I'm not sure whether that rule matters. Everyone has the same incentive
to avoid interference with each other as they did before. Right now if
we interfere with each other there's no recourse. Sounds like that'll
still be the case. Codified status quo.
------ Original Message ------
From: "Mark Radabaugh" <[email protected]>
To: [email protected]
Sent: 7/21/2017 4:49:37 PM
Subject: [AFMUG] Be careful with 3650 (was CBRS in trouble)
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
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]
On Jul 21, 2017, at 3:26 PM, Mathew Howard <[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]>
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]>
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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