Dish Network bid extensively in the FCC's blockbuster C-band auction for midband 5G spectrum, but walked away with only one license. It covers Cheyenne, Wyoming, with a population of around 64,000.

As a result, Dish is urging the FCC to rejigger its proposed rules for the upcoming 3.45GHz spectrum auction as well as the agency's rules governing the 3.5GHz CBRS spectrum licenses it auctioned last year.

"Dish urges the commission to think holistically about midband spectrum in order to maximize the efficient use of these valuable airwaves," the company wrote to the FCC Friday.

Dish's proposal for the 3.5GHz CBRS band is noteworthy because the company spent $913 million in the FCC's CBRS auction last year to purchase 5,492 licenses. The action gave Dish roughly 20MHz of valuable midband spectrum across the entire country.

"Dish spent wisely going for breadth and not depth," wrote the financial analysts at Cowen of Dish's CBRS purchases. "This was a solid strategy to in-fill nationwide coverage of upper midband spectrum ideal for Dish's wholesale/enterprise IoT network."

These go to 11

Now, Dish is urging the FCC to change its rules governing the CBRS band so that it can more easily build a network in that spectrum.

"The current CBRS EIRP [equivalent isotropically radiated power] limit of 47 dBm/10MHz ... is likely to thwart a wide variety of desirable use cases, effectively limiting CBRS users to small cell deployments," Dish wrote. dBm is a common measurement for wireless transmission power levels expressed in decibels (dB) and milliwatts (mW).

"Dish's technical analysis found that no party is likely to be harmed by higher power use cases in the CBRS band," the company wrote, urging the FCC to raise its maxim power levels for transmissions in the CBRS band to 72 dBm/10MHz.

Such a change would allow Dish to essentially "turn up the volume" on its transmissions in the CBRS band and thereby cover wider geographic areas with faster services. It's also worth noting that the 5G radios Dish is preparing to deploy do not include CBRS capabilities.

Changes to 3.45GHz

Part of the reason Dish is advocating changes to the 3.5GHz CBRS band is so that it will more directly align with the 100MHz between 3.45GHz-3.55GHz the FCC is planning to auction in October, as well as the C-band that sits between 3.7GHz and 3.98GHz. The FCC recently proposed power limit rules for the 3.45GHz-3.55GHz band that are similar to the C-band.

Dish said that keeping the CBRS band "relatively encumbered" with lower power limits would leave it "sandwiched between the 3.45GHz band and the 3.7GHz band, both of which would have services rules optimized for large-scale, wide-channel 5G service offerings."

Dish continued: "This is akin to connecting two cities with a new 8-lane high-speed roadway, but constructing a stretch of single lane road in the middle. The current US approach undermines the overall usefulness of the entire 3GHz band, and places the United States at odds with our major global competitors, especially China."

Dish also said the FCC would need to require TDD synchronization across the CBRS band and the 3.45GHz band in order to prevent interference.

Dish isn't the only company urging the FCC to change its proposal for the 3.45GHz auction. Google, cable companies and others are also arguing for changes including smaller license areas. The FCC will vote on final rules for the 3.45GHz auction later this month; the agency is currently split between two Democratic commissioners and two Republican commissioners.

Midband aspirations

Dish has participated in virtually every spectrum auction the FCC has held over the past decade, and now sits on a trove of spectrum holdings below 6GHz that's roughly half the size of AT&T's holdings. The company also owns substantial millimeter wave (mmWave) spectrum licenses, and is working to obtain FCC approval to conduct 5G operations in its 12GHz holdings.

However, the eye-watering bids in the FCC's C-band spectrum auction reflect network operators' desperation for midband spectrum for 5G. Many have described this kind of midband spectrum as "Goldilocks" spectrum that toes an ideal line between coverage and capacity.

Thus, Dish is clearly interested in raising the value of its CBRS holdings and, potentially, bidding heavily in the upcoming 3.45GHz auction in October. The company could potentially use technologies like carrier aggregation to combine transmissions in those two bands to offer speedy and broad 5G connections.

"If the FCC were both to require TDD synchronization and increase CBRS power levels, the US could create 530MHz of contiguous mid-band spectrum (3450-3980MHz) with compatible power levels, which as explained above would position the US to compete at global scale for 5G technology and services," Dish argued.

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— Mike Dano, Editorial Director, 5G & Mobile Strategies, Light Reading | @mikeddano