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Vantage Point files Comments re: 3.5 GHz Band with the FCC

January 2, 2018

Vantage Point Solutions recently filed comments in response to the FCC’s Notice of Proposed Rulemaking seeking comment on several contemplated changes to its rules governing Priority Access Licenses (PALs) that are to be issued in 3550-3700 MHz band (3.5 GHz Band).

Comments summary:

  • Among the many proposed changes for which comment is being sought, the Commission’s contemplated rulemaking, particularly to enlarge PAL geographic license areas to Partial Economic Areas, to impose buildout requirements, and/or to enlarge the 40 MHz spectrum aggregation limit, will serve to limit and even preclude access to PAL licenses by small and rural providers.

 

  • Especially since these particular contemplated rule changes will have comparatively little impact on investment interest compared to the more pressing concerns raised by the major, nationwide carriers, such as short license terms and lack of renewability, they should be abandoned so as not to stifle participation by small and rural providers. Such protection is mandated by Congress.

 

  • Further, licensee access to Citizens Broadband Service Device registration information is crucial for network planning, has not been harmful in the past, and should not be limited.

 

You can view Vantage Point’s full comments here: VPS Comments to FCC re: 3.5 GHz Band