This was posted to the WISPA lists. If you are using or plan to use CBRS please file BY MONDAY in the FCC docket your comments:
Please compose your OWN letter to the FCC and file it with the FCC by Monday. Do NOT simply copy our memo and post it to the FCC. This needs to be in your words, showing your use of the band and the actual services you provide or intend to provide. An excellent example: https://ecfsapi.fcc.gov/file/10718384010406/FCC%20CBRS.pdf <https://ecfsapi.fcc.gov/file/10718384010406/FCC%20CBRS.pdf> Sincerely, Mark Radabaugh WISPA FCC Committee Chair [email protected] <mailto:[email protected]> 419-261-5996 Citizens Broadband Radio Service GN Docket No. 12-354 Suggestions for Filing Comments OPPOSING Petitions for Rulemaking Deadline: Monday, July 24 at 11:59 pm EDT Background CTIA and T-Mobile have recently filed petitions for rulemaking with the FCC that would fundamentally change the Citizens Broadband Radio Service (CBRS), which includes the 3550-3650 MHz band and the existing 3650-3700 MHz band. WISPA will be filing extensive Comments opposing the proposed rule changes, and we believe it is very important for individual members – WISPs, manufacturers, vendors, etc. – to also file Comments. The FCC adopted rules in 2015 to establish the CBRS band. The band employs a three-tier spectrum access model. Incumbent Access (earth stations and military) that must always be protected from interference; Priority Access, which will be auctioned by the FCC according to census tracts and must protect incumbents; and General Authorized Access (GAA), a “license by rule” service that must protect Incumbent and Priority Access use. The FCC allocated up to 70 megahertz for Priority Access Licenses (PALs) and the remaining 80 megahertz for GAA use. The FCC also will allow GAA use opportunistically when and where Priority Access Licenses (PALs) are not in use. The model will be governed by a Spectrum Access System (SAS) that will enforce the three-tier approach. In addition to fixed wireless service, the CBRS band is viewed as an “innovation band” to enable other business models such as Industrial Internet of Things, private networks, venues (e.g., airports, arenas, shopping malls), neutral host networks and others. The Mobile Industry Proposals (links to petitions on next page) The mobile industry wants to change the rules so they are friendlier to 5G services that they are developing, though they concede that actual deployment of 5G in the CBRS band will be years away. The effect of the proposals will effectively foreclose other uses and create a “5G-only” band. To achieve this goal, here is what the mobile industry is proposing: Ø Extend Priority Access License (PAL) terms from 3 years to 10 years and add a “renewal expectancy.” Ø Conduct PAL auctions based on Partial Economic Areas (PEAs) instead of census tracts. There are 416 PEAs and more than 74,000 census tracts. Together, these proposed rule changes would make the cost of acquiring protected PALs through auction significantly higher, pricing out many small would-be bidders and essentially ensuring that the large mobile wireless carriers have exclusive access to the spectrum for an indefinite period of time over a large geographic area. Smaller providers, even if they had the means to outbid the large carriers, would be forced to acquire large-area licenses (multiple counties) that are likely much larger than the targeted areas WISPs would want to serve. In addition to these proposals, T-Mobile (but not CTIA) also proposes the following: Ø Allow PALs in the existing 3650-3700 MHz band and eliminate the GAA spectrum allocation (although GAA would still be available on an opportunistic basis when and where PALs are not in use). Ø Set a 50 megahertz cap, enabling three large carriers to acquire all of the licensed spectrum. These additional proposals will virtually guarantee that the CBRS band becomes a “5G-only” band. IN addition, eliminating the GAA tier in the 3650-3700 MHz band without accommodating existing 3650-3700 MHz users could present serious interference problems if newcomers are not required to protect incumbents. General Guidelines · Please review the two petitions: o Here is a link to the CTIA Petition: https://ecfsapi.fcc.gov/file/10616144416997/170616%20-%20FILED%20CTIA%203.5%20GHz%20Petition%20for%20Rulemaking.pdf <https://ecfsapi.fcc.gov/file/10616144416997/170616%20-%20FILED%20CTIA%203.5%20GHz%20Petition%20for%20Rulemaking.pdf>. o Here is a link to the T-Mobile Petition: https://ecfsapi.fcc.gov/file/106191696422731/T-Mobile%203.5%20GHz%20Petition%20for%20Rulemaking%20--%2012-354%20--%206.17.2017.pdf <https://ecfsapi.fcc.gov/file/106191696422731/T-Mobile%203.5%20GHz%20Petition%20for%20Rulemaking%20--%2012-354%20--%206.17.2017.pdf>. · File comments unique to your company, not “cookie-cutter” comments o Explain what your company does § How many customers do you have? § What part(s) of the country do you serve? How rural is the area you serve? § What service do you currently offer (e.g., speed)? o As appropriate, emphasize: § Your company’s investments in 3650-3700 MHz § Plans for gaining access to the CBRS band § Benefits of having the ability to get access to 100 megahertz of mid-band spectrum § Note that you have an experimental license (if you do) and what the purpose of the trial is § Problems that additional spectrum will solve (e.g., investment, congestion, throughput, QoS, interference, etc. o Focus on consumers o For rural providers: focus on extending fixed broadband service to rural Americans that lack broadband or choice o Be clear that you oppose the CTIA and T-Mobile petitions · We are happy to answer questions, provide suggestions and assist in filing your comments. INSTRUCTIONS FOR FILING YOUR COMMENTS WITH THE FCC IN GN Docket No. 12-354 Comments can be prepared as a double-spaced document with a caption, or as a single-spaced letter. Comments are filed electronically at the FCC’s ECFS web site: https://www.fcc.gov/ecfs/filings <https://www.fcc.gov/ecfs/filings> Proceedings: 12-354 Name of Filer: enter your company’s name, not your name Type of Filing: pull down menu, enter “Comment” right at the top of the menu File Number, Report Number, Bureau ID number: leave these blank Please be sure to file by Monday, July 24 at 11:59 pm EDT > On Jul 21, 2017, at 1:30 PM, Adam Moffett <[email protected]> wrote: > > 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 > <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] <mailto:[email protected]>> > To: "af" <[email protected] <mailto:[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] >> <mailto:[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] <mailto:[email protected]>> >> To: "Animal Farm" <[email protected] <mailto:[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> >>> >>> -- >>> <Vcard.jpg>
