Federal Communications Commission	DA 21-969



DA 21-969
Released:  August 6, 2021

WIRELESS TELECOMMUNICATIONS BUREAU AND OFFICE OF ENGINEERING AND TECHNOLOGY APPROVE SONY’S USE OF KEY BRIDGE’S ENVIRONMENTAL SENSING CAPABILITY 

GN Docket No. 15-319

1. By this Public Notice, the Wireless Telecommunications Bureau (WTB) and the Office of Engineering and Technology (OET) of the Federal Communications Commission (Commission or FCC) approve Spectrum Access System (SAS) administrator Sony Corporation’s (Sony) request to amend its SAS authorization to permit it to use Key Bridge Wireless LLC’s (Key Bridge) Environmental Sensing Capability (ESC) to protect federal incumbent operations in the 3.55-3.65 GHz portion of the 3.55-3.7 GHz band (3.5 GHz band). See 47 CFR §§ 0.241(j), 0.331(f) (delegating authority to WTB/OET to oversee the SAS approval process and facilitate the testing and development of multiple SAS operators).  Although Sony has been referred to as Sony, Inc. in previous WTB/OET releases, we now clarify that, according to their filings, Sony Corporation is the correct name for the entity involved.  See Letter from James Morgan, Director and Counsel, Sony Electronics Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed Oct. 13, 2020) (ESC Request).
  We find that Sony has demonstrated effective communication and interoperation with the Key Bridge ESC and, as such, is approved to use the Key Bridge ESC to protect federal incumbent operations consistent with the Commission’s rules and its SAS authorization. 
2. On January 27, 2020, WTB and OET approved four SAS administrators, including Sony, for full scale commercial deployment in the 3.5 GHz band. Wireless Telecommunications Bureau and Office of Engineering and Technology Approve Four Spectrum Access System Administrators for Full Scale Commercial Deployment in the 3.5 GHz Band and Emphasize Licensee Compliance Obligations in the 3650-3700 MHz Band Under Part 96, GN Docket No. 15-319, Public Notice, 35 FCC Rcd 117, 120 (WTB/OET 2020) (SAS Approval Public Notice).
  At that time, Sony did not have an ESC associated with its SAS.  In the SAS Approval Public Notice, WTB and OET noted that, “[i]f a SAS operator plans to make substantive changes to its system, for example, to comply with new releases of industry standards, the SAS operator must supplement or amend its filings in GN Docket No. 15-319 to reflect these changes.” SAS Approval Public Notice, 35 FCC Rcd 117, 119, para. 5.
  WTB and OET also stated that ongoing compliance with the Commission’s rules and policies is a condition of SAS certification and that a SAS administrator may be required to demonstrate its ability to operate with an associated ESC prior to using that ESC to authorize commercial deployments in the band. Id. (“an SAS may be required to demonstrate proper interoperation with its associated ESC to demonstrate effective protection of federal incumbents from actual commercial deployments.”)
  
3. On October 13, 2020, Sony filed its request to provide SAS services in the 3.5 GHz band with Key Bridge as its approved ESC provider. See ESC Request.  See also Wireless Telecommunications Bureau and Office of Engineering and Technology Announce the Approval of an Additional Environmental Sensing Capability for the 3.5 GHz Band, GN Docket No. 15-319, Public Notice, 35 FCC Rcd 7001 (WTB/OET 2020); Wireless Telecommunications Bureau and Office of Engineering and Technology Extend the Conditional Authorization of Key Bridge’s Environmental Sensing Capability, GN Docket No. 15-319, Public Notice, DA 21-723 (WTB/OET Jun. 21, 2021); Wireless Telecommunications Bureau and Office of Engineering and Technology Extend the Conditional Authorization of Key Bridge’s Environmental Sensing Capability, GN Docket No. 15-319, Public Notice, 35 FCC Rcd 14684 (WTB/OET 2020).
  On April 23, 2021, Sony filed its ESC Interoperability Testing Report showing successful interoperation between Sony’s SAS and Key Bridge’s ESC. Letter from James Morgan, Director and Counsel, Sony Electronics Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed Apr. 23, 2021) (ESC Report).
  Sony later filed a supplement to the ESC Report on May 25, 2021. Letter from James Morgan, Director and Counsel, Sony Electronics Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed May 25, 2021) (Supplement).
  After review of its submissions, we find that Sony has demonstrated that its SAS can properly interoperate with Key Bridge’s ESC and that it will comply with all relevant provisions of the Commission’s Part 96 rules.  As such, we approve Sony’s request to amend its SAS authorization, subject to ongoing compliance with the Commission’s rules and policies, to use Key Bridge as their associated ESC provider. Consistent with the Commission’s rules and WTB and OET’s earlier instructions, ESCs may only be used in conjunction with a fully certified SAS and within geographic areas where they have approved ESC sensors.  Wireless Telecommunications Bureau and Office of Engineering and Technology Establish Procedure for Registering Environmental Sensing Capability Sensors, GN Docket No. 15-319, Public Notice, 33 FCC Rcd 10016 (WTB/OET 2018) (ESC Sensor Registration Public Notice).  Once ESC sensor approvals are in place, ESCs may be used to detect the presence of federal incumbent radar transmissions in the 3550-3650 MHz portion of the 3.5 GHz band and to communicate that information to one or more certified SASs in accordance with the Commission’s rules.  See 47 CFR § 96.67.


4. By the Acting Chief, Wireless Telecommunications Bureau, and the Acting Chief, Office of Engineering and Technology.  
– FCC –
2