As far as I have read, the proposed rules seem quite similar to the Dynamic Spectrum Alliance model rules. I think one possible area for deeper discussion is regarding the geolocation database, as referenced at the bottom of page 6.
“WSDs shall require registration authentication by a geolocation database before they operate. The qualified database shall provide device management functionality for the identification of non-conforming WSDs for their immediate deactivation. With time, the operation ofa large number of WSDs may require multiple geolocation databases with open standards to ensure interoperability so that network operators can select a qualified geolocation database of their preference.”
I believe that geo-location databases are the endgame for dynamic spectrum but to date they have proven a barrier to implementation of TVWS regulation due to the cost and complexity of setting them up operationally. Canada implemented TVWS regulation back in 2015 but still have yet to appoint an authorised geo-location database provider. Similarly in South Africa regulations were gazetted in 2018 but there is no commercially operational database yet, although maybe CSIR’s is?
The point here is that there are a lot of moving parts in setting up a geo location database. Whose software? Who will host it? How will it be paid for? Commercial or government operation? etc. Those are all worthwhile problems to sort out but ideally they are something that can be sorted out in parallel to allowing operators to get started with services. In rural areas, there is typically a lot of spectrum available and in many regions it should be possible to identify spectrum that can be used without risk and tracked in a spreadsheet.
This seems to be the approach that South Africa and Mozambique have taken in authorising service providers prior to the existence of a fully operational geo-location database. Worth checking this out in more detail.