 I hope you all noticed there were, of course, food and handouts outside. Welcome to New America. I am Michael Calabrese. I direct the Wireless Future project here, which is part of our Open Technology Institute. This event is on auctioning America's wireless future. Who's going to have the spectrum for the next generation of ultra-fast, low-latency networks? And we're particularly talking about the Citizens Broadband Service. And back in April 2015, the FCC voted unanimously 5.0 to adopt a breakthrough spectrum sharing order. CBRS, the Citizens Band Service, opens a large band of high-quality spectrum for both licensed and unlicensed sharing with U.S. Navy radar operations at 3.5 gigahertz. So this is something new and innovative, because until now, spectrum bands have typically been either, you might say black or white. You know, they've been either exclusively licensed, for example, for cellular services or for television or whatever, or unlicensed, which is bands, of course, that Wi-Fi use. Or they've been allocated for military or other federal users, and those bands are managed by the NTIA, part of the Commerce Department. But CBRS is premised on a unique framework that is designed to make licensed spectrum affordable for a diverse set of localized users and use cases. The proposal for this multi-tiered sharing approach came originally back in 2012 from the President's Council of Advisors on Science and Technology. Their report focused on opening federal bands for sharing, the reason being that the federal government had the largest amount of spectrum, but often for uses such as radar, such as naval radar off the coast, most of the bandwidth is not in use, at least not in most places or at most times. And the question was, you know, what's the best way, since all the good spectrum has been assigned to somebody, how do we open bands dynamically for sharing? And so the recommendation was essentially what became the Citizens Broadband Service. The final order was adopted in last year in May 2016, resolving petitions for reconsideration and charging the Wireless Innovation Forum to host a industry multi-stakeholder process that I'm sure you'll hear a bit more about later to hammer out the technical rule, because this is, you know, certainly the most complex approach toward spectrum access that's ever been attempted since it involves three different types of services essentially operating across a band together. So what I figure is, I don't want to chew up too much time, but I should just give you just a quick overview of what the Citizens Broadband Service is, you know, what the framework is, so that then the speakers actually don't have to do that piecemeal. Essentially, we're talking about 150 megahertz of spectrum between 35, 50, and 3,700 megahertz that would be shared with incumbents that include Navy radar and also satellite earth stations that are in the adjacent band and have to be protected as well. So it's a three-tier spectrum sharing hierarchy, and on that handout, you see that pyramid in the upper right that pretty much explains it, that's, you know, kind of become the classic description, which is at the top of the pyramid, you have the Navy. You have what's called incumbent access, Navy radar. Then there is a spectrum access system, a geolocation database system that will facilitate sharing along with the sensing system, and that will enable sharing of two flavors. One is priority access licenses, which we'll be probably talking and debating a bit quite a bit, because that's what's sort of at issue right now about what the terms of those priority access licenses will be. Currently, it's the bottom 70 megahertz of the band will be for seven priority access licenses, each being 10 megahertz. They have three-year terms, but the initial term can be up to six years. It was sort of a start, you know, recognizing a kind of start-up time with a new service, new equipment, new deployments, and so the licenses are, you know, that's unusually short terms. It's also not automatically renewable, so at the end of each license term, there's competitive renewal, meaning there would be, if there's contention, in other words, if there's demand for more than seven licenses in each local area, there would be an auction again. And so there would probably be an auction every three years in the future under the current, excuse me, under the current rules. And then another key feature is the license areas are very small by the standards of FCC auctions. They're just census tracts, and census tracts, you know, of course, in a city like New York could be a few square blocks, or they're much bigger, obviously, out once you get out into the suburbs and into rural areas, but they're still incredibly small. There are thousands, tens of thousands of census tracts nationwide, whereas FCC licenses are often, like in the TV incentive auction, was based on partial economic areas, which itself was also small by historical standards. The Competitive Carriers Association had pushed for these smaller PEAs, and there's only 416 of them nationwide, so they're multi-county areas. And then finally is general authorized access, which is 80 megahertz of the band. So the band's roughly divided in half, and it's not unlicensed, contrary to what I said earlier, it's licensed by rule, but it's open access. Anybody can use it just like unlicensed, just like Wi-Fi, you might say, except there is a registration requirement, and of course, like the PALs, like the Prior to Access License Operators, the GAA users will be subject to control by the database. And so sharing is governed by this geolocation database called the Spectrum Access System. And essentially what it does is devices are required to check frequently and make sure that there's not a Navy ship, for example, pulling up the ports, which shouldn't be much of a problem in Iowa, but the majority of the population lives along the coast, and so that's why this is critical. And in coupled with that is a environmental sensing capability. So essentially a network of sensors up and down the coast, all the way around the United States, that would hear the Navy ships approaching the coast and then alert the SAS, which would in turn tell the devices if necessary to change channels. And for that reason, something that's also very unusual is that the Prior to Access Licenses are not for a specific frequency band. Everything that's been auctioned before has been specifically for a certain piece of the airwaves, but what a PAL entitles you to is 10 MHz of Spectrum with interference protection, but you may have to move. If the Navy ship comes, your device has to be capable of frequency hopping of automatically switching to another channel in the band. And for that reason, both the license and the GA gear, all the equipment that's certified for the band is required to operate across the entire band. In addition, one last feature, interestingly, which what we pushed heavily for is that the GAA users, in other words, the quasi-unlicensed use, is permitted on any of the spectrum in the band across the entire 150 MHz when it's not in use. So for example, if somebody acquires a set of Prior to Access Licenses in the New York area and it takes them two years to actually deploy service, during those two years, that spectrum is available for open public use on a GAA basis. As soon as they commence service, they notify the SAS. The SAS notifies the GAA guys, get the heck off their channel. So you're only green-lighted, kind of hour-to-hour for the channels that are not in use by somebody higher up the food chain. So I know that sounds complicated, which is why this wind-form process has spent tens of thousands of hours, probably collectively, among all the companies working out all the air interfaces and all the rules. But that's where we stand. So we're going to have two panels. This first one is, I think of them as the unusual suspects, in a way. Because typically when we have these events, you know, it's all, pretty much who you can expect is always, you know, Verizon, AT&T, Facebook, Google, et cetera, you know, kind of the usual big players in spectrum proceedings. But CBRS is a very different situation because these small license areas and other aspects has really promised to open this up to new uses and new users. And we have many of them represented here. So what I'll do is I'm going to ask an initial question to each of you as a way of, by way of introduction. So I'll remind the audience. But you have their bios. I'm just going to give name, rank, and serial number because you have their bios. And then we'll have some discussion and then we'll open it up to your questions and comments after each of the panels. And probably, you know, just 50 or some minutes or so. You know, then we'll switch over to the other, to the second panel, which will focus more on the regulatory issues specifically. So Michael Fitzpatrick, immediately here on my left, is the head of regulatory advocacy for General Electric here in DC and develops regulatory strategy across all of GE's diverse business groups. Michael, GE, you know, as I was just saying, GE doesn't often file comments on spectrum allocations and rules. So why this time, what sort of innovations and use cases are you expecting that makes us spend important to GE's business? Thank you. Michael, it's great to be here and you're right. We aren't traditionally in these conversations, although increasingly we are and will be because spectrum policy is becoming important to every commercial, industrial enterprise in the United States. So let me take, if I could, a quick step back and do a brief commercial on what GE is today because it's highly relevant to why I'm sitting here next to you today. And then I'm going to talk about some really big picture ideas on why this is such an important policy. And then when we get into the discussion, we can dig down deeper into it. So first of all, General Electric is a large conglomerate. We build, cure, power, move the world. We are a large infrastructure company. Jet engines, locomotives, gas powered turbines, wind turbines, grid management, health care machines, sophisticated health care machines and jet engines. Okay, so we are in a sense making the infrastructure for the 21st century globally. What's the big idea is that the fourth industrial revolution is upon us and it has to do with machine to machine communication. It has to do with harnessing the power of big data and predictive analytics to make our world better, safer, more resilient and more efficient. Okay, it's kind of like in the movie The Graduate, Plastics. Well, it's IIOT. That is the future, at least for the next generation. And this policy catalyzes the potential of the industrial internet. So let me speak a little bit about what that is. All of our machines now aren't simply pieces of steel and wire. They are literally supercomputers and they are throwing off terabytes of information every minute hour, operation cycle. Okay, a jet engine is throwing off information at 1,000 parameters every second. And that information can be aggregated into vast data lakes in the cloud securely, very securely. And you can mine the data in that lake to create operational efficiency. You can predict malfunction. You can predict accidents. You can improve efficiency and efficacy of operations. And that can yield to huge economic benefits and huge safety benefits. And our customers understand that. We sell them a machine now. We're also selling them the capacity for that machine to operate better into the future and more safely. We sell them actually an outcome, a performance outcome. And that's all enabled by getting this data from the edge to the cloud. And you get from the edge to the cloud increasingly in this spectrum space, okay, because it meets the requirements so perfectly for us and for our customers. Let me give you a couple quick examples. Jet engines, as I said, are spinning off all this information. When that plane lands, you can go up and plug a laptop into the engine, download the information with a human being, then go to another computer and transfer it into the cloud somewhere. Or that plane can be throwing that information into the cloud in real time, okay? If you've got a pipeline that has a SCADA system that's sensing pipeline flows, okay, and there's an emergency situation, you want the valves to close instantaneously, right? You want that instantaneous communication, that resilient communication to occur. So this is also a question of critical infrastructure. It has implications for the national interest in terms of our safety and national security. It has to do with improving safety of our systems, and it has to do with economic performance. So when we saw this spectrum and this innovative idea being introduced, we were all on board. Because it provides small geographic units, it provides us and our customers with the opportunity to economically purchase bandwidth that works for our purposes, okay? And they're myriad, as I was saying. And if we were to go to a regime where we would essentially be licensing this if we were able from a large cellular carrier, query whether we would be able to. Query whether our customers would be able to afford it. It adds a lot of uncertainty and inefficiency into the process. So our view is the spectrum is a precious national resource. This policy supports national interest on so many levels, including helping America win the industrial internet era, the Fourth Revolution. And any alteration to a policy that seems to be successfully launched and gaining traction appears to us a little bit like a solution in search of a problem. Last point I'll make, this is happening now. This isn't speculative. We are making these devices, these technologies. Now we had 10,000 SCADA radios in the field supporting critical infrastructure before this policy went in place. And they were protected by the policy. We're now leveraging this to go to scale way beyond that. And it's happening as we speak. So this isn't some ephemeral future benefit for the country. It's happening right now. Thanks, Michael. We'll go next to Joe Canfield, who is Vice President and Assistant General Counsel of NTCA, excuse me, the Rural Broadband Association. So Joe NTCA represents smaller, typically more rural carriers. Can you tell us a bit about how your ISP members plan to leverage PAL and GAA spectrum and whether access to the licensed portion of the band will be important for connecting more rural homes and businesses? Sure, in order to understand really what our members interested is in this band, you really have to understand who our members are. So NTCA represents about 850 rural broadband providers. And that's kind of a mix between commercial companies, typically family-owned businesses and cooperatives, community-owned telcos. And our members serve the most sparsely populated, difficult to serve areas of the country. And they're difficult to serve because of topography, weather, and also just the economics of serving really, really rural areas. There just aren't a lot of people to support a system. Our companies exist mostly because the large companies weren't willing to serve these areas. And when you hear a large company, you know, AT&T or Verizon, talk about rural. They're not talking about our rural. Our rural is rural, rural. Our members serve about 40% of the country's land mass, land mass but only about 5% of the subscribers. So all of our members offer broadband, right? They do this to most of the communities. All of them do it through a wire line service, but we also have wireless. Now, when you're serving a ranch that's maybe a mile and a half from its closest neighbor and the ranch house is half a mile from the road, it's not economical to get fiber to that ranch, right? So you might use wireless as a solution to get service to that area. To give you sort of context, our members serve an average of seven subscribers per square mile. And you compare that to a large company that serves 130 subscribers per square mile. So it's a different solution when you're talking about serving a rural community. And they have to be very creative in doing that. Our members also offer a video product. Most of them offer video. And we have some that offer a wireless mobile product as well. The use of Spectrum, it's really important to the membership because it can be a very efficient way to get service out. And our members are already doing this. And in order to make it a continued solution for rural communities, the Spectrum has to be affordable. And it has to be licensed in a way that covers just the territory the company is willing to serve. So when you put something at auction, our members are competing against an AT&T or Verizon or even T-Mobile. They will not win. They just simply don't have the resources to that. They have never won. They will not win if they're interested in the same Spectrum resource. So it's just, when we're talking now, just nearly a year after the FCC issued its latest order on reconsideration, we're talking about opening this Spectrum band completely up to a business plan that really suits just the nation's largest mobile providers. It creates a lot of uncertainty for companies now where they've started with plans and now they're all pulling them back. And it has the potential to completely upend what I think is going to be a very useful and creative resource for small companies serving rural communities. Our multi-billion dollar commercial industrial and infrastructure companies would agree with rural users that they won't win at auction because it doesn't meet the business case, right? So it's a really interesting feature of this. Yes. Buying an area that's 10 times as big as they need or 1,000 times bigger than they need. In your case, yeah. So we'll go to Patrick Leary. Patrick is president of Bicel Technologies North America, a provider of disruptive LTE solutions. So Patrick, tell us a bit about Bicels and what you were seeing in the marketplace. What sort of use cases you expect to be supporting? Thank you, Michael, and thank you, New America Foundation and you folks for attending and those of you online. So at less than four years old and over 350 patents and 10 patents pending, Bicels is what you might call an innovation engine. We were found specifically wrapped around LTE. We were founded by one of what they call the 12 Fellows at Woway, specifically the gentleman that built and ran its IPR division. So the one that really put Woway on the map for LTE. So we participate in everything from narrow band LTE, small cell, indoor and out, and rural broadband. And North America, even though we've only been selling for commercially about less than one year, we've got about 300 small operators. Among them are NTCA members. In addition, among them are customers that use GE equipment from utilities. So we understand from which both of these gentlemen and the lady come from on their opinions. There's a bit of serendipity that happened in the past week that really should help inform your opinions and should frame some of our conversation. And I love it when that kind of thing happens, well-timed. One was a piece that came out, I believe it was September 11th of this year, by the GSMA that said, there is expected $1.8 trillion in IoT revenue for carriers by 2026. Now, what do you suppose would be the greatest threat to that carrier revenue? And that would be the ability of NTCA members, private network operators, whether they're hospitality, whether they're healthcare, or virtually anyone, because the use cases are as broad as Wi-Fi, of that I guarantee you. So the biggest threat to that revenue comes from the ability of all these other entities to get low-cost priority access licenses, so they can build their private network. And instead of shedding that off X to pay a carrier, they can do that in-house. So, I would contend that it's the goal of the four carriers to drive up the cost of a PAL equal to or greater than the cost of what that operator or entity would otherwise be paying for IOC services. So I think you should pay attention to that metric. Second, a kind of comical bit of news came out just very recently that a lot of people up north received a letter from Verizon, some 8,500 of them, saying that their broadband, they were being canceled as customers because they were too using too much of their unlimited data, which is let's just say oxymoronic, right? But that should have informed our opinions about what and what is not a broadband provider. So having said that, CBRS is something I've been tracking actually way long before the first NPRN came out in December of 2012. And here to tell you, this has a potential economic impact equal to or greater than Wi-Fi for a huge amount of reasons. There's a phenomenal amount of spectrum orphans that exist out there, whether it's Lockheed Martin, whether it's someone in the oil patch, whether it's a utility, whether it's a hospital having to deal with HIPAA problems or bang doing secure transactions or hospitality which has to use Wi-Fi services and internal operations. So CBRS gives all these entities for the first time since the development of Wi-Fi, the ability to do what they do in a much better and more secure way. And to do it potentially with protected spectrum. It's a phenomenal sort of idea. Only reason all these folks use Wi-Fi today, there's only one reason. Anyone venture a guess? They're only choice. So what happens? They have to bolt on all the security infrastructure on top of it. Wi-Fi is a fantastic technology. It saved carriers, bacon, billions of dollars. We all use it every day. But this was not what it was intended for, right? It's intended to be best effort service. So if you're doing critical infrastructure, for example, utilities in the US, make no mistake, that is critical infrastructure. Our friends up north in Canada, the Canadians have 1.8 spectrum for utilities. We don't have that opportunity here. Intelligence is being driven to the edge. They need to connect things and they need to do these things using a standard technology, not some proprietary kind of one-off that binds them to a very small number of vendors and not with Wi-Fi which is being shared by all kinds of other devices completely beyond their control. I don't know about you, but if wireless has a role to play in the performance of a jet engine, I fly a lot. I'd prefer that was happening off some of the technology other than Wi-Fi. So I would urge that if the rules don't change too much and I'm supportive of the carriers' arguments, and some of them I can even agree with, especially the right of renewal and maybe some extended term. But if you make the cost prohibitive for kind of the lowest common denominator user to secure a pal, and I mean maybe some like Scripps Ranch or whoever it is, then you foreclose on the opportunity of this band to literally transform the telecommunications space. Thanks, Patrick. Next up, Chris Kimbrough is CBRE's managing director for in-building solutions within its telecom advisory services group. So real estate sector here. Chris, high quality connectivity everywhere is increasingly critical for office complexes and other real estate development. How do you see your clients making use of this new citizen's band spectrum and what sort of use cases do you expect to support? I'd like to start to say I think I'm the most unusual of the unusual suspects up here. So I think I'm going to echo a lot of what's already been said, but also kind of move it down into smaller spaces because for those of you who don't know CBRE, we are the world's largest property management, commercial real estate management firm. In the US, we have about three billion square feet under management. So we have clients that range, run the gamut, properties that run the gamut from 5,000 square feet up to millions of square feet. We have clients that own one property. We have clients that own many, many, many properties. We work across the gamut. So, and our focus really is on client service. That is, we're here to deliver world-class solutions to our clients. And the promise of CBRS at the high level for us is this ability to help provision these end-building systems with multi-carriers on them. That's always front of mind when we are looking at our vast portfolio of properties that we have under management and the increased need for connectivity is how do we get it in the first place? So really getting CBRS out there is vital for us. Vital for our clients. That being said, I think that there are specific use cases that, first of all, I know, and we were discussing this earlier in the green room. I don't even think, everybody's talking about innovation in this space. And I don't even think that, and I've said this in other contexts, that we're gonna see the breadth of what CBRS, what can be accomplished with CBRS until we see it deployed. And so I think that it would be beneficial to have it deployed, as broadly as possible, without too many restrictions on who can have access to it. And because when I start to think of use cases within commercial real estate, and commercial real estate isn't really focused on, it's not like everybody's out there chattering about CBRS the way we are. It's not a big, but it's clearly not on most people's radar. But once it gets on their radar, the use cases that I can see are in commercial. I focus on multi-tenant office space. I was with two clients last week, two of our major clients, and both of them delivered kind of the same message in the context of broader conversations, which is we're looking for ways to deploy IoT, smart building technology, building automation systems, all in an integrated system that's secure that allows us to better manage their properties for them, and provide these efficiencies that will drive down the cost of managing properties and drive down the cost of operating them. So while GE has a very specific use case for doing this, it does replicate itself in smaller contexts across multi-tenant office space. Also, we manage across different verticals. We have industrial properties to varying levels. We also manage hospitality spaces, medical health center, retail, you name it. We're probably in it. All of those use cases, again, you can see where our industrial clients would have a very, you know, would be very focused on being able to use that IoT functionality within a CBRS-enabled system to make their current industrial facilities function more efficiently. If you look at provisioning for hospitality, it's becoming more and more of an issue and it's something that we are trying to, again, we're trying to help our clients and right now it's a struggle. So the potential for CBRS to help us help our clients is, I think, just phenomenal. But it is about getting it out there and allowing the most innovation to take place because I think until our clients and our managers and our technical people get their hands on it and really have the ability to, you know, kind of play with it in real time, in real space, that we're not going to see all of the potential of it and we can't tell it too much on the front end. I think you're just, you do have the potential to kill that innovation. And, you know, again, three billion square feet. There's a lot of room for innovation there if we have, you know, the ability to help service our clients with, you know, the correct level of access for the system. So. Thanks, Chris. And our final introduction is Patrick Dunphy, who is the CIO at Hospitality Technology Next Generation. Patrick, why is the hotel industry interested in this band? Isn't Wi-Fi good enough for you? Because Wi-Fi's obviously become, you know, an essential, in fact, some service show the essential amenity at hotels, convention centers, even restaurants. So how would the venues you represent make use of small area licenses for LTE? That seems like it's going a step beyond. Thank you. So the primary use case really focuses around redistributing the macro network inside of the hotel itself. At least historically, hotels have been very underserved. A small ecosystem of providers with very little innovation over the last 10 to 15 years, and often a one to five year cycle to get approval from an MNO to deploy an in-building cellular network, which at least currently costs anywhere between two and three million dollars for a large 500,000 square foot convention space, and obviously quite a bit more as you scale up. So my hope is with the appropriate regulations and smaller licensing sites that in-building cellular will be deployed like Wi-Fi in the near future. I think we'll always have guests facing Wi-Fi, no matter what we do, because that's at least the status quo for now. Longer term, I think there'll be 8th back, building management systems, and quite a bit more focusing on IoT, hopefully through providers like IBM. So that's the longer term play, but perhaps most important is that we have a healthy ecosystem of suppliers. And if this licensing band is simply available only to people with billions of dollars to spend on Spectrum, we're going to lose out and lose out bad. We'll be in the same situation that we are right now with poor in-building cellular coverage, which most of our hotel owners cannot afford for the foreseeable future. Okay. Thanks. Well, let me turn back, maybe initial with a first moderator question to you two at the end, Patrick Dunphy and Chris, probably because Patrick Leary alluded to this, but I think it's good to, I'm kind of interested for particular like hotels and real estate and maybe some other verticals, maybe Michael Fitch and again. But why not simply buy these services for mobile carriers? The automakers are increasingly putting cellular connectivity into cars, but they're doing that through AT&T and Verizon. So why don't you just sit back and relax? The big carriers will build out on these bands and then you can just buy what you need from them, right? You're going to guarantee that? Why not? You're going to guarantee it? Can I get it in writing? I mean, I think that's, we had up in the same situation we're in now, where we're asking the carriers for every single property, for service and the ability to turn on our four carriers at once as opposed to having to ask each carrier individually for access is a big differentiator. So that's a mutual host network concept? Yeah, yeah. So major metropolitan areas have much less of an issue than rural areas, so I certainly share your opinion on that. Most rural hotels will never, ever get support from a major network operator to deploy an end-building network. It's just not cost-effective for them to provide the backhaul for it, and it's not cost-effective for the hotel owner to buy the equipment necessary to do that. So there's a couple of third-party providers that exist in the industry today that fill that gap. There are not that many of them. They all, again, focus on getting MNO approval, and they have a much easier time of it than hotel owners do, but until these networks can be deployed in the space of months and not years, we're not happy with the status quo. Well, it brings up an interesting point of scale on two levels. One, the scale of the property itself is a barrier to getting cellular service into the building. And two, there are not that many service providers out there that can implement these systems as in the way they are now. They're fairly complex systems. They're not easy to design. And so there's the scale of actually provisioning these systems. Of having the resources out there to provision them. Whereas with the implementation, presumably with CBRF, would be more streamlined. And if it's more streamlined, then we can have a greater scale of implementation. And that's going to service everybody because you can't, right now, it's a struggle to find the resources to even get the system built. We're talking rural areas, you're also talking IOT and rural areas where you're talking about connected tractors and farming equipment now. And you may need that connectivity during planting season and harvest season, but not potentially throughout the entire growing season or the fellow season. So to get a large carrier to put a tower to cover a field that the spectrum is only being used a couple of times a year, but intensely during that couple of times a year, it's just not going to happen. So it makes far more sense to get that spectrum in the hands of someone who really does want to use it. Let me just, you seem to have touched a point here. So just let me lay out some of the verticals that this has application to just from GE's perspective. Ports, freight rail lines, hospitals all over America, transmission lines and utility power stations, refineries, the oil fields. So individual well pads and production and distribution facilities out in areas that have more cows than people. Aviation, wind farms. The idea, it's just hard to imagine how added cost, added uncertainty, and by cost I mean real cost and transaction cost, added uncertainty, the perhaps inability to have primacy because so much of this is critical infrastructure, so you need to have protected, dedicated spectrum. So it's not going to be well served by GAAs and the potential for interference. That construct doesn't fit with this. And I would return to, I would flip the question and say, why should we? I mean the whole point of this policy in the sense of its brilliance was that it took one piece of spectrum that here too fore been dedicated to the government. And the government made a policy decision that to benefit the most people, it was called citizens for a reason, to benefit the most people, the most innovation, the most application in America, we were going to try this novel experiment. And the experiment is working. It has the potential to be massively beneficial for the United States of America to catalyze innovation, to catalyze economic growth, to catalyze social benefit. So as far as I know, I'm not quite sure what's happened since 2015. There may have been one thing that happened. I guess I'm not sure what, why the proposition, the merits of the proposition have changed other than you have companies like GE and others investing millions and millions of dollars in potentially stranded costs to actually carry out innovation in this span. And let me just end with one thought, which will be a topic of the next panel who I just saw went up to get mic'd up. And that are the regulatory questions surrounding this. That's my day job at GE. And I think I'm confident that the merits of this policy, the number of stakeholders who see the value in it, will carry the day in the end at the FCC. I think it's just the proposition speaks for itself. There are some real headwinds and challenges to changing this policy because it was promulgated through notice and comment rulemaking. It was a unanimous vote by the FCC which was upheld on a petition for reconsideration. And in order to change or overturn the policy, you have to have a record, an administrative record, that specifically demonstrates why the changes in policy are more compelling than the record that justified the policy in the first place. And so I'm not saying that we're gearing up for litigation or anything like that. I'm just saying, as a policymaker, one of the things you look at is, at the end of the road, are we going to be able to defend this in court? And what are the empirical reasons why this policy is changing? What are the changed circumstances that justify modification or revocation? And I would argue, I'm not sure that those are apparent to us. I think I can tell you certainly a couple things that happened. So the report in order on this is actually issued April 17, 2016, not 16. What happened since that period? Since that period example, in spring of 2016, both Facebook Live, Twitter Periscope, YouTube's Live, of which we're on right now, all were integrated into their general user platform, among many other things. So the streaming traffic statistics have gone bad. And the carriers start hitting the panic button, ding, ding, ding, ding, ding, ding. So the opportunity to maybe perhaps lay claim to some of this spectrum, I think, is borne partially out of that. And then when they saw the changes in administration, they thought, okay, maybe we have an entity a little bit more favorable this time around. But in terms of the other question, why not just carriers? Well, some carriers are doing a specific sort of IoT. And the sort that they are doing now, say, for example, something other than narrowband IoT, requires high-cost terminals. They may be 10 or more $15 terminals, which is price prohibitive if you're trying to drive that intelligence down to something really small, almost the size of something that should be RFID, that could really benefit from being connected. And it's that expensive because it has to talk up to the cell power. As opposed to talking using some other innovative technology like narrowband LTE, talking in a very short range, being able to leverage low power, low power enabling up a 10-year battery life kind of low power. So that's one reason the carrier may not be offering the kind of thing you need. Secondly, the word private network. Let's not forget the modifier here, private. What's the latest entity that's had their user information hacked? It's not Yahoo this week or it's them every week, but it's someone else, right? So if you're doing HIPAA stuff or secure transactions or the data mining that's going on now, you really want to throw that on more of a public network? Probably not, right? So the arguments are simple. They're legionned, and I agree with Michael that the premise that this has to evolve to support the carrier needs. It's not the carrier needs, it's the one. The rest of us have the needs. So I reject that the basis of that argument is frankly kind of offensive and ridiculous. Another contrarian view you might say is besides why not, we just talked about why not just buy services from the carriers, is the notion that why not just, why don't you all just rely on the GAA portion of the ban? So as I was saying at the top, you all recall, half the ban, the little more than half the ban will be available for general authorized access, which is open to anyone on the best efforts basis, very similar to Wi-Fi on license. I think Michael here has mentioned critical infrastructure, which suggests one reason, but I guess the question is, do lots of other use cases need interference protection? And then I guess at the same time, you could talk about like, but can you also leverage the GAA portion of the ban at the same time, even if you do need PALs? Yeah, very simply, flip the question, and ask the carrier the same question. What do they want licensed? Well, it's the same reason we want protection, right? Is our information or use cases any less important than their commercial motive? Absolutely not, right? I think that's very, very simple. But with some level of protection from interference, it's hard to justify that. And, you know, you're using it for wireless backhaul, for example, and you can't depend on it if it's not protected from interference. So can you say critical infrastructure, you mean a very specific thing, but then to your point, like, what really is critical? You know, it depends on how you define critical, and, you know, for our clients, critical may mean something entirely different, but it does rely on having that primacy. Yeah, well, maybe quality of service is critical to them. Or continuity of service, you know. I can think of a couple of cases where if they had interruptions during the day, it would be custom millions upon millions of dollars. Have critical functions occur in your space. Exactly. And then does the, I mean, something else, I think we argued in our filing, our comments, too, was that the use of the GAA portion of the ban would also be greatly diminished if there's not an opportunity for all, you know, all the users like you to have, you know, whether, I don't know how many pals you would necessarily need. You can only get up to four under the current rule, but whether it's one, two, three, four, or your, you know, to ensure that quality of service or that critical infrastructure. But then what about in terms of leveraging the availability of the GAA? Like, I think that's a great appeal to the carriers, too, because if they have two or three pals, they also have particularly a first mover vantage to make use of the 80 megahertz of GAA as well. They just put all that into the GAA, whether it's for redundancy or whatever, and maybe you reserve the pal just for your most critical thing, whatever it is, that's your thing. But you can also expect the carriers will use the GAA, too, just like they want to use 5GIG for LAA and LTEU, which people like us build equipment for. So, you know, let's not... We don't discount the value of the unlicensed any more than the carriers now do, although they once did, but now it's probably the single piece of spectrum that saved them the highest amount of OPEC or even CAPEX. So GAA is important, but I think the rule as it exists strikes a very nice balance between the availability of pals, the opportunity to use of pals that aren't deployed as well as reserving some GAA. In the top 50, that has to stay GAA because there's massive amounts of investment already in that space for that band. So I think the rules as they are are struck with pretty nice balance. Something else about this particular band that many folks here may not appreciate. I don't think anyone's mentioned this is the propagation characteristic. Because, you know, so the commission in the spectrum frontier proceeding is making available thousands and thousands of megahertz of very high frequency millimeter wave spectrum, you know, which has trouble going even to glass, for example, you know, whether on trees or walls or anything else. So is... You know, you don't know if they're coming in, but can you say something about the propagation of this mid-band spectrum? What difference does that make? I will just say, given all of the different applications we have, that it's very important to our customers. I mean, this band has characteristics to it that make it particularly useful for the kinds of applications that she is working on with our many, many different customers. I'm not going to say that high-band spectrum has no utility, but its utility is certainly extremely limited. You're talking distance, and high-band spectrum is not going to meet the distance requirements. One of the reasons why this is such an interesting piece of spectrum for those that may not know, this rule essentially, to some degree, harmonizes in the U.S. with the rest of the world. It has been using this spectrum, both for fixed wireless and for some level of cellular pedestrian kind of mobility for almost 20 years. Whether it's everywhere in Russia in the former Soviet Republic, whether it's all the entire continent of Africa, pretty much, all of South America, Central America, Canada, Europe, they've been using this band. This spectrum activity globally harmonizes, and with that comes math, vendor participation and everything else. So, yeah, it's a very unique piece of spectrum. Let me give you a minute to make way for the second panel shortly, but let's see if we have any questions from the audience for these unusual suspects here. Any questions? And if you do, please identify yourself, of course. Yes? Say it again with the mic. Are there any build-up requirements for PAL owners? For PAL licenses? There is no spectrum squatting because the spectrum floats. It's not a specific piece. And if someone hasn't built out their PAL, the truth is you don't know where that PAL might appear anyway on the spectrum chart. So it's available for opportunities that the GAA use at such time as a PAL licensee flips on their PAL and then the spectrum access system then vacates anyone else that would be in the piece of spectrum the SES chose for that PAL. That's part of the beauty of the spectrum. Actually, if you can't have spectrum, or you won't have spectrum warehousing, that you do have now, whether it's because the company that holds the spectrum has no use for it in a particular area or they just don't want someone else to get it, which we do have now. Yeah, so even if you're holding a license, you're holding 10 MHz until you need it until you're ready to use it, actually. And that in turn, you know, until then the GAA users can use it. It's an interesting part of this band. In fact, if you go to a CBRS alliance event, you'll see people from all over the world because they're all following this proceeding. It's the way this spectrum is managed using the dynamic nature of the time domain, which is the most efficient way to actually manage spectrum, which, by the way, has never really been done on a scale ever in the roughly, since 1931 or so, history of the FCC. So there's a whole lot at stake here. They want to say that again. Yes. How do you vision the warming between the LT network today and a CBRS band? So all the devices will have the events... I think it's up to the particular operator whether, for example, whether it would enable some other IMZ, which is your unique ID to attach to your network, and then you would have to have roaming agreements with the other entities. But the process and the technical mechanisms for that are identical to how they would occur today, for the most part. So if I give you an example of a cable operator, right? They have a host agreement with Verizon, for example. Right? And they're also interested in CBRS band. So they are implementing a resale-based business model. So how would they be able to roam between the Verizon network and CBRS band? Yeah, I think... I don't think the guys like Comcast, Time Warner and Charter will have any problem forming roaming agreements with Verizon and everyone else. There's just so much market potential. But it's... However, they wouldn't typically negotiate something like that today. I don't see that as any kind of burden no matter what the rules are. Thank you. Yeah, and we have someone from Charter on the next panel, so you might even repeat that. All right, well, if there's not any other burning questions, this is a great opportunity to move to our second panel focusing on the regulatory debate that's currently in front of the FCC. But thank you to all of you. So come on up, Dresden, Colleen and everybody. Also, while they're getting up here, a warm welcome to my friend Dale Hatfield, who's here. The Dean of Spectrum Gurus. Great to see you, Dale. The names are on there. Okay, well, we'll start this up right away. So we have here some of the usual suspects, the preeminent players in this debate, certainly right now and even for years since it started. I'll start with Steve Sharkey, who is vice president for government affairs, technology and engineering policy at T-Mobile, its office here in D.C. So, Steve, I think as, I think I even failed to mention, but you can obviously tell us a bit about it. Both your company and CTIA filed petitions asking the commission to revise the rules for priority access licensing and T-Mobile's petition goes further proposing that the entire band be auctioned with those revised rules, which would mean auctioning off the 80 megahertz currently allocated for GAA. Can you explain, the policy rationale behind the petitions? Yeah, and thanks for inviting me to be here today. I will say I love the first panel, it was a great panel, and I think when I looked at the participants, I thought you were inviting me to be beat up on our proposal. But, I was actually really surprised by the first panel because I think the one thing that came out of that is the value of license spectrum and the reliability of that and that there was widespread acceptance that that's what's really required. So, really our proposal came out of what we were seeing around the globe, though, of this band being what a key band for 5G technology. In Asia, Europe, Latin America, around the world the band is being looked at as a portion of at least a key driver of 5G. So we felt we were really missing an opportunity to be a leader in taking advantage of 5G technology here in the U.S. with the current structure. Because the current structure really does have uncertainty around deployment, the short license terms, lack of renewability, and a limited amount of spectrum for licensed services really undermines the value and I think the investment. So, our petition, probably the biggest parts of that are that the entire band should be licensed. There should be 10-year licensed terms with a renewal expectancy and it should be on larger areas, P.E.A.s rather than the other ones. What we don't do is propose to get rid of the 3-tier structure. Our proposal would maintain that so that GAA use would be there on an opportunistic basis. You would still have the SAS Managing Use of Spectrum. And if a power licensee doesn't build out or is currently using spectrum, GAA use would be free to use it. I think after listening to the first panel and the value of licensed spectrum, it's actually surprising that when I read the comments, there used to be a lot of opposition to what was proposed on licensee across the entire band. Because one of the main points there was the desire to compete against carriers for licenses. Frankly, the more licenses you have, the lower the prices will be, the more companies to get hold of that. The current rules limit you to four power blocks, which we think is fine. But under the current structure, with a maximum of seven power that's not even, that's two licensees. And so if you're competing for such a limited number of licenses that the companies that we just heard speak, that they thought would have, you know, if they think it's hard to compete, it's going to be much harder to compete for seven licenses as opposed to 15. But I guess all in there, that's really our, the intent is really to position the U.S. to compete as effectively as possible for deployment of 5G services to really structure this band in a way that backs investment and drives technology innovation and makes it, you know, a leading technology while not losing kind of key characteristics in innovation of the approach with the SAS and the overall future structure. Thanks, Steve. To introduce next Kawin King who is Vice President for Regulatory Affairs at Charter Communications and is responsible for Federal Regulatory, particularly on wireless and public safety issues. So Kawin Charter's Spectrum Internet service offers mobile connectivity over Wi-Fi primarily. How would the CBRS band support your wireless offerings and what's Charter's position on changing the rules for PALS? Michael Fregel, thanks for having us. Charter's very excited about CBRS band. Also on a personal level, thank you for inviting me to be on a panel. This is a comic book writer so as part of that he's on panels all the time at these comic conventions. So my kids thought it was pretty cool that I was going to be on a panel. Unfortunately, captain don't change rules too much it's not, doesn't confuse you with Batman but I got the panel so I'm moving up in the world. But as you mentioned Charter Charter is already in the wireless business. We have over 200 million wireless devices that as we also publicly announced we are moving forward transitioning from a Wi-Fi only to full mobility network. So first we're going to take our wireless infrastructure kind of from an inside out looking at inside of home first and then opportunistically kind of outdoor where we can do that. First in 2018 we've entered into an with Verizon we're going to use their network to enhance our Wi-Fi service. But the next big step is Spectrum and so we are excited about the Spectrum opportunities and the 3.5 band is really interesting to us. Cable is really well positioned to deploy quickly in this band with our existing plant. We have power, backhaul and location are already there so deploying small cells we're really well positioned to do that quickly and really quickly improve service for our customers. So in looking at the 3.5 band and the rules we do like the rules and we also like the idea to quickly deploy these rules so any type of changes to the rules that are going to slow down that deployment we would not be in favor of. You know we think that the sharing that was created is good. We're also open to some tweaks but we think that when you make any tweaks to the rules we have to be careful that you don't you know that sharing network, that sharing tier is still there, that we still can use both GA and PALS and that any changes to the rules don't disrupt the ability to use GA. We think GA is a great way to kind of legitimize the business case for going into the spectrum and so if you have rules that make it really hard to use GA that's going to disrupt the whole purpose of this band which was to bring innovation and new entrants into the marketplace. As I mentioned we are open to some small tweaks that are probably bigger sizes but we think PEAs are too big and then looking at you know slightly larger license terms we'll be open to discussing that as well. Okay Thanks So next Steve Coran is the FCC Council to WISPA, the Wireless Internet Service Providers Association and the Chairman of Lerman Center's Broadband Practice Group from here in DC. So Steve, the record indicates that dozens of WISP spout comments in opposition to the T-Mobile and CTIA petitions can you explain why smaller wireless operators such as your members prefer the framework and licensing rules that the FCC finalized last year? Well sure there are a lot of reasons but first of all thanks for having me here and thanks for all of you guys for coming and streaming let me start with a couple of things first of all this is we have a rural broadband problem here in the U.S and that is that there's 23.4 million people who live in rural areas that are not getting access to broadband right now and CBRS offers the best opportunity to use spectrum as infrastructure that was referred to in the first panel as well spectrum as infrastructure to serve those folks we have people right now operating in the 3650 to 3700 megahertz band 60,000 or more registered sites and through a flip of a switch and a software upgrade they can easily migrate into the CBRS band and get the additional one get the additional bandwidth and two get the additional protection of priority access licenses if they so choose and our job was to sort of create options if they wanted to do GAA they could do GAA if they wanted to do PALS they could do PALS and the attraction of this is really kind of two things one is area you know our members serve rural areas much like NTCAs members that you'll talk about and these are very sort of community-based businesses privately funded and and the folks here really want to serve their communities and having to buy areas that are much larger than they really want to serve and a really position to serve is not a winning proposition for them the second one is the term the rules offer right now kind of a pay as you go type of scenario where every three years you can re-op and there's also other things in the record that we might want to talk about a little bit later that suggests that there may be ways for incumbents to get some sort of a preferred right at the subsequent auctions for PALS so the idea of a pay as you go reduces the upfront investment and what folks should be investing in is deployment not buying spectrum but it would be nice to have the protection and the options of this sort of thing so bottom line is it's low barriers to delivery and it's great spectrum and license spectrum for the first time that rural communities can get and we don't think that rural America should be shut out from having access to license spectrum and be able to apply fixed wireless services in areas that are lacking that service okay thanks Steve and finally I'd like to introduce Preston Marshall who is an engineering director wireless architect for alphabet access where he is responsible for developing spectrum access technologies and also the author of a new book whose title is too long for me to remember there thank you Michael show the people on the live webcast thanks very much for having me and thanks for coming sort of discussing this is tough to fit into a two or three minute discussion particularly after I follow Steve but we have to go back and think a little bit about why did we accept this ban it was to create a couple features to put a wide variety of different classes of users on an even spectrum and even standing going into the spectrum the last panel showed I think the kind of enterprises that are imagining innovating in this ban and that's only possible because we allow for the first time cellular people who would otherwise be an unlicensed to coexist so a handset that might be sold in a Verizon store can work on an enterprise network that a roaming agreement that was between carriers can roam with all the features of LTE and security and such on an enterprise of the IOT community can make use of the volume of a non-proprietary technology and that was pinched on this balance between license and unlicensed I'm glad that everyone supported license I'm glad because if you go back to Pcast a lot of people thought having any exclusive or any protection at all was a bad idea and so Pcast said let's give people the choice of both we think about competition among companies what that allowed was a competition between spectrum models if you thought protection was really important you could buy it if you were really innovative and clever you could not buy it and use that money for building better equipment if we look at what the second thing we did is we pick a band that was intrinsically local what we did in three tiers might not make sense at 6 or 700 MHz it goes a long way it's a good coverage band but this is a 3.5 band the energy from this band if it went through this floor between 8th where 9th was 8th below us 100,000 of the energy you radiate up here gets down to that floor it's a very low quality band this is a very localized band therefore the framework was set up to have very localized licensing a single building a single refinery we're very active at looking at sports venues a single sports venue FCC we thought actually went too large with census practice because there are 4,000 people that are bigger than a NFL stadium if you increase the size of what you offer in the market you increase obviously the cost and you've essentially said the only people who can buy that are those who can monetize it against a large area coverage so that's really the question how do we match how people will monetize the spectrum and we hear Chris here talk about a building you saw GE talk about a refinery industrial plant that's the scope of their monetization we've always felt that the important thing that maximizes the opportunity was to match monetization against the size of spectrum carriers monetize against a very large area but the people who are interested in this band or a lot of them monetize against small areas you can always buy more but you can't buy less and so by going at census track we provide the ability to buy a small block or for carriers to buy a large one Steve made the comment that their proposal offers more options chances for licenses it doubles the number of licenses but it divides by factors of almost a thousand the number of the blocks that can be bought so it's reducing the number of licenses by the hundreds so yes more licenses are good that's a totally correct statement but what we actually do is reduce by hundreds secondly as we extend that license what we do is we look for people with stable revenues and stable businesses stable businesses generally mean the ones that ten years from now will never hear about the exciting ones are the ones who only have enough money to operate for the next two or three years the next Google the next Facebook the next whatever but we want to find these people who have a small amount of money they've got a great idea now if I put them up against someone buying essentially perpetual rights what is the chance that we're going to see those companies under this ecosystem I won't answer you can answer for yourself so that's really the challenge who do we want in this spectrum we want to create an opportunity for a new kind of service like the first panel talk highly specialized getting the kind of LTE indoors that you're used to outdoors and use it as an engine of innovation the FCC called this the innovation ban the support to PCAST largely came out of the council of economic advisors because they saw it as an engine of innovation like Wi-Fi became if we were the first to have this we would then have a very significant impact on the international market by the US brands so we have to go and think about this not in terms of what's best for one user community but to think about too what are the new user communities who historically have an enter here like GE like CBR so that should tell us something that we succeeded in these current rules in reaching out for new sources of capital because our goal ultimately is to be to see as many people deploy broadband as we can and so when we have a whole panel of people saying we want to deploy broadband if the rules don't change and block us that's a deal we should all accept and actually Preston mentioning the localized uses and sports stadiums reminds me I should have on the first panel mentioned what I thought was the coolest demo that I've seen for CBRS which was NASCAR which Preston I think helped organize with Nokia and Qualcomm we did another one of course we can't see what it is but this was putting a 360 degree camera in the cockpit of a race car Richard Petty made the cars available to us we did it at Las Vegas such a deployment would very likely be impossible if someone bought up all all of the 150 megahertz in a pal and a single race track certainly couldn't compete against the carrier to buy perpetual rights over a so that's an example of what we would lose so everything is about opportunity cost and those are the kind of opportunities we would lose in a 360 immersive VR it feels kind of freaky if you go up against the wall really fast what would I like but I could use my mouse to look out any of the windows you're looking around I could see more than Petty could because he has to watch the road I was a passenger but it's very cool to look at other cars look at people in the stands and it's all in high def you can turn around in one race we did the car was tapped and spun you could actually go back and replay and this time you looked out the rear window and you could see the car come up and hit them but there was no camera looking there and that's an example I don't think we scratched the surface of cool things but I think we have a very good chance of suppressing all of that if we make this just another carrier band which essentially is what's on the table so can I jump in on that it's only fair I agree it's a fiction that you're just giving that up if you lace in the entire band and you can we can talk about license size and what's the rest license size but to think that none of that happens if carriers buy spectrum or that nobody can compete against a carrier for spectrum it's just fictional to throw out charter as a poor entity that may not enter the market if they have to buy licenses is a little absurd and frankly for Google to be saying that some of the innovation that's going on is difficult I think it's one thing to say for a band that was essentially a coverage band which has largely been addressed by existing systems your own argument is this is a 5G band you couldn't walk through Mobile World Congress without seeing 5G and everything so I think 5G spectrum does create more excitement than coverage spectrum so I think it's a different market when we think about what happened in 3.5 than what happened in 6.100 well I think we would look at the balance of coverage and capacity I think what it does the more interest that you have the more investment there is in new technologies and developing new technologies and new applications that everybody benefits from and I think there's plenty of room for innovation and frankly competition and hopefully we end up with actually a much larger pool of mid-band spectrum than just this as the FCC looks at this mid-band NOI and you know we'll grow out from this and I think there's plenty of opportunity for that I think with these with very small license areas what you do risk is having spectrum not be as fully utilized by having to coordinate at borders and limitations on power levels that are there which would benefit from being increased from rules that make it more difficult to aggregate spectrum and get broader bandwidth so some of those things get easier as you expand the license size it doesn't really look like how we build systems today and I think most people who have mentioned unlimited plans becoming not limited realize that to some extent the way we build networks today isn't keeping up with the way we are using bandwidth today particularly indoors and I think our particular excitement in this band is the indoor case where we know there's very large amounts of attenuation in the walls and people can build a lot in GAA if they're not encumbered by having an overarching power if you auction up all 15 its perpetual rights it will be sold and essentially in large parts of the country in the areas where there's lots of opportunity for indoors we'll actually see the suppression of indoors we'll be working away from the problem we need to solve your own CEO got up and talked about how indoors should be the building owners problem here's an opportunity for building owners to actually step up to that problem and we'd be suppressing that let me let me just correct up my CEO we are always trying to get better access indoor and to get on the gas systems that are deployed indoors so I think there's plenty of opportunity for promoting indoor coverage here working with building owners and then customers pay someone else to use it I saw Et Chen at Mobile World Congress the idea that Verizon was open to neutral hosts and he put up interestingly a chart of a hospital saying it's private LTE in that hospital they have a chart where they have three types of spectrum so I think it's not this isn't the sort of carriers and non-carriers I think some of the carrier community starts to see the virtue in a more synergistic relationship with indoors there's a little more balance than to ask that creates monetization opportunities and a lot of features of this ecosystem that was designed in that are potentially compromised we've seen the amount of interest from non-carriers that's emerged we had SRO at Mobile World Congress and Mike did really well on panel one here on that indoor issue could this be I mean maybe I'm overly optimistic but could this be something like Wi-Fi where most people don't even realize when you're on your smartphone the majority of the data is not touching carrier spectrum or carrier infrastructure it's using Wi-Fi to send it a short distance over unlicensed airwaves into the local wireline connection certainly almost all the time probably you're at work at home Starbucks, airports, whatever which seems to be a benefit to the carriers in the sense that you're buying the subscription you're thinking wow this device is great because I'm getting all this bandwidth and I'm only paying so much and I'm wondering if that isn't also true for indoor if there's neutral host LTE networks inside everywhere for example or inside a lot of important high traffic places and it serves as an amenity for the customers of every carrier you know not just 18 team Verizon but T-Mobile and Sprint doesn't that increase the value of that subscription to the smartphone I mean struggles to get into building and a lot of times we're expected to pay very high fees for getting into those buildings on the LTE networks so you know a neutral host that's got reasonable access but can they do that it was always from PCAST sort of the killer app new sources of capital because you guys have been a lot on spectrum and a lot on equipment built new sources of capital monetize it the problem with Wi-Fi is if you follow the incentives everybody wants to put a Wi-Fi sticker on the door but they don't benefit if they go from one gig to ten gig backhaul they don't benefit if they increase the density of the devices so what neutral host brings into it is that the building owner benefits from bandwidth is an incentive to deploy not just enough to put the Wi-Fi sticker on the door but to create meaningful amounts of bandwidth we would like to see people doing virtual reality there's a lot of very very powerful apps that are in the pipeline that are going to be bandwidth constrained and so in creating an incentive structure where the building benefits financially from building the economics going from one to ten gig is the advantage the neutral host over to ask and so you know keeping that opportunity for lots of neutral host deployment seems like something that helps the carriers deploy cheaper and from our point of view in Google we want to bond bandwidth whoever provides that bandwidth and incentivizes it charters so are these priority access licenses are they important for neutral host networks or can they just rely strictly on GAA so the carriers have all gotten behind LAA you know LAA is a mix we're incentivizing people to be clever it's easy to just hide behind protection it's cheap to do it like Wi-Fi we know the limits of both LAA and I think you guys have Steve's company fully supportive mixes the two keeping a piece GAA is essentially replicating the GAA ecosystem in this band and so if you pushed LAA or you pushed LTEU it seems like you're on our bounds to see the benefit of an open GAA ecosystem that isn't put up for auction I think the challenge we have here though is that it's a relatively small amount of spectrum right with 150 megahertz that we're dividing up into a bunch of different buckets that isn't going to be the most efficient use of this spectrum so yes we are fully supportive of LAA and are deploying it and that should be a technology going forward in these bands and I think the opportunity we're talking kind of just about the 3.5 gigahertz band here but if we look at the bigger picture of what's going on with the mid band proceeding that you have to see it started where we really do have an opportunity to look at a big swath of spectrum that could be used primarily for licensing services and another big swath of spectrum that would be unlicensed and result in very efficient use of both of those that would be complementary we usually differ to not include swaths but one swath would both get used up we've tracked in this band why is wifi so popular it was a lingua frankwa that cell phones could get to and devices and anyone could deploy and so having bands that are accessible not partitioning the communities but multiple communities and the one band creates that diversity of supplier that ultimately can drive the innovation how about for wisps and cable it's just double tennis here and my partners at the nat and he and steve are just sitting in the middle of the ping pong table so for wisps and cable for example how do you think about this this balance between pals that are available do you need those and gaa working together and how do you think about it I think about it in these terms I look back historically at the way that larger geographic areas that are not density based or population based necessarily are allocated and the way that they are and the way that carriers have deployed on that spectrum and I don't want to see a repeat where the Los Angeles County or the Los Angeles PEA gets built out and have 5G in Los Angeles and you still have people that live 50 miles outside of the city or 100 miles outside of the city in Los Angeles County still can't get broadband in their homes and that for me is the biggest thing that we want to accomplish here and I look at what the FCC created I'll come to your question just a second but I want to build up a little momentum here is pent-up responses for pent-up demand for responding what the FCC created was an innovation bed for everybody but it also created an opportunity for you to have different kind of uses like virtual reality and neutral hosts in urban areas but also created an opportunity for rural areas and the proposals that are on the table from the mobile community would essentially create a zero sum game where it becomes a 5G band with the existing carriers and there isn't room and even if there is room it won't get built out and opportunistic use is not a viable not a viable alternative without sort of allocated GAA channels to fall back on because it's just not going to drive the economy and it's not going to drive the innovation that's going to bring that sort of thing in this very nice band to serve those unserved homes doing the testing right now we're looking at kind of the use cases for testing mobile in various markets we're testing fixed and I think looking at both inside and outside and in particular on some of the fixed testing kind of what can you do with the rural areas and how could we get into that using this spectrum but we already have a great network out there using Wi-Fi this is the perfect opportunity for us to use this which is why it's important I think to have both house and GAA we do want to be licensed in the band but it's also important to have GAA not always a business GAA is a great reason to do that so we think that the balance policy that was created by these rules shouldn't be disrupted by making rules that really look like a traditionally wireless band which makes it perfect for the carriers but not necessarily for other new entrants before we get off to the areas the size the geographic sizes we'd like to charter in its comments suggested that you know there might be grounds for compromise you know the difference between one of the somebody on the previous panel said it was like a factor of a thousand perhaps not a thousand but factor several hundred the difference in size between a partial economic area of which there's only actually 416 nationwide and a census draft which in different cities can be incredibly localized so so I think in your comments you said you were unlike many of the rest of us that you were open to a middle ground so I don't know if you talk a bit about that because there also comes you know at what point does it get unaffordable for you know and it's a good question and we suppose counties which I think we're definitely open to still talking we think that PAs are way too big for many of the reasons everybody these people handle discussing that census tracts are a little difficult operationally it's actually for a cable company who you know a lot of our plant runs down the sides of the streets and I understand census tracts kind of tend to run down the middle of the streets so there's reasons to look operationally at if there's something a little bit bigger than a census tract but getting too big comes with all the reasons that we wouldn't want us to be a traditionally wireless fan so we're definitely open to compromise if there's some kind of middle ground counties was one thought that we proposed to see you know how others would react to that we think that in certain areas counties would be great I know other people have suggested those are still too big but we would you know I think finding middle ground approach we'd be happy with is there any other middle ground ideas is there anything between counties and census tracts that would be middle ground we're still too big you know because I look at CBRE back there when Chris talks you know and she's thinking about buildings you know this would be helped a bit if we had more flexibility in using scatter losses where we could recognize right now the rules even the wind forum ones that were kind of the lowest common denominator sort of do interference analysis somewhere before the American Indians came across the Bering Sea before we built buildings using just terrain in fact for most of the places that are interesting to deploy it's about building we've had the rules updated to reflect more use of geodata then we could be more comfortable but right now when we're using long lee rice which is just the natural terrain it makes Manhattan look like an unoccupied piece of forest it's still a fairly large keep out zone for palvin so that drives us towards wanting seeing smaller and smaller areas more enabling of somebody go ahead so you know you did mention that there's other spectrum in play on the mid band and there's a lot of variables in what we're talking about here in terms of term in terms of geographic area in terms of renewability and you know those are conversations that maybe we all should have because if you kind of limit it it becomes much more difficult to negotiate and it becomes much more difficult to achieve kind of results that everybody can live with we haven't even talked about things like should we have different sizes in urban areas versus rural areas we haven't talked about things like maybe you should have some pals that are longer terms than others so there's a lot of different things that we can do but we all need to sort of have that discussion behind closed doors but have a holistic way and I think that would be a good out-of-the-box way to try to cut through some of this and I was going to throw in at the end of what Preston said just for the sake of that Longer rate Longer rate is that the PCAST proposal originally was not to use standardized geographic areas for interference protection but to simply you know protect based on deployment so you deploy you tell the SAS what you deploy and they would you know give you a certain interference protection perimeter you might say and the idea was that then you could really squeeze as much use as possible in and do that on a dynamic basis but the FCC could not wrap their heads around the idea of an auction that was not selling standardized geographic units and we argued with them a lot about how small can we go and their conclusion yes right and the conclusion was census tracts were tremendously big two years ago right right and which now seem you know Steve and others believe they're way too small but one argument it's interesting that the commission brushed aside two years ago which has come up again and I just wanted to mention in case any of you have an opinion is the idea that it's actually even you know forget about what's good policy or not it's just infeasible we can't the FCC can't possibly manage an auction with 60,000 units you know up for sale and do this every you know three years that it's just too complex to have census tracts time seven seven licenses at a census tract level which is I think something like 60,000 units total but Paul Milgram the Stanford economist who was the lead in designing the TV incentive auction just did a filing saying no that's you know kind of crazy at the end of Steve if you want to you've spoken to Milgram about it and supported some of his work so he's putting another fuller paper out later this week it's or later this month it gets into other things but the two things that he focused on in the paper he submitted to the FCC were one it's not too complicated to conduct the sort of an auction because it doesn't have some of the things the traditional spectrum auctions have had which is things like complimentary use and substitution there wouldn't be a lot of switching when you have dynamic spectrum access the SAS does that for you you could also go to a simpler auction design the FCC has used the very first auction they did which I hope we never do again was an oral outcry auction we're not going to do that but we could do single wrap we could do single round bidding with sealed bid there's a lot of different auction designs the FCC could could adopt and I'm not here to say which one you know I would prefer at the moment the second thing he pointed out was a way to sort of overcome the problem if it is a problem of being able to invest in the short-term license and the idea here is that every three years there would be an auction maybe it'd be conducted by the commission maybe it'd be conducted by some other exchange where the incumbent licensee would have some sort of a foothold so if it were me I would get a preference if I bid lower than Preston here just because I've had the license and that's one of his ideas his other idea is the idea of a depreciating license where you set a price for your license way up here and wherever you want it to be you pay a certain fee in exchange that's related to that price but if somebody comes along and offers you that price you have to sell them that license and I think if we want to get into that for this proceeding then it would be a long time before we see CVRS actually become a reality beyond the experimental stage but it is an interesting thought for future auctions for those who sort of get into game theory there are lots of different approaches to adding certainties in licensee and we wouldn't foreclose any of those I think the key is that there's enough certainty around the investment and use and I think it's actually it's interesting that it's I think it's been pretty common theme throughout all the species that the value of having certainties is really real I suppose it's just a license model and just on the idea that in your brains you know it would pack as much in as possible if you don't have the license there as in the other outcome there would be you could end up with a small island throughout that has broken up and use that interference protection that actually limits the sufficient use over all of this spectrum which is the way we see it you know when a few such specimens go over that area that's efficiently possible you can coordinate with yourself easier than with others we addressed that early in the filing process and arguing that the SAS would be dynamic and always try to maintain contiguous so if it happened to be that AT&T went in and then T-Mobile went in and then T-Mobile wanted to come right next to it we wouldn't leave them as neighbors we would move the AT&T but the first time we can move people around in the spectrum so we don't get this blocking that we get today so we would just move the AT&T and essentially start to allow people to build out to use us as examples of that more traditional deployment though right so now if you're talking about every building owner having some different system and having to then coordinate amongst those it gets more difficult one of the things we set as one of the objectives of Sea Bearers Alliance Wind Forum and Sea Bearers Alliance Wind Forum technology neutral between us say in the wisps and then within Sea Bearers Alliance is a set of agreements that look very much like how a carrier manages interference and agreements on time one of the virtues of building a band whose real structure was very friendly to LTE was in fact that LTE has all of these features to put networks together to put them sharing spectrum reused one you guys have made great use of it in all and so the framework is to extend among a homogenous deployment those techniques into more heterogeneous ones and we think that's something that with the right industry standards could have been accommodated and the TCAS was influenced by its co-chairman which is Eric Schmidt but he was thinking that G-Google runs 2 million I forgot the exact number but I think it would flow in the paper like 2 million a minute auctions for placing those ads and so running for probably a 4 a month process a mere half a million doesn't seem like a technologic burden certainly I want to open the floor for questions so think about it but I wanted to cover one the other contentious issue just quickly only one other contentious well the other most contentious issue which is and you all have commented on a little bit already but renewal whether there should be competitive renewal which we've never had or just in a sense automatic renewal well the proposal is 10 year licenses that renew over and over again unless you well and that's a question I don't believe that either CTIA or T-Mobile proposed build-out requirements which are typically associated with automatic renewal we did say that there should be some build-out requirements here although there are different ways to do it I think like Steve said if you don't build-out there is some pro-rater amount if you don't pay out I think creative ways to do it because one of the challenges here is how do you define whether that was fine but I think there are creative ways to do it a little bit but we did say there should be some penalty if you don't use it or some requirements to use it and obviously so somebody's not using it and you know it's free to be used by DOA but the problem I think of that is sort of the policy question of how do you have use it or share it with build-out requirements or renewal expectancies and trying to put all those together under one roof because if you think about use it or share it or the opportunistic use is kind of the antipasys of build-out and kind of the antipasys of renewal expectancy so if you have thousands and thousands of license or hundreds and hundreds of licenses depending on where we end up or somewhere in between let's just use thousands as our metric is the FCC staff really going to want to look at all those renewal showings and build-out requirements when it has to use it or share it so renewal expectancy to argue unless it has some teeth behind it and I don't know how you do it it's really just sort of becomes a perpetual license and that's the sort of thing that we like intensely about the proposal that the mobile community has advanced what would build-out mean to Los Angeles County you deployed in one little piece and included anyone else from having the certainty of a PAL license because you built out one neighborhood but you know LA can have hundreds or miles the solution where you give back spectrum after you know you have eight years to build it out you give it back is not really a solution because we all know what areas are going to be given back that can be the rural areas that are not that don't give you the ROI that your company needs but it's also the areas where people need broadband in their homes we have two problems with renewal one is it really means that we've locked not only we may not lock technologies in but we've locked business models in and so we don't have the ability of new business models to come in let's forget individual companies and two it raises the price which blocks out those innovators and if I'm bidding for something that goes for all time that never depreciates against my balance sheet I have a very different view of it than if I'm bidding against something that in the end of four years goes up for competition I warehouse the right to be protected rather than warehousing the use of spectrum but they raise the price they become barriers to the innovation that otherwise drives the economy you know why is wireless sort of set like it is where the internet goes off and reinventing itself creation of new companies and all because there's no barriers to entry well there's plenty of innovation in the wireless space both by carriers and new companies that are building equipment to go on networks or compete without renewal we spend billions of dollars a year on infrastructure deployment and that's what you undermine is if that's all going to go away within three years what's our motivation for deploying it and I'm a little I mean WISPs run into this all the time how many times have we heard WISPs that deploy on unlicensed spectrum and when somebody else comes in to use that spectrum they complain because they've already made this investment have a business up that customers depend on and now want to protect that unlicensed spectrum that they got for free from anybody else coming in so I think that the fiction that just because it's unlicensed there's no barrier companies are trying to put up with barriers all the time and in fact the LAA, LPU LAA was a prime example of that where Wi-Fi is widely deploying unlicensed fans but yet the rules allow deployment of any technology and as soon as we brought in a technology that they felt was going to be widely deployed they tried to put up regulatory barriers to block that and blocked it for years until we were finally able to overcome that So Steve, I think the PCAST report I don't think it recommended a period of years what it argued was that licenses should match capital recovery and so and very much in the PCAST model was thinking indoor modifying enterprise deployments which are typically three-year life so I think an argument that says that types of deployments that have higher capital recovery times that licenses match I don't think is intrinsically wrong because we didn't want people's the PCAST argument wasn't to put people's capital at risk what it was was to create opportunities for some for the next thing is this still the highest and best use of a funneling common or is this something that should pass away so we wanted that turnover but not for anyone to lose capital so I think an argument not just that three years or five years or seven years is better but an argument of this is what it takes to create a certainty for recovery of investment versus a certainty of I'll be here forever is probably not an unreasonable one and I think we heard earlier there was some seem to be greater openness among speakers here too like looking at the terms probably more so than say the geographic size but let's get to the audience because we're running out of time and see if there's questions how about yeah start all the way in the back since that's where the microphone is and would come up with that so if T-Mobile gets the rules changed that they want because I look at this basically you know I'm looking at CBRS is very much an in-building technology so if T-Mobile gets the rule changes they want are they going to refocus a significant portion of that billions of dollars in infrastructure build every year to build out those in-building systems I can't say what our future plans are but this is a band that we would look at as coverage in capacity not just limited to in-building and outdoor use or one of our biggest issues on in-building is getting access to buildings where building owners have agreements with companies that have destroyed buildings and we can't get in or where there are high rates for us to enter that don't make it economic so we deploy in-building all the time and work with the building owners but the demand for in-building is increasing and I get what you're saying but those situations I think are decreasing where that's the impediment to getting into a building is the rates that you're being charged by a neutral host we have owners that are willing to pay for systems but there's just not the capacity with the carriers right now to provide signal source for every single one of those situations so if you get your rule change focused and this is very well suited to the in-building space then it would seem that instead of where it falls now to the enterprise to a large extent to fund these systems then the carriers then would take that on us back on themselves you know look we there's no reason that we don't want in-building coverage we want in-building coverage customers use data we want to be able to make sure that they can get the data we need so to the extent that there are ways to make that happen you know we are looking at that Patrick has a question not that he needs it Michael I'm going to agree with you in particular on the LA front I do think it was silly of the West I know many of which are my customers that they rejected that however it's an open and in fact our company provides the reference design to Intel for their LA however what you may not fully realize what you did in doing that is you just gave props to the concept of a band that enables innovation whether that's LA or whether that's LTEU so in a way you help make the argument for more open CBRS so you know I fully understand the argument and obviously we are deploying in unlicensed bands the point was made we benefit greatly from unlicensed bands I don't know what the latest numbers are but I would guess more than 50% of our traffic is over unlicensed so we have nothing we are supportive of unlicensed we're having more of it when we look at this band it's a wasted opportunity because it's inefficiently allocated and constructed it's done in a way that is not going to maximize investment in the band or technology or deployment and we just think we've got a much better opportunity to drive a more productive use of the spectrum in a way that's going to advance 5G development in the country and that particularly given everything else going on that there is going to be a bigger picture of additional mid band spectrum for both license and unlicensed systems that that will be a more efficient way to do it any final question and then we'll wait back there that was who you are I'm Todd Wiggins and I am a videographer in DC and I have a generic question I would like to know if 5G will introduce any kind of war of insecurity in the case of any type of attack because that seems to be a big concern with EMPs and so on will there be any effective mitigation of any concerns or electric or electronic pulsing or any way that it could be more vulnerable or less vulnerable than it is now security aspect it doesn't depend if it's 5G it's semiconductor so smaller they get the more vulnerable they are live with it I bet if we went around this room everybody would have a different definition of what 5G is and I think most people would right but most people would say it's sort of densified 4G that involves a lot of fixed lengths I don't know if you would disagree with that or not but that's at a very different technology but the time we get there we'll have redefined LTE to become 5G just like we redefined pieces of 3G to be 4G non standalone 5G begins the slope of redefining it security issues will probably be the same Michael just a quick question given the breadth and heterogeneity of the stakeholders who seem excited about this policy and the spectrum most of whom are commercial players and understand how to commercialize spectrum and technology and see value at and given the commissions 5 nothing support for this and a full administrative record I guess I'm interested in what empirical support you might point us to that supports the idea that the policy is inefficient that the spectrum is being allocated in an inefficient way because I think we'd be very interested in looking at it we've sort of filed on the record about some of the inefficiencies here and some of the discussion about what we've looked at is you know I think it's a fiction that the band is viewed as a partially licensed band I mean when you look at licenses that are short term with no renewal expectancy that are a decreasing number as years go on because of the way that they're some renew it was really set up to be an unlicensed band with a nod to some potential for license service and I just don't think it's going to drive the kind of especially when you're talking as we look at 5G and you're looking at kind of 40 megahertz wide bandwidth when you take the fan and divide it up into such small segments it's not the most official way to do it so it's fascinating that the carrier view is that it was largely unlicensed all the unlicensed community walked away from it because they thought it looked like just another thing for the carriers so and I think that's the win that should tell us we did something right that both sides you know the good deal was when the other side likes it and I think we accomplished that I would point if you go read T-Mobile's filing their comments about efficiency are largely from the point of view of the kinds of deployments they do today so the other view would be if I don't worry about it it's overhanging me and I go to World Trade Center I can put 103 copies of networks in each floor and they'll have 50 dB of isolation and they'll work fine but if there's a pal there I get just one so efficiency is very much what is your model of deployment I can understand T-Mobile and I wouldn't disagree with their filing from the viewpoint they brought it from but I think the real challenge if we have to give the commission is do you look at what's there now in a couple of years if you're going to leave it alone and let it play Policy does not equal efficiency policy involves a lot of other things it's a policy that involves in this case innovation it's a policy that involves enabling in building stuff it's municipal driven broadband networks it's Wisp-driven broadband networks and it's allowing those in other areas to have the same opportunities in DC I read a quote in the travel magazine on the plane on the way back that said DC is a city surrounded on all four sides by reality so I think we need to keep that in mind as we kind of think about the world outside of these four walls and the city here when we kind of think about what is the national policy Any final comment from Cohen and Steve and then we're going to wrap up I actually like that quote business people and engineering teams that are driving our policies here are not in DC and they look at this exactly the same way because they look at that decision and they look at it as a fictional experiment that came out of DC to drive policy objectives that won't be achieved with the framework that was put in place I'm going to just say a little bit because I think our engineers are back there with the possibilities in the band and they do want some minor tweaks but I think they see a lot of possibilities for the spectrum hopefully using all the testing we're doing and what things are working out I think they do think that with some small tweaks we could make it a really successful band They're optimistic out there in reality They're outside these four walls so they must be They all look at Washington and they're like what the heck is going on there so you are using something and everyone thought it would be an unsuccessful policy experiment The fact is if we give people the opportunity to innovate they shock us with the cool things they can do if we sit and say well it isn't like what we've always done well we know where that comes out but we have seen that if we give people the tools and opportunity they will find something really cool and I think we have to keep looking at Wi-Fi which was a garbage band the language that described it in the proceeding the sparraging and yet look what it became I don't believe any engineer can sit and say no one will ever make good use of this what that just means is they can't imagine the cool things someone else would think about Thanks to all of you who hung on for the entire show and thanks the panel