4/8 FCC Comments Responding to the NFL’s Request to Waive CBRS Rules

New America's Open Technology Institute filed comments alongside Charter Communications and DISH Network with the Federal Communications Commission (Commission) responding to a Request for Partial Waiver filed by the National Football League to waive the rules for the Citizens Broadband Radio Service (CBRS) in the 3.5 GHz band. The introduction to the comments are available below:

The Open Technology Institute at New America (“OTI”), Charter Communications, Inc. (“Charter”), and DISH Network Corporation (“DISH”) hereby provide their comments on the National Football League’s (“NFL”) Request for Partial Waiver (“Petition”) of Section 96.39(c)(2) of the Commission’s rules. While OTI, Charter, and DISH do not oppose the NFL’s Petition, we respectfully ask the Wireless Telecommunications Bureau (“Bureau”) to explicitly limit any grant of the NFL’s request to the facts presented. By taking this careful approach, the Bureau will ensure that its actions do not open the door to a flood of waiver requests that would undermine the Commission’s carefully constructed framework for operations in the Citizens Broadband Radio Service (“CBRS”) band.