I urge ALL of you using 3.65 gear to pay very close attention to what the definition of power level at the edge of a SAS is - it is a whole lot louder than many of you are thinking about. The actual document is here:
https://www.fcc.gov/document/35-ghz-order-recon-and-2nd-ro <https://www.fcc.gov/document/35-ghz-order-recon-and-2nd-ro> Pay very close attention to this, and the examples in the appendix. (d) Received Signal Strength Limits: (1) For both Priority Access and GAA users, CBSD transmissions must be managed such that the aggregate received signal strength for all locations within the PAL Protection Area of any co-channel PAL, shall not exceed an average (RMS) power level of -80 dBm in any direction when integrated over a 10 megahertz reference bandwidth, with the measurement antenna placed at a height of 1.5 meters above ground level, unless the affected PAL licensees agree to an alternative limit and communicate that to the SAS. The standard is -80dBM/10Mhz approximately 5’ off the ground measured by a UNITY GAIN antenna. This frequency is going to be LOUD. If you are used to deploying with 20dBi gain antennas this means the interference signal can appear to you as if it was -60dB and still be perfectly legitimate. At the same time your base stations at 200’ with 16dBi gain antennas that are looking toward a PAL boundary are likely to see -64dB of noise or much higher if the PAL is calculating the -80dB by taking into account terrain, while your base station at 200’ is has clear line of sight to the other transmitter. I’m very concerned that many of you are installing NLOS services and counting on being able to continue to provide service use extremely low signal levels. I routinely see posts of people installing LTE customers at very low signal levels. This is not going to continue to work well when the base station is faced with significant noise. Mark Mark Radabaugh WISPA FCC Committee Chair [email protected] 419-261-5996 > On Jul 21, 2017, at 3:38 PM, Jeff Broadwick - Lists <[email protected]> wrote: > > The way it's structured right now, the 50MHz we are using now, and the top > 30MHz of the CBRS band will all be GA. The bottom 70MHz of CBRS is set aside > for PALs. Currently they are to be auctioned off by census tract for 5 > years, with one renewal option. That's what WISPA fought for, and that's > what we are trying to protect. > > Jeff Broadwick > ConVergence Technologies, Inc. > 312-205-2519 Office > 574-220-7826 Cell > [email protected] <mailto:[email protected]> > > On Jul 21, 2017, at 3:26 PM, Mathew Howard <[email protected] > <mailto:[email protected]>> wrote: > >> My understanding is that GA availability would be dependant on what's >> actually in use... so you would still be able to use it in an area where >> someone holds a PAL, but hasn't actually deployed anything. Of course if the >> entire 150mhz is auctioned off as PALs, there's always going to be the >> possibility that the PAL holders are going to come along and turn on some >> new towers in an area where you have a ton of GA stuff deployed, and the >> your whole network is suddenly gone... with no realistic way to fix it. >> >> But yeah, if the PALs are covering an entire PEA, none of us little guys are >> going to end up with any. >> >> On Fri, Jul 21, 2017 at 12:30 PM, Adam Moffett <[email protected] >> <mailto:[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> >>> >>
