Cellular South Licenses, LLC Request for Extension of

Cellular South Licenses, LLC Request for Extension of Build Out Requirements

for A and B Block Licenses in the Lower 700 MHz Band

Supplement

Cellular South Licenses, LLC d/b/a C Spire Wireless ("Cellular South"), a subsidiary of

Cellular South, Inc., hereby files this supplement to its pending requests to extend for two years,

until June 13, 2015, the build-out deadline for its 700 MHz spectrum licenses in the A and B

Blocks of the lower 700 MHz spectrum band ("the Lower 700 MHz Band").1 A complete list of

Cellular South's licenses in the A and B blocks, along with the corresponding ULS file number

for the extension request, is set forth at Attachment A. As set forth in the pending extension

requests, Cellular South submits that grant of a two-year extension of its build-out deadline is

warranted due to the unforeseen and unresolved lack of device interoperability in the 700 MHz

Band. The lack of device interoperability, accompanied by roaming service complications, has

directly frustrated the deployment plans of Cellular South to build-out spectrum in its licensed

geographic areas.

This supplement is intended to provide additional information to illustrate Cellular

South's difficulty in satisfying its build-out requirements for its lower 700 MHz B Block

licenses. The attached maps (Attachment B) highlight why deployment of a 4G-LTE network

across the Lower B block is only practical and feasible if it is accomplished as part of a fully-

integrated deployment of a 4G-LTE network over a larger area in combination with Cellular

South's Lower A Block spectrum.

1 If its requests are not acted upon by the Commission by the current June 13, 2013 construction deadline for the Block B licenses, Cellular South has requested that the deadline be extended two years from the date the Commission acts.


for A and B Block Licenses in the Lower 700 MHz Band Supplement

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In 2008, Cellular South participated in Auction 73 and acquired 700 MHz spectrum

licenses in the A and B Blocks of the Lower 700 MHz Band for approximately $192 million.

While much of the valuable low-band spectrum is concentrated in the hands of a few carriers,

Cellular South managed to acquire twenty-four Lower 700 MHz licenses, including fourteen A

Block and ten B Block licenses. Cellular South’s intent in acquiring its 700 MHz licenses was to

deploy the first LTE network in its existing operating area, and to expand into new markets

where it would also have the first LTE network.

Cellular South is not alone in its desire to deploy an LTE network -- it is abundantly clear

that wireless operators all over the country are choosing LTE for their 4G networks and

consumers are demanding capabilities that only LTE can deliver. In this marketplace, it is not

possible for Cellular South to compete for customers unless it has the current generation

technology, like LTE. Use of the Lower 700 MHz band for LTE is particularly important for the

Company to remain competitive in its current service area because it would allow Cellular South

to offer LTE services to at least seventy-percent (70%) of the population (as well as fifty percent

(50%) of the geography) of its existing service area, resulting in coverage for 2.5 million POPs.2

While some other "start-up" carriers have proposed to deploy fixed wireless networks

with their 700 MHz licenses, Cellular South has always believed that deploying the first LTE

network in its operating area with its 700 MHz licenses is not only vital to serving the public

interest by satisfying built-up market demand for high-speed mobile wireless services, but it is

also vital to the competitiveness of Cellular South in the marketplace. Having already launched

2 POPs estimate is based upon U.S. Census 2011 estimate data. See, e.g., quickfacts.census.gov. See also Letter from Benjamin M. Moncrief to Marlene H. Dortch (Jan. 14, 2013) filed in WT Docket No. 12-69.



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an LTE network in Cellular South's PCS spectrum, it would make little sense for the Company to

pursue a technology other than LTE in the Lower 700 MHz A and B Block licenses.

While the Lower B Block licenses acquired by Cellular South will provide additional

bandwidth for Cellular South’s network, that B Block spectrum is not sufficient by itself to

deploy a 4G-LTE network without the Lower A Block spectrum in Cellular South’s 700 MHz

License Area. As demonstrated in the attached maps, the Lower B Block licenses cover a

fragmented and small geographic area that is not commercially viable by itself to launch a

network. For its B Block licenses, it does not make sense for the Company to build-out an

isolated Band 17 network for 10 CMAs that comprise three different clusters of licenses spread

across four states. Build-out of the Lower B Block licenses only makes sense in the context of a

simultaneous build-out of the Lower A Block licenses. The Lower B Block licenses are

complementary to the larger and contiguous footprint of the Lower A Block licenses held by the

Company.

While complementary, the Lower B Block licenses are still viewed as critical to the

Company because they will provide additional much-needed spectrum and bandwidth capacity in

certain geographic areas where they overlap with Cellular South's Lower A Block licenses. As

the Commission is aware, all carriers, including Cellular South, are looking for opportunities to

deploy as much spectrum as possible in order to satisfy ever-increasing consumer demand,

especially for the bandwidth intensive applications used on LTE networks. Deployment of the

Company's Lower B Block licenses will play an important role in satisfying this demand.

Further, in those geographic areas where the Lower B Block licenses do not overlap with

Cellular South's Lower A Block licenses, the Lower B Block licenses are critical because they



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will help to expand the reach of the Company's planned network to even more consumers --

consumers who likely would not have had access to next-generation LTE technology.

Although Band 17 devices are available for the Lower B block, it is totally impractical

from operational and economic standpoints for Cellular South to abandon its A Block licenses

and build out its B Block licenses either for commercial service or simply to save the licenses.

Such an effort would require Cellular South to duplicate many of its capital expenses which

would reduce the capital available to expand the coverage of its existing LTE network and future

700 MHz network.

The reasons that justify build out extensions for Cellular South’s Lower 700 MHz A

Block licenses apply equally to Cellular South’s Lower 700 MHz B Block licenses. While

Cellular South appreciates the Commission's recent grant of a short-term build-out extension

until December 13, 2013 for Cellular South's Lower 700 MHz A Block licenses,3 a longer term

build-out extension (as contemplated in the pending extension requests) is still needed for both

the A and B Block licenses held by the Company, especially in the absence of any resolution of

the interoperability and roaming issues outlined by Cellular South and other 700 MHz licensees.

Even if the interoperability issue is resolved by the Commission in the near future, Cellular

South will need sufficient time to build-out its network and acquire the necessary interoperable

devices to be used on the network.

As set forth in Cellular South's pending extension requests, the Company satisfies the

Commission's standard for granting an extension request in these circumstances. The lack of

device interoperability and roaming service unavailability have directly impeded Cellular South's

3 See "Wireless Telecommunications Bureau Extends 700 MHz A Block Licensee Interim Construction Benchmark Deadline Until December 13, 2013," Public Notice DA 13-210 (rel. February 13, 2013).



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deployment plans for its A and B Block licenses. At the time of Auction 73, Cellular South

reasonably expected, based upon over 20 years of experience in the wireless industry, that the

700 MHz band would include device interoperability, and as a result, devices would be widely

available. However, as detailed in the pending extension requests, the concerted efforts of

certain carriers and manufacturers has prevented device interoperability and completely upended

Cellular South's deployment plans -- a circumstance beyond Cellular South's control. Further,

the lack of device interoperability could not have been reasonably foreseen by Cellular South at

the time it acquired its A and B Block licenses, since device interoperability existed in every

other previous frequency band.

To require Cellular South to satisfy its build-out deadline for its Lower 700 MHz A and B

Block licenses when the issue of device interoperability has not been resolved would place an

undue economic burden on the company. The absence of a robust device selection for the Lower

A Block and the inability to roam on to other parts of the Lower 700 MHz Band, have gutted

Cellular South's plans to build-out its Lower A and B Block licenses in an economic and viable

way. Forcing Cellular South to move forward with building out its licenses in spite of these

significant obstacles would waste scarce financial and spectral resources, and result in an

unmarketable LTE network serving few, if any, customers -- a result that is not in the public

interest.



ATTACHMENT A

Name Call Sign/Lease

ID

Market Number

Channel Block

1st Build-out Date

ULS File Number

Cellular South Licenses, LLC WQIZ423 BEA039 A 6/13/2013 0005449634Cellular South Licenses, LLC WQIZ424 BEA043 A 6/13/2013 0005449762Cellular South Licenses, LLC WQIZ425 BEA044 A 6/13/2013 0005449768Cellular South Licenses, LLC WQIZ426 BEA045 A 6/13/2013 0005449778Cellular South Licenses, LLC WQIZ427 BEA071 A 6/13/2013 0005449785Cellular South Licenses, LLC WQIZ428 BEA073 A 6/13/2013 0005449792Cellular South Licenses, LLC WQIZ429 BEA074 A 6/13/2013 0005449794Cellular South Licenses, LLC WQIZ430 BEA075 A 6/13/2013 0005449801Cellular South Licenses, LLC WQIZ431 BEA076 A 6/13/2013 0005449804Cellular South Licenses, LLC WQIZ432 BEA077 A 6/13/2013 0005449810Cellular South Licenses, LLC WQIZ433 BEA078 A 6/13/2013 0005449818Cellular South Licenses, LLC WQIZ434 BEA079 A 6/13/2013 0005449823Cellular South Licenses, LLC WQIZ435 BEA080 A 6/13/2013 0005449828Cellular South Licenses, LLC WQIZ436 BEA082 A 6/13/2013 0005449835Cellular South Licenses, LLC WQIZ437 CMA226 B 6/13/2013 0005449837Cellular South Licenses, LLC WQIZ438 CMA249 B 6/13/2013 0005449843Cellular South Licenses, LLC WQIZ439 CMA252 B 6/13/2013 0005449848Cellular South Licenses, LLC WQIZ440 CMA265 B 6/13/2013 0005449852Cellular South Licenses, LLC WQIZ441 CMA272 B 6/13/2013 0005449858Cellular South Licenses, LLC WQIZ442 CMA283 B 6/13/2013 0005449861Cellular South Licenses, LLC WQIZ443 CMA308 B 6/13/2013 0005449868Cellular South Licenses, LLC WQIZ444 CMA369 B 6/13/2013 0005449872Cellular South Licenses, LLC WQIZ445 CMA503 B 6/13/2013 0005449876Cellular South Licenses, LLC WQIZ446 CMA648 B 6/13/2013 0005449879



ATTACHMENT B

Maps of Cellular South (C Spire) 700 MHz Lower A and B Block Licenses

Use, duplication, or sale of this service, or data contained herein, except as described in the SNL Subscription Agreement, is strictly prohibited.

C Spire Lower 700 MHz B Block Licenses


C Spire Lower 700 MHz A Block Licenses


Joseph.Mirshak

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Joseph.Mirshak

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C Spire Lower 700 MHz A & B Block Licenses

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Documents

Cellular South Licenses, LLC Request for Extension of