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 <dmmoff...@gmail.com> 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). > 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" <mhoward...@gmail.com> > To: "af" <af@afmug.com> > 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 <dmmoff...@gmail.com> wrote: > >> Trying to find time to read the whole NPRM before making an opinion, but >> it does sound bad. >> >> >> ------ Original Message ------ >> From: "Dave" <dmilho...@wletc.com> >> To: "Animal Farm" <af@afmug.com> >> Sent: 7/20/2017 4:39:18 PM >> Subject: [AFMUG] CBRS in trouble >> >> Anyone else doing this >> >> http://files.constantcontact.com/d4d6cd6a501/40256872-b6da-4 >> 840-b79d-61e111535347.pdf >> >> -- >> >> >
