes are now more familiar with the application process due to the 2.5 GHz window, reducing the need for extensive, time-consuming outreach beyond what the FCC already provides for all auction participants. While acknowledging the complexity of an "inventory auction," they argued that the FCC staff has prior experience from the 2.5 GHz auction in handling licenses that only partially cover Tribal lands.
Specific Legal and Technical Corrections Requested:
Footnote 162: The filers strongly disputed the FCC's draft legal finding that a simultaneous auction and TLW would violate Section 309(j)(3)(E)(ii). They argued there is scant evidence that carving out Tribal lands (which bidders often do not wish to serve) meaningfully impacts bidding behavior. They urged the FCC not to adopt this broad finding, which would needlessly constrain its ability to create TLWs in the future.
Footnote 149: They noted a technical inaccuracy, clarifying that while the 2.5 GHz window was the first non-broadcast TLW, the FCC has long used mechanisms in the broadcast context to award licenses without auctions, and these mechanisms could be applied to other wireless services.
Alternative Proposal: If the FCC ultimately decides against a TLW, PK and NCAI requested that the Commission, at a minimum, include strong language in its order reminding carriers of their responsibility to serve Tribal lands. They disputed claims by CTIA that carriers are already adequately working with Tribal nations. They urged the FCC to state its intent to monitor carrier build-out on Tribal lands and its readiness to impose remedies, such as forced partitions or "use or lose" conditions, if carriers fail to provide service.
Source: [NOTICE OF EXPARTE, Public Knowledge, National Congress of American Indians, https://www.fcc.gov/ecfs/document/1071193716934/1]
WISPA – The Association for Broadband Without Boundaries
Proceeding(s): 17-258
Date of Meeting: July 14, 2025 (Written Ex Parte Communication)
Date Disseminated: July 14, 2025
Participants:
WISPA – The Association for Broadband Without Boundaries,
David M. Zumwalt (President & CEO) submitted a written communication to the following FCC staff:
Arpan Sura
Edyael Casaperalta
Will Holloway
Paul Powell
Jessica Greffenius
Nellie Foosaner
Kamran Etemad
Navid Golshani
Robert Pavlak
Dana Shaffer
Summary of Discussion:
In a written ex parte communication, WISPA expressed its strong opposition to any regulatory changes that would disrupt incumbent operations in the CBRS band (3550-3700 MHz). WISPA argues that the CBRS band is an American success story, vital for rural broadband deployment and the growth of private networks.
WISPA presented several key arguments against altering the current CBRS framework:
CBRS Success and Importance to Rural America: The CBRS band is critical for WISPA members, who use it to provide broadband to hundreds of thousands of customers in rural and underserved areas. Citing reports from NTIA and the OnGo Alliance, WISPA highlighted the band's rapid growth, with over 413,000 Citizens Broadband Radio Service Devices (CBSDs) deployed, the majority (67.5%) located in rural census blocks. Over 60 WISPA members acquired Priority Access Licenses (PALs) in Auction 105, and many more rely on General Authorized Access (GAA) spectrum. WISPA notes that recipients of federal funding (Connect America Fund, Rural Digital Opportunity Fund) use CBRS to meet their deployment obligations.
Opposition to Higher Power Levels: WISPA opposes proposals to increase maximum power levels for CBRS devices. As a Time Division Duplex (TDD) band, higher power would increase the risk of co-channel and adjacent-channel interference. It would force small providers to either operate with reduced service areas or undertake costly, premature equipment upgrades, ultimately harming rural consumers.
Opposition to Mandatory GAA "Coexistence" Rules: The filing objects to changing GAA rules to give Spectrum Access Systems (SAS) mandatory control over channel assignments. WISPA argues these algorithms are designed for mobile carrier needs and fail to account for the highly directional antennas used in fixed wireless access, which would improperly limit channel availability for GAA users.
Opposition to Relocating CBRS Operations: WISPA strongly opposes forcibly relocating CBRS operations to another band, an action they contend would primarily benefit a few large mobile carriers seeking to create a contiguous 3.45-3.98 GHz band. Such a move would:
Strand the significant investments made by hundreds of PAL licensees, many of whom are small businesses.
Incur massive relocation costs for equipment, labor, and service disruption that would likely not be fully compensated.
Disrupt service for millions of households that rely on CBRS for broadband.
Undermine the goals of the Broadband Equity, Access, and Deployment (BEAD) program, which relies on CBRS as a cost-effective deployment solution, especially following NTIA's June 2025 BEAD Restructuring Policy Notice.
Mobile Carriers Have Sufficient Spectrum: WISPA asserts that major mobile carriers do not need additional mid-band spectrum from the CBRS band. The filing cites recent statements from executives at AT&T, Verizon, and T-Mobile indicating that they currently possess an abundance of mid-band spectrum and have no immediate need for more.
In conclusion, WISPA urged the Commission and NTIA to protect the thriving CBRS ecosystem and to seek spectrum for future auctions from bands that would be less disruptive to existing, widely deployed services that are critical for closing the digital divide.
Source: [NOTICE OF EXPARTE, WISPA – The Association for Broadband Without Boundaries, https://www.fcc.gov/ecfs/document/10714036520689/1]
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