yep, and a self fulfilling failure on the part of the FCC.    The FCC looked at 
the registered CPE and decided that WISP’s were not using the band without ever 
considering how badly they fubared the entire registration process.

You WISP’s don’t need an extension, you didn’t use the band.   Uh, yeah.

Mark

> On Jan 27, 2020, at 10:16 AM, Ken Hohhof <af...@kwisp.com> wrote:
> 
> That whole process was such a joke.  You were supposed to register the AP 
> locations and then each subscriber location BEFORE you installed them and 
> wait several weeks for the FCC to mail you the notice of registration.  As if 
> any customer would order service and then wait for the FCC to let you 
> install.  But a side effect was that you could just register a whole bunch of 
> prospective locations, with no requirement they actually be installed.  And 
> many of us failed to understand that the grandfathered protection areas would 
> be based on registered subscriber locations, not AP sector coverage.  So 
> given the timeframe, many of us were deploying a bunch of APs but didn’t have 
> many subscribers yet, and those were maybe close to the AP.  With the 
> advantage of hindsight, the thing to do was to register several locations at 
> the far reach of every AP to define your protection area.  A few WISPs seemed 
> to realize this, judging from the flood of applications the FCC received days 
> before the deadline, resulting in a several month backlog.
>  
> And of course the application process was a formality, the only reason they 
> would be denied was somebody typed something wrong.  Of some catch 22.  Like 
> we had a Purewave basestation in an optional mode where it used 3 x 120 
> degree sectors essentially as an omni.  But the FCC would kick back the 
> location registration if we put 360 degrees as the antenna coverage.  We 
> ultimately had to register it as 120 degrees.  Yet this was not like Part 101 
> where they are actually approving your path, frequencies, EIRP, etc.  It was 
> more like a CAPTCHA to prove you could type accurately.
>  
>  
> From: AF <af-boun...@af.afmug.com <mailto:af-boun...@af.afmug.com>> On Behalf 
> Of dave via AF
> Sent: Monday, January 27, 2020 8:47 AM
> To: af@af.afmug.com <mailto:af@af.afmug.com>
> Cc: dave <dmilho...@wletc.com <mailto:dmilho...@wletc.com>>
> Subject: Re: [AFMUG] FCC 3.5 GHz Spectrum Auction 105
>  
> I guess it would make sense for those who are wanting to have something 
> inside the metro areas or places with dense population otherwise yes this is 
> a great opportunity for those who are in the rural areas. 
> I have both so I am wanting at least 1 pal to secure our future here. 
> I dont have too much anticipation that the telcos will light up much here but 
> we want to be prepared.
> We also missed the deadline on locking in our existing APs at the time of 
> april 2015 so its somewhat crucial we have something to lean on.
>  
> 
> <image001.jpg>
> On 1/26/20 7:29 AM, Mark Radabaugh wrote:
>> 10 years of idle time without getting a return on your investment, while the 
>> GAA user use the spectrum for free.   Not a winning investment, though there 
>> is a lot of stupid money out there. 
>>  
>> Mark
>> 
>> 
>>> On Jan 25, 2020, at 9:30 PM, Steve Jones <thatoneguyst...@gmail.com 
>>> <mailto:thatoneguyst...@gmail.com>> wrote:
>>>  
>>> So 10 years of idle time means you cannot renew. It's definitely an 
>>> investors game
>>>  
>>> On Sat, Jan 25, 2020, 12:02 PM Mark Radabaugh <m...@amplex.net 
>>> <mailto:m...@amplex.net>> wrote:
>>>> In the interest of getting the ACTUAL rules into this discussion instead 
>>>> of just speculation, this is what the FCC rules are on term and renewal 
>>>> requirements: 
>>>>  
>>>> (3)  License term:  Each PAL has a ten-year license term.  Licensees must 
>>>> file a renewal application in accordance with the provisions of Section 
>>>> 1.949.
>>>> 
>>>> (4)  Performance requirement:  Priority Access Licensees must provide 
>>>> substantial service in their license area by the end of the initial 
>>>> license term.  “Substantial” service is defined as service which is sound, 
>>>> favorable, and substantially above the level of mediocre service which 
>>>> might minimally warrant renewal.  Failure by any licensee to meet this 
>>>> requirement will result in forfeiture of the license without further 
>>>> Commission action, and the licensee will be ineligible to regain it.   
>>>> <>Licensees shall demonstrate compliance with the performance requirement 
>>>> by filing a construction notification with the Commission in accordance 
>>>> with the provisions set forth in § 1.946(d) of this chapter.  The licensee 
>>>> must certify whether it has met the performance requirement, and file 
>>>> supporting documentation, including description and demonstration of the 
>>>> bona fide service provided, electronic maps accurately depicting the 
>>>> boundaries of the license area and where in the license area the licensee 
>>>> provides service that meets the performance requirement, supporting 
>>>> technical documentation, any population-related assumptions or data used 
>>>> in determining the population covered by a service to the extent any were 
>>>> relied upon, and any other information the Wireless Telecommunications 
>>>> Bureau may prescribe by public notice.  A licensee’s showing of 
>>>> substantial service may not rely on service coverage outside of the PAL 
>>>> Protection Areas of registered CBSDs or on deployments that are not 
>>>> reflected in SAS records of CBSD registrations.  
>>>> 
>>>> (i)  Safe harbor for mobile or point-to-multipoint service.  A Priority 
>>>> Access Licensee providing a mobile service or point-to-multipoint service 
>>>> may demonstrate substantial service by showing that it provides signal 
>>>> coverage and offers service, either to customers or for internal use, over 
>>>> at least 50 percent of the population in the license area.
>>>> 
>>>> (ii)  Safe harbor for fixed point-to-point service.  A Priority Access 
>>>> Licensee providing a fixed point-to-point service may demonstrate 
>>>> substantial service by showing that it has constructed and operates at 
>>>> least four links, either to customers or for internal use, in license 
>>>> areas with 134,000 population or less and in license areas with greater 
>>>> population, a minimum number of links equal to the population of the 
>>>> license area divided by 33,500 and rounded up to the nearest whole number. 
>>>>  To satisfy this provision, such links must operate using registered 
>>>> Category B CBSDs.
>>>> 
>>>>  
>>>> 
>>>> Mark Radabaugh
>>>> WISPA Policy Committee Chair
>>>> 419-261-5996
>>>>  
>>>> Mark
>>>>  
>>>> 
>>>> 
>>>>> On Jan 24, 2020, at 6:30 PM, Seth Mattinen <se...@rollernet.us 
>>>>> <mailto:se...@rollernet.us>> wrote:
>>>>>  
>>>>> On 1/24/20 3:07 PM, Steve Jones wrote:
>>>>> 
>>>>>> You have to actually have gear up, it's not like n license where you 
>>>>>> just register. It's got to be live and transmitting, and it's verified 
>>>>>> every 4 minutes
>>>>> 
>>>>> 
>>>>> Right, someone gets the PALs, does nothing so it's usable as GAA, then at 
>>>>> some point later start transmitting in the PAL to kick the GAA users 
>>>>> somewhere else possibly more congested.
>>>>> 
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>> 
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