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:
Ø*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.
Ø*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*
oExplain 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)?
oAs 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.
oInclude 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
oFocus on consumers
oFor rural providers: focus on extending fixed broadband service to
rural Americans that lack broadband or choice
oBe 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
sco...@lermansenter.com <mailto:steve.co...@lermansenter.com> 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
(mhespenhe...@allpointsbroadband.com
<mailto:mhespenhe...@allpointsbroadband.com>)
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