Federated , Inc. 4075 Wilson Boulevard 9th Floor Arlington, VA 22203 www.federatedwireless.com

April 27, 2021

VIA ECFS

Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554

RE: Second Supplement to Federated Wireless, Inc. Notification of Intent to Operate a Citizens Broadband Radio Service Spectrum Access System in American Samoa Wireless Bureau and Office of Engineering and Technology Approve Five Spectrum Access System Administrators to Begin Initial Commercial Deployments in the 3.5 GHz Band, GN Docket No. 15-319

Dear Ms. Dortch:

Federated Wireless, Inc. (“Federated Wireless”) hereby submits this second supplement to its February 25, 2020, notification of its intent to operate a Citizens Broadband Radio Service (“CBRS”) Spectrum Access System (“SAS”) in American Samoa.1 Federated Wireless is authorized to operate as a SAS Administrator in the upper 50 MHz of the CBRS band in American Samoa.2 Federated Wireless’s request to operate as a SAS Administrator in the lower 100 MHz of the CBRS band in American Samoa is pending, awaiting a determination by the National Telecommunications and Information Administration (“NTIA”) and the Department of Defense (“DoD”) as to the appropriate means of ensuring protection for federal incumbent users of the CBRS band in the area surrounding American Samoa.3

On April 26, 2021, the NTIA submitted to the Office of Engineering and Technology (“OET”) and the Wireless Telecommunications Bureau (“WTB”) a letter (“NTIA Letter”) notifying OET and WTB of the required protection criteria for American Samoa.4 NTIA noted DoD has defined Dynamic Protection Areas (“DPAs”) for the territory. DoD further has determined that instead of utilizing the CBRS Environmental Sensing Capability to protect these DPAs, a scheduling portal will be used to implement the requisite incumbent protections (such portal-activated DPAs, the “P-DPAs”). In accordance with the requirements set forth in the

1 Letter from Jennifer M. McCarthy, Vice President, Legal Advocacy, Federated Wireless, Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed Feb. 25, 2020), as supplemented by Letter from Jennifer M. McCarthy, Vice President, Legal Advocacy, Federated Wireless, Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed Mar. 24, 2020). 2 Wireless Bureau and Office of Engineering and Technology Approve Spectrum Access System Administrator Federated Wireless for Full Scale Commercial Deployment in the 3650-3700 MHz Band in American Samoa, GN Docket No. 15-319, Public Notice, DA 20-438 (WTB/OET rel. Apr. 21, 2020). 3 See infra Note 1. 4 Letter from Charles Cooper, Associate Administrator, Office of Spectrum Management, NTIA, to Ronald Repasi, Acting Chief, Office of Engineering and Technology, FCC, GN Docket Nos. 15-319, 17-258 (filed April 26, 2021). NTIA Letter, Federated Wireless acknowledges that, as a SAS Administrator, it will communicate with the portal on a regular basis and protect any P-DPA during scheduled activities. Federated Wireless is prepared to implement the P-DPA approach immediately.

Federated Wireless thanks NTIA, DoD, and the Federal Communications Commission for its work in opening up critical mid-band spectrum for the residents of American Samoa with this action and looks forward to similar efforts in the other U.S. Territories. Federated Wireless respectfully requests that the Commission expeditiously grant Federated Wireless authorization to operate as a SAS Administrator throughout the full CBRS band in American Samoa in order to bring the full benefits of this critical 150 MHz of mid-band spectrum to the residents of American Samoa as soon as possible.

Should you have any questions regarding the foregoing or require additional information, please contact the undersigned.

Respectfully submitted,

/s/ Jennifer M. McCarthy Jennifer M. McCarthy Vice President, Legal Advocacy Federated Wireless, Inc. 4075 Wilson Boulevard 9th Floor Arlington, VA 22203 Cc: Paul Powell, FCC Charles Cooper, NTIA

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