Review:
The previously adopted rules split the 150mhz of the 3.5ghz band into a
general availability (GA) section and a 70mhz wide Priority Access
License (PAL) section. PAL licenses are to be auctioned per census
tract, and have a 3 year license term. At the end of 3 years you can
renew once, for a total of 6 years, (After that I believe they go back
for another auction, but I don't recall). The GA section is
administered by an automated Spectrum Access System (SAS), and any
frequencies in your census tract not used by a PAL are available for GA
use.
CTIA proposal:
The CTIA suggests that the PAL license term be 10 years and that they
should have an expectation of being able to renew them. They also
suggest that licenses be granted for a PEA rather than a census tract.
PEA's are gigantic
(https://apps.fcc.gov/edocs_public/attachmatch/DA-14-759A4.pdf). Their
justification for the license term of 10 years is that mobile
deployments may not see a return on investment in 3 years. The
justification for guaranteed renewal is that it will encourage
investment in the band. The justification for PEA's instead of census
tracts it that it's easier for them. For all three points they also
point out that these changes would be more consistent with how current
licensing works (for them).
T-Mobile proposal:
T-Mobile suggests everything the CTIA suggests, but further suggests
that the entire 150mhz become PAL, with GA use only allowed
opportunistically where a PAL has not been granted. T-Mobile goes on to
suggest changes in the channel selection and bidding process consistent
with their proposal of having the whole band auctioned off, and a few
technical points such as less restrictive OOB emissions rules.
My take:
The expectation under the current rules is that big carriers will bid on
PAL's for census tracts in dense areas where they need more small cell
deployments, but rural tracts will go for a couple hundred dollars each.
If they get the right to bid on a PAL in an entire PEA, then we won't
get any. They'll bid on our PEA because of the cities contained in our
PEA, and we'll never outbid them.
The CTIA proposal and the T-Mobile proposal are dated just a few days
apart, and T-Mobile is a member of the CTIA. So I assume they're asking
dad for a Lamborghini so they can settle for the Corvette.
It might be ok ONLY if the GA availability is dependent on where they
are deployed and not simply where they hold a license. If I can still
use the whole 150mhz in small town USA because big carriers are not
going to build 3.5ghz out in the woods where they already have
sufficient spectrum in 800mhz, 2.5ghz, etc; THEN I'd be happy enough.
------ Original Message ------
From: "Mathew Howard" <[email protected]>
To: "af" <[email protected]>
Sent: 7/21/2017 11:03:13 AM
Subject: Re: [AFMUG] CBRS in trouble
I didn't read through the whole thing, but from what I got skimming
through it, it sounds like they basically want PALs to be auctioned for
the entire 150mhz, instead of the current 70mhz they're limited to, and
they want a single entity to be allowed to hold more PALs... and some
changes to the licensing structure to make it a bit more like
traditional licenses. It probably wouldn't change much in areas out in
the middle of nowhere, that the big companies don't have much interest
in, but in some areas, I would imagine you'd end up with the three
biggest cell carriers in the area snapping up all the PALs, making the
entire band essentially non-existent for the rest of us.
Their statement that there won't be enough investment in the band
without those changes is pretty obviously nonsense, since there's
already plenty of gear that will operate in the band available... and
the new system isn't even online yet.
On Thu, Jul 20, 2017 at 4:04 PM, Adam Moffett <[email protected]>
wrote:
Trying to find time to read the whole NPRM before making an opinion,
but it does sound bad.
------ Original Message ------
From: "Dave" <[email protected]>
To: "Animal Farm" <[email protected]>
Sent: 7/20/2017 4:39:18 PM
Subject: [AFMUG] CBRS in trouble
Anyone else doing this
http://files.constantcontact.com/d4d6cd6a501/40256872-b6da-4840-b79d-61e111535347.pdf
<http://files.constantcontact.com/d4d6cd6a501/40256872-b6da-4840-b79d-61e111535347.pdf>
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