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Code phase Global Navigation Satellite System (GNSS) positioning performance is often described by the Geometric or Position Dilution of Precision (GDOP or PDOP), functions of the number of satellites employed in the solution and their geometry. This paper develops lower bounds to both metrics solely as functions of the number of satellites, effectively removing the added complexity caused by their locations in the sky, to allow users to assess how well their receivers are performing with respect to the best possible performance. Such bounds will be useful as receivers sub-select from the plethora of satellites available with multiple GNSS constellations. The bounds are initially developed for one constellation assuming that the satellites are at or above the horizon. Satellite constellations that essentially achieve the bounds are discussed, again with value toward the problem of satellite selection. The bounds are then extended to a non-zero mask angle and to multiple constellations.