I look forward to reading everyone's comments - especially after I
stole some very useful paragraphs from a few of you. :)
----- Original Message -----
*From:* Ken Garnett <mailto:[email protected]>
*To:* 'WISPA General List' <mailto:[email protected]> ;
[email protected] <mailto:[email protected]> ; 'Principal WISPA
Member List' <mailto:[email protected]>
*Sent:* Thursday, December 28, 2017 10:17 PM
*Subject:* Re: [WISPA] Last day to file CBRS Comments is today.
Please file ifyou have not already done so.
Done.
Proceeding:17-258
Confirmation #:201712293080913313
Submitted:Dec 28, 2017 8:07:52 PM
Status:RECEIVED
Name(s) of Filer(s)Cal.net, Inc.
- Ken Garnett
Chief Technology Officer
Cal.Net
530-672-1078, x103
*From:*[email protected]
<mailto:[email protected]>
[mailto:[email protected]] *On Behalf Of *Mark Radabaugh
*Sent:* Thursday, December 28, 2017 4:58 AM
*To:* [email protected] <mailto:[email protected]>; Principal
WISPA Member List <[email protected] <mailto:[email protected]>>;
[email protected] <mailto:[email protected]>
*Subject:* [WISPA] 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:
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
[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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