Mark- For those of you members who volunteered the time to work directly with the FCC I thank you. I do understand the need to comment and file.
For those of you who are working closely with the FCC, I have the following questions. 1. What is your gut telling you the FCC will do at this point? (obviously none of us really know) 2. Do you feel the FCC is already in the pocket of big money? I ask these questions because a few years ago we based our massive 3.65 deployments on prior rulings that may change. Nearly every member and vendor I spoke with years ago fully expect WISP’s to have more 3.65 spectrum made available. I have been in the industry since 2005 and it seems like the FCC has slowly chipped away on the spectrum needs of WISP’s. Tyson Burris, President Internet Communications Inc. 739 Commerce Dr. Franklin, IN 46131 Daytime # 317-738-0320 Cell/Direct # 317-412-1540 Online: www.surfici.net [ICI] What can ICI do for you? Broadband Wireless - PtP/PtMP Solutions - WiMax - Mesh Wifi/Hotzones - IP Security - Fiber - Tower - Infrastructure. CONFIDENTIALITY NOTICE: This e-mail is intended for the addressee shown. It contains information that is confidential and protected from disclosure. Any review, dissemination or use of this transmission or its contents by unauthorized organizations or individuals is strictly prohibited. From: [email protected] [mailto:[email protected]] On Behalf Of Mark Radabaugh via WISP Sent: Thursday, December 28, 2017 7:58 AM To: [email protected]; Principal WISPA Member List <[email protected]>; [email protected] Subject: [Wisp] Last day to file CBRS Comments is today. Please file if you have not already done so. WISPA Members, We are in the middle of one of the most important fights in the history of our industry. We need every member (operators, vendors, service providers) to submit comments to the FCC. More background and an outline to help you cover all the bases are in Steve Coran’s email below. Please take 30 minutes today and put together a letter to the FCC on CBRS. If you need assistance, or want help reviewing a draft, contact me, Mark Radabaugh, or Steve Coran off list and we’ll help you. We have also developed a website that will enable you to see the difference between census tracts (the current proposal for allocating PALs) and PEAS. Instructions for accessing that website are below. If you would prefer to have a KMZ file showing PEA's that you can use, you can download it here: https://www.dropbox.com/s/y5b1zf1mtm5b0v2/FCC_PEAs_website.kmz?dl=0 THIS IS CRITICALLY IMPORTANT Citizens Broadband Radio Service GN Docket No. 17-258 Suggestions for Filing Comments regarding Notice of Proposed Rulemaking Deadline: Thursday, December 28, 2017 at 11:59 pm Eastern Time Background On October 24, 2017, the FCC released a Notice of Proposed Rulemaking (NPRM) 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 many of the proposed rule changes, and we believe it is very important for individual members – WISPs, manufacturers, vendors, etc. – to also file Comments. Summary of Current Rules That Will Be Changed If WISPs Do Not Comment The FCC adopted rules in April 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. Summary of Proposed Changes to the Rules Sought by the Mobile Industry Here is a link to the proposed regulatory action that the FCC is considering: https://apps.fcc.gov/edocs_public/attachmatch/FCC-17-134A1.pdf) PLEASE BE SURE TO READ Paragraphs 9-27, which are relevant to the proposals discussed below The FCC, at the request of the mobile industry, is proposing changes to the PAL rules so they are friendlier to national mobile carriers. If adopted, the proposed rules would effectively foreclose small companies that wish to acquire protected spectrum for small areas and create a “5G-only” band available only to the large mobile wireless providers. The specific proposals are as follows: > Conduct PAL auctions based on Partial Economic Areas (PEAs) or other > geographic areas that are larger than census tracts, such as counties. There > are 416 PEAs and more than 74,000 census tracts. Census tracts are optimized > at a population of ~4,000. > Extend Priority Access License (PAL) terms from 3 years to 10 years and add > a “renewal expectancy” that could make PALs essentially perpetual. 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 that are likely much larger than the targeted areas WISPs would want to serve. Guidelines • Please review the NPRM • You can also review WISPA’s recent comments in meetings with Chairman Pai and Commissioner O’Rielly, which are attached to this email • File comments unique to your company, not “cookie-cutter” comments o BE AS SPECIFIC AS YOU CAN BE – THE FCC WILL LOOK AT THE SUBSTANCE OF THE ARGUMENTS MADE, NOT OVERBROAD STATEMENTS 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, especially if those investment were made in reliance on the CBRS rules that were adopted in April 2015 • Plans for gaining access to the CBRS band • How expanding the geographic area of PALs to an area larger than census tracts will dramatically reduce your ability to make competitive bids at the PAL auction, because you have to acquire a much larger area than you plan to use to connect unserved and/or provide better service to your existing customers • Benefits of having the ability to get access to 100 megahertz of mid-band spectrum • Any reduction in investment based on the threat of the proposals in the NPRM • 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 Include maps of your service area, showing PEA boundaries, and identifying areas where licensed mid-band spectrum would help you connect additional customers or provide better service to existing customers 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 proposals to increase the size of PALs or lengthen the term of licenses • We are happy to answer questions, provide suggestions and assist in filing your Comments. Please contact the WISPA DC team (email [email protected]<mailto:[email protected]> who will forward your request for assistance to the appropriate member of WISPA’s team) INSTRUCTIONS FOR FILING YOUR COMMENTS WITH THE FCC IN GN Docket No. 17-258 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 Proceedings: 17-258 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 Thursday, December 28 at 11:59 pm Eastern Time Thank you. Attached is a link to a site which will allow you to overlay state-by-state census tracts with Partial Economic Areas (PEA). Registration is required to access the site, use this registration form<https://wispa.allpointsbroadband.net/accounts/register/>. After registering, you can select the states to display census tracts from. and add the PEA layer in the menu on the left. You can click on any tract or PEA to display data about it in a popup window. https://wispa.allpointsbroadband.net/ A few notes: * The order you add layers to the map matters; think of it like adding physical layers. If you add tract layers first, then the PEA layer, when you click you will see data about the PEA you clicked. If you add the PEA layer first, then tracts, you will see census data when you click because the tract layer will be "on top" * Due to technical limitations you can only display a handful layers concurrently, if you try to select too many they will not load, and you may need to refresh the page * When zoomed-out, holes may appear in the tract layers, especially around population centers. When you zoom in those holes will fill in. For technical or registration issues please contact Michael Hespenheide ([email protected]<mailto:[email protected]>)
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