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> On Behalf Of dave via AF
Sent: Monday, January 27, 2020 8:47 AM
To: af@af.afmug.com
Cc: dave <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.
 




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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