Re: [WISPA] FCC NPRM WT Docket 10-153

2011-01-19 Thread michael mulcay
Rick,

 

Pleased to give you WSI's opinion and comments re WISPA's Reply Comments WT
Docket 10-153.

 

Section I. Reject FiberTower's Proposal

 

Well stated and WSI is in full agreement.

 

Section II. Shared Spectrum

 

WSI agrees. 

 

Section III. Adaptive Modulation

 

By agreeing with Verizon and Comsearch et al, who are proposing unnecessary
regulation based on a false premise and an incorrect reading the rules, you
are supporting regulation that would unnecessarily deny service or increase
the cost of service. See slides 20 and 34 of the attached Power Point slides
from WSI's December 8, 2010 ex parte meetings with the FCC.



Section IV. Auxiliary Stations

WSI agrees but we would have added the key items of smaller antenna size and
lower costs.

 

Section V. Smaller Antennas


Agree on the need for smaller antennas but small (less than 4ft at 11GHz and
6ft at 6GHz) antennas for frequencies at and below 13GHz can only be used on
short paths for good availability numbers. Also, if patterned after the
11GHz rules every path would block very large numbers of future paths.
Therefore, WSI believes these short paths should be auxiliary paths where
even at 6GHz the antennas can be any size that works (1ft, 2ft) and no
future paths will be blocked by the auxiliary stations. WSI's Comments to
the NPRM/NOI, Page 8, and Review of Part 101 Antenna Standards are given
below:


 

In Section 101.115 of the Rules the Commission wisely specifies the
electrical requirements that must be met but not how the electrical
requirements are to be met, thereby promoting innovation. As noted in this
NOI, smaller antennas have several advantages for carriers and consumers;
however, the advantages from the use of smaller antennas should not come at
the expense of wasting spectrum, but should come from innovation. For
example, this NPRM is proposing to allow the use of very small antennas on
auxiliary stations (for example 1ft. antennas at 6GHz) without causing any
interference to existing licensees or future applicants. Therefore, WSI
strongly recommends that any revision to the antenna rules facilitate
innovation as the means to promote more efficient and cost effective use of
spectrum.

 

Thank you for asking for our comments, I hope they are useful.

 

Best,

 

Mike

 

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Rick Harnish
Sent: Monday, January 17, 2011 12:00 PM
To: 'WISPA General List'
Subject: Re: [WISPA] FCC NPRM WT Docket 10-153

 

Mike,

 

Where to you fall in with WISPA's Reply
Comments.http://fjallfoss.fcc.gov/ecfs/document/view?id=7020921272.  I would
love to hear your honest opinions, criticisms or supportive statements.

 

Respectfully,

 

Rick Harnish

Executive Director

WISPA

260-307-4000 cell

866-317-2851 WISPA Office

Skype: rick.harnish.

rharn...@wispa.org

 

 

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of michael mulcay
Sent: Monday, January 17, 2011 2:11 PM
To: 'WISPA General List'
Subject: [WISPA] FCC NPRM WT Docket 10-153

 

In my experience, significant growth opportunities occur in wireless when
there is a regulatory change, a technology change, or both. The last major
opportunity in backhaul and access occurred in the 1990's when, as stated in
a previous post, Western Multiplex Corporation petitioned the FCC for a rule
making and an immediate waiver of the rules pending a rule making to allow
unlimited EIRP in the 2.4GHz and 5.8GHz ISM bands. When both were granted
(with the 3 for 1 rule at 2.4GHz), Western Multiplex introduced the Lynx
spread spectrum radio, a technology change in conventional backhaul and
access. Western Multiplex grew rapidly and the regulatory and technology
changes created the opportunities for entrepreneurs to start wireless
internet service companies and the WISP industry was born.

 

With the FCC's Notice of Proposed Rule Making, WT Docket 10-153, to allow
auxiliary stations and make it feasible for technologies used in Part 15
frequency bands to be used in Part 101 frequency bands below 13GHz, the
scene is set for a dramatic decrease in the cost of provisioning Part 101
fixed service licensed backhaul and access, thereby presenting WISPs large
and small with significant growth opportunities. 

 

I believe the questions for a WISP are: 

 

1. Can I grow my business with the added ability to provide +100Mb licensed
services at or near the cost of provisioning unlicensed service? I believe
the answer is yes, as applications are requiring faster and faster speeds.

 

2.  Are Part 101 frequencies below 13GHz available in my service area? I
believe the answer is yes for most if not all WISPs. 

 

3. Do I want to take control of my own destiny, that is, own exclusive-use
spectrum so as not to be at the mercy of interference from others, as is the
case when using unlicensed bands? I believe the answer is yes.

 

4. What do I have to lose or gain by filing an ex

Re: [WISPA] 11Ghz Licensing Warning Question

2011-01-19 Thread michael mulcay
Scriv,

You were one of the few who immediately saw the potential benefits. Thanks
for the help over the years. 

To answer your questions:

1. Wireless Strategies mission is to engineer, provision, lease and/or sell
concurrently coordinated licensed microwave networks. 

2. Concurrently coordinated spectrum will support FDD, TDD, FDD-TDMA or
TDD-TDMA depending on the application. Therefore, all existing products and
technologies that can support PTP, MPTP and PTMP applications can be used
and WSI has no intellectual property interest in these products. In the 6GHz
and 11GHz licensed bands there are many manufacturers that have FCC
certified FDD equipment but only Exalt has FCC certified FDD and TDD
equipment. For PTMP operation there are many product manufacturers with
product in the unlicensed bands (Motorola, Proxim etc.) that I believe could
simply be re-banded from the 5.8GHz band to the 5.9GHz to 6.4GHz band. So,
the question that WISPs should ask their microwave equipment suppliers is:
How soon after a ruling by the FCC to allow the use of auxiliary stations
are they able to deliver equipment and what would be the price?

3. Regarding smart adaptive antennas, WSI deployed and operated a custom
designed 6GHz smart adaptive antenna in Baltimore. OEM Comm., who recently
joined WISPA, has a custom designed 11GHz adaptive antenna. However, we
expect adaptive antennas to soon be available from several manufactures
(with costs competitive with legacy CAT A antennas).

Best,

Mike


-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of John Scrivner
Sent: Monday, January 17, 2011 2:57 PM
To: WISPA General List
Subject: Re: [WISPA] 11Ghz Licensing Warning Question

I want to thank you gentlemen for taking the time here to debate these
issues. I have been a proponent for concurrent coordination as
proposed by Michael Mulcay for a few years now. Michael did an
eloquent job of proposing these ideas before the WCAI around 2005
maybe? I was in the audience. The licensed players there did not
really see anything novel about the opportunity.

They blinked.

Michael and I spent a great deal of time discussing many of the same
concerns I have seen discussed here. I brought the concurrent
coordination proposal before the WISPA FCC Committee at that time but
saw much of the same lack of interest as was witnessed at the WCAI
show where I had first heard about it directly from Michael.

We blinked too.

Now we see that we are finally starting to see some traction for
concurrent coordination within WISPA. I feel that Jack Unger has done
a good job of bringing this proposal before the committee and making
sure the opportunity was clearly described and explained in a way that
made sense to our members. Thank you for that Jack. You work hard for
us and it is appreciated.

I too see this as an all ships rise in higher waters type of
proposal. WISPs are buying more and more licensed backhaul. Clearwire
has stopped making their crazy 300 PCN requests in a day. The true
opportunity here is for WISPs to take advantage of. It is one of the
only ways we can sell a  real metro-Ethernet style service with an
SLA. We can be our own first customers too. No longer needing a
dedicated backhaul to each individual rural tower would be a windfall
in cost and logistics for WISPs who want to replace all their backhaul
with something that is truly carrier-class.

The only question I have left is who will be building gear that is
legal to operate as a concurrently coordinated link radio once you get
your RO in your favor? Will you, Michael Mulcay, be the sole
beneficiary of licensing this technology? If yes then what are the
terms by which existing manufacturers of licensed radios can buy a
license of your intellectual property to include concurrently
coordination into base stations and CPEs? If this detail has not been
established then our support for you could easily turn into an
incredible windfall for you and your company but may not really yield
us anything of real value in the end.

So Michael, I ask you, what is the status of the intellectual property
license opportunity for concurrent coordination? Have any manufactuers
bought a license or have agreed to buy a l;icense to use your IP for
this purpose? How much of a percentage of the total price of the
product would we expect to pay for your IP as part of a base station?
For a customer CPE?
John Scrivner


On Mon, Jan 17, 2011 at 1:02 PM, michael mulcay
m...@wirelessstrategies.net wrote:
 Fred,



 Useful discussion, let’s continue.



 I am guessing that in those cases, you didn't begin a presentation by
 putting a pointed set of insults (the whole obstructionism bit) into the
 Record.  Your slide set might have been entertaining at a WISPA
conference,
 or as a political broadside aimed at outsiders whose views of the FCC you
 wish to lower.  But as a presentation to be mainly read by the
professional
 staffers at the FCC, who

Re: [WISPA] 11Ghz Licensing Warning Question

2011-01-17 Thread michael mulcay
 that make better use of spectrum (100
auxiliary paths instead of 100 primary paths), increase the value of that
spectrum and leave more spectrum available for all new applicants. In this
way everybody wins.

 

I will again quote FCC Chairman Genachowski: 
 
We can't create more spectrum, so we have to make sure it's used
efficiently. 


Nobody disagrees with that platitude.  The question is how?  You support
one view, but your arguments were not well made.  And from the PoV of the
WISP community, there is risk as well as opportunity.

 

What risk? I see the risk as being opportunity lost.

. Last but not least, auxiliary stations will give WISPs a
significant business growth opportunity.


I have a suspicion that much larger companies would be more likely to be the
ones to win any battles here. 



I don't think so, as the FCC's rules on spectrum acquisition levels the
playing field and also WISPs are better placed to be first to market in
their service area with the same licensed service performance and, with
their traditionally low overhead, they have an opportunity to beat the
competition on price. 

What you are proposing is maintain the legacy approach, with all of its
drawbacks. How will that conserve spectrum, dramatically lower the cost of
licensed microwave backhaul and access, and benefit WISPs? 


You are suggesting a best-case outcome for a proposal that you have not
argued for very well.  I am suggesting that there may be better approaches,
and that Tom has a point that your proposal could possibly backfire on the
WISP community.

 

There are those who fear change and those who embrace change. I believe
there is a major opportunity for those WISPs who are willing to take it. The
fear is that those who fail to be proactive will be left on the outside
looking in. 

 

Mike

 

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Fred Goldstein
Sent: Friday, January 14, 2011 7:41 AM
To: WISPA General List
Subject: Re: [WISPA] 11Ghz Licensing Warning Question

 

At 1/14/2011 01:31 AM, Michael Mulcay wrote:



Content-Type: multipart/alternative;
 boundary==_NextPart_000_0013_01CBB371.AEA7F3F0
Content-Language: en-us

Fred, 
 
Tom DeReggi's comments were business-case based and constructive; basically
exploring whether the Commission's NPRM on auxiliary stations would benefit
the large operators or WISPs or both. In WSI's opinion the answer is both,
but with WISPs getting the higher business growth percentage.  Frankly, I do
not see anything in your position that would benefit the WISP community.


You do not know my position.  What I was pointing out was twofold. One, your
technique was bad; two, there are valid reasons (which Tom has spelled out
well) to see the WSI position as not being a certain win for the WISP
community.  BTW I am not necessarily opposing all auxiliary-station use.
But your presentation to the FCC doesn't make the case.




 
 Further, I have nearly thirty years of experience working with the FCC,
initially with the Xerox XTEN filing, and later, at Western Multiplex as VP
of Business Development  I wrote the request for a Rule Making and an
Immediate Waiver of the Rules pending a Rule Making to allow unlimited EIRP
in the 2.4GHz and 5.8GHz ISM bands. Both were granted (with the 1 for 3 rule
at 2.4GHz) and we were able to take Western Multiplex from the Living Dead
(profitable with no growth) to a Star Performer (rapid profitable growth),
growing the company by 25%, 50% and 100% in three consecutive years. I
believe that auxiliary stations can give WISPs the same type of growth
opportunity.


I am guessing that in those cases, you didn't begin a presentation by
putting a pointed set of insults (the whole obstructionism bit) into the
Record.  Your slide set might have been entertaining at a WISPA conference,
or as a political broadside aimed at outsiders whose views of the FCC you
wish to lower.  But as a presentation to be mainly read by the professional
staffers at the FCC, who are for the most part dedicated, competent people
whose work is fettered by politics from above, it struck me as
counterproductive.  They do not want to be insulted. 

Most of my regulatory work is in the Part 51 area (mainly CLECs), which is
predominantly political.  What technical questions arise there are usually
resolved on a political, not fact-based, basis, mainly as cover for an
industry position.  I still harbor some illusions that Part 101 and Part 15,
to give two examples, are handled on a somewhat more honest basis, with
technical rather than political judgement being most important.  The current
version of the old joke is that the FCC staff is 1500 lawyers and Stagg
Newman, but I know there are really a few other engineers left to help keep
Stagg sane.  To be sure, WTB is rather politicized, and my own experiences
with them are not so good, but a lot of that has to do with internal
politics and silos.  I think the auctioned spectrum

[WISPA] FCC NPRM WT Docket 10-153

2011-01-17 Thread michael mulcay
In my experience, significant growth opportunities occur in wireless when
there is a regulatory change, a technology change, or both. The last major
opportunity in backhaul and access occurred in the 1990's when, as stated in
a previous post, Western Multiplex Corporation petitioned the FCC for a rule
making and an immediate waiver of the rules pending a rule making to allow
unlimited EIRP in the 2.4GHz and 5.8GHz ISM bands. When both were granted
(with the 3 for 1 rule at 2.4GHz), Western Multiplex introduced the Lynx
spread spectrum radio, a technology change in conventional backhaul and
access. Western Multiplex grew rapidly and the regulatory and technology
changes created the opportunities for entrepreneurs to start wireless
internet service companies and the WISP industry was born.

 

With the FCC's Notice of Proposed Rule Making, WT Docket 10-153, to allow
auxiliary stations and make it feasible for technologies used in Part 15
frequency bands to be used in Part 101 frequency bands below 13GHz, the
scene is set for a dramatic decrease in the cost of provisioning Part 101
fixed service licensed backhaul and access, thereby presenting WISPs large
and small with significant growth opportunities. 

 

I believe the questions for a WISP are: 

 

1. Can I grow my business with the added ability to provide +100Mb licensed
services at or near the cost of provisioning unlicensed service? I believe
the answer is yes, as applications are requiring faster and faster speeds.

 

2.  Are Part 101 frequencies below 13GHz available in my service area? I
believe the answer is yes for most if not all WISPs. 

 

3. Do I want to take control of my own destiny, that is, own exclusive-use
spectrum so as not to be at the mercy of interference from others, as is the
case when using unlicensed bands? I believe the answer is yes.

 

4. What do I have to lose or gain by filing an ex parte letter in support of
the FCC's NPRM to allow auxiliary stations? I believe that there is nothing
to lose and everything to gain. 

 

I suggest that if you agree with the above that you file an ex parte letter
in support of the FCC's proposal to allow the use of auxiliary stations. If
any of you would like help composing and filing an ex parte letter please
contact me off list and I will customize one for you and help with an
electronic filing (it takes less than two minutes). I believe that the FCC's
NPRM re auxiliary stations represents a golden growth opportunity.

 

Thanks,

 

Mike

Wireless Strategies Inc.

m...@wirelessstrategies.net

Direct:   831-659-5618

Mobile: 831-601-0086  

 




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Re: [WISPA] 11Ghz Licensing Warning Question

2011-01-15 Thread michael mulcay
Matt,

 

As you can see,  I strongly believe that the FCC proposed rulemaking to
allow the use of auxiliary stations would be good for the wireless industry
and especially for WISPs.

 

Thanks,

 

Mike

 

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Matt Larsen - Lists
Sent: Thursday, January 13, 2011 11:43 PM
To: WISPA General List
Subject: Re: [WISPA] 11Ghz Licensing Warning Question

 

Wow Michael,

That was an outstanding post.   Thank you for taking the time to put it
together.

Matt Larsen
vistabeam.com

On 1/13/2011 11:31 PM, michael mulcay wrote: 

Fred, 

 

Tom DeReggi's comments were business-case based and constructive; basically
exploring whether the Commission's NPRM on auxiliary stations would benefit
the large operators or WISPs or both. In WSI's opinion the answer is both,
but with WISPs getting the higher business growth percentage.  Frankly, I do
not see anything in your position that would benefit the WISP community.

 

 Further, I have nearly thirty years of experience working with the FCC,
initially with the Xerox XTEN filing, and later, at Western Multiplex as VP
of Business Development  I wrote the request for a Rule Making and an
Immediate Waiver of the Rules pending a Rule Making to allow unlimited EIRP
in the 2.4GHz and 5.8GHz ISM bands. Both were granted (with the 1 for 3 rule
at 2.4GHz) and we were able to take Western Multiplex from the Living Dead
(profitable with no growth) to a Star Performer (rapid profitable growth),
growing the company by 25%, 50% and 100% in three consecutive years. I
believe that auxiliary stations can give WISPs the same type of growth
opportunity.

 

I believe your last paragraph summarizes your view, so I will address this
paragraph.

 

But Part 101 is all about using conventional means. 

 

Wrong -- Part 101Fixed Service rules are about the use of spectrum for Fixed
Services, fortunately not about conventional means as this would preclude
innovation.

 

.(narrow beams, narrow bands) to squeeze in as many PtP users as possible
via coordination, not auctions.

 

There are two problems with the conventional approach: 1. Narrower and
narrower beams mean larger and larger antennas with the related dramatic
increases in CAPEX and OPEX, and even then they are still not perfect. 2.
The FS market requirement is for higher and higher speeds requiring higher
and higher bandwidths, not narrower and narrower bandwidths.

 

It works pretty well.  

 

Actually it works very poorly as demonstrated by the difficulty of Prior
Coordinating new 6GHz and 11GHz paths in cities such as New York and Los
Angeles. The reason for the congestion is that every licensed station is
given protection from harmful interference and all antennas radiate and
receive signals in all directions, hence the reason for Rule 101.103 and the
large antennas are a major contributor to the high cost of conventional
licensed microwave links.

 

As some of the Reply Comments noted, the alleged keyhole for auxiliary
stations doesn't really exist very often.  

 

The keyhole has nothing to do with auxiliary stations as it is a contour
around any station for a given interferer. Prior coordination requires that
a new applicant check the EIRP at all angles around the proposed stations
for all distances up to 125 miles at angles between five and three hundred
and fifty five degrees, and at all distances up to 250 miles for all angles
within five degrees of the antenna azimuth. This means that there are a very
large number of locations around existing paths where a new applicant path
cannot be deployed because the new path would cause harmful interference,
and as the distance from the new applicant to an existing path or paths
decreases, the number of choices for the new applicant path also decreases
to the point where a new path at any angle will not prior coordinate. With a
conventional approach these locations are unused, they are wasted. But
with auxiliary stations the existing licensee can put the unused locations
to productive use.

 

But TDD and FDD also   risk compatibility problems, and most of Part 101 is
FDD, while your proposal is TDD.  

 

Wrong -- there are no compatibility problems using TDD in areas where FDD is
operating, since a TDD path must prior coordinate before a license will be
issued. Also, there is nothing preventing an auxiliary path from operating
FDD, TDD, FDD-TDMA or TDD-TDMA.  

 

So it might make more sense to push for more spectrum elsewhere, rather than
use self-defeating hyperbole to fight Part 101 interests head-on.

 

I will again quote FCC Chairman Genachowski: 

 

We can't create more spectrum, so we have to make sure it's used
efficiently. 

 

So, why are you proposing that we do not challenge the big companies who
have vested interests in maintaining the status quo? 

 

The facts are these:

 

Spectrum is a finite precious national resource.

Every month thousands of new licenses are issued

Re: [WISPA] 11Ghz Licensing Warning Question

2011-01-13 Thread michael mulcay
 are proposing is maintain the legacy approach, with all of its
drawbacks. How will that conserve spectrum, dramatically lower the cost of
licensed microwave backhaul and access, and benefit WISPs? 

 

Mike

Wireless Strategies Inc.

 

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Fred Goldstein
Sent: Thursday, January 13, 2011 12:34 PM
To: WISPA General List
Subject: Re: [WISPA] 11Ghz Licensing Warning Question

 

At 1/13/2011 02:40 PM, Michael Mulcay wrote:



... 
The FCC committee was correct as spectrum is the life blood of all WISPs and
conservation of spectrum is absolutely essential. 
 


Of course.  I read your presentation, and some of the Reply Comments and
other parties' views.  So please take my criticism as constructive.

You shot yourself in the foot with your opening pages.  The whole routine
about obstructionism, and the stories about cars being disassembled near
animals, serves to alienate you from the skilled technical people at the FCC
who have to make these decisions.  Part 101 is not as politically charged
as, say, Part 51.  Your story could easily be construed as an insult.  In
fact it is hard to construe it otherwise.  This doesn't win cases.  (Do you
see this as being how it's taken?  Aw, he called me a name.  I guess I'll
have to adopt his position, so he doesn't call me a name again.)  FCC
submissions, including WISPAs, are normally very diplomatic.

Second, your repeated references to millions of paths being lost are clearly
hyperbole.  Yes, technically, there could be a zillion paths, but the demand
for any one of those paths is miniscule.  The only ones that matter are the
ones that people will use.  

There are essentially three types of path.  Fixed point-to-point paths,
fixed point-to-multipoint, and mobile.  Part 101 is about the first
category.  WISPs usually deal in the second.  CMRS is about the third.
Auxiliary stations are essentially a way to turn Part 101 into what it
isn't, fixed point-to-multipoint.  

Now I *do* agree that the FCC has set aside too little spectrum below 28 GHz
for that purpose.  IIRC there was once a 10 GHz allocation, based on the
1980ish Petition of Xerox for what they were planning to call XTEN but
abandoned.  This was called Digital Termination Systems and I don't know if
any such licensing still exists, but it was narrowband.  I have a slide set
here from 1982 from a company (LDD) that was building a 10 GHz DTS PtMP
system called RAPAC, which shared technology with their other product, the
CAPAC -- probably the first cable modem!  But they tanked.  I think the
MMDS-BRS band is authorized for PtMP, but licensed/auctioned, making it
inaccessible.  So I do see the need.

But Part 101 is all about using conventional means (narrow beams, narrow
bands) to squeeze in as many PtP users as possible via coordination, not
auctions.  It works pretty well.  As some of the Reply Comments noted, the
alleged keyhole for auxiliary stations doesn't really exist very often;
with high-performance (good F/B ratio) antennas and modest transmitter power
(70 dBm EIRP, 1 W TPO), back-to-back stations can coexist.  But TDD and
FDD also   risk compatibility problems, and most of Part 101 is FDD, while
your proposal is TDD.  So it might make more sense to push for more spectrum
elsewhere, rather than use self-defeating hyperbole to fight Part 101
interests head-on.



 --
 Fred Goldsteink1io   fgoldstein at ionary.com   
 ionary Consultinghttp://www.ionary.com/ 
 +1 617 795 2701




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Re: [WISPA] 11Ghz Licensing Warning Question

2011-01-07 Thread michael mulcay
Adaptive modulation is the subject of an FCC NPRM WT Docket 10-153. Can you
lock the equipment in a non adaptive mode?

 

Mike

 

Wireless Strategies Inc

831-601-0086

 

From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Scott Carullo
Sent: Thursday, January 06, 2011 2:46 PM
To: wireless@wispa.org
Subject: [WISPA] 11Ghz Licensing Warning Question

 

Comsearch has this to say on one of the sites in coordination, anyone know
what it is supposed to mean?  They are closed now, I'm not being patient sry
:)


Path Warnings Document


FCC Rule Part(s)


Description

Result / Action


N/A

site1 Radio Equipped with Adaptive Modulation.

Review Radio Parameters


N/A

site2 Radio Equipped with Adaptive Modulation.

Review Radio Parameters


101.31 (b) (1) (ii)

site1 - ASR may be required based on C/L Height.

Verify/Change Antenna Height or File with FAA


N/A

site1 Failed Glide Slope or Height requirement.

Verify/Change Antenna Height or File with FAA



Thanks

Scott Carullo
Technical Operations
855-FLSPEED x102

  http://www.flhsi.com/files/emaillogo.jpg 




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Re: [WISPA] Interference on 11GHz

2010-06-29 Thread michael mulcay
Give a spectrum management company (Comsearch, WAC etc) your site info and
have them do an interference search.

-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of can...@believewireless.net
Sent: Tuesday, June 29, 2010 2:04 PM
To: wireless@wispa.org
Subject: [WISPA] Interference on 11GHz

Anyone know who we would contact at the FCC to help determine what is
causing us
interference on our 11GHz link?  Seems to have started as soon as
Clear started putting
a ton of 11GHz gear on one of our broadcast points.  They are saying
they conducted
a study and no interference was found.




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Re: [WISPA] Couple more questions for the 11Ghz folks

2010-04-22 Thread michael mulcay
Scott,

For a 30 mile path in Florida with a 40dB fade margin the outage is
predicted to be in excess of 20 hours. About 12 miles is the max I would
use.

Mike

831-659-5618

-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Scott Carullo
Sent: Thursday, April 22, 2010 9:07 PM
To: Travis Johnson; wireless@wispa.org
Subject: Re: [WISPA] Couple more questions for the 11Ghz folks

I guess my question would be whether the 6Ghz difference between 5gig and 
11gig is as much different from 11gig to 18gig...  Seams to me just 
guessing that 11gig and 18gig would act very differently for rain fade 
but then again I'm without any experience on either so I'm just probing for 
answers...

Scott Carullo
Brevard Wireless
321-205-1100 x102



From: Travis Johnson t...@ida.net
Sent: Thursday, April 22, 2010 11:58 PM
To: sc...@brevardwireless.com, WISPA General List wireless@wispa.org
Subject: Re: [WISPA] Couple more questions for the 11Ghz folks

Hi,

I assume you have had path analysis done already? Like by Trango or 
Dragonwave or whomever equipment you are considering for this project? 
What do their numbers show for availability?

Honestly, a 30 mile link using 11ghz in Florida seems a little scary to 
me. I have some 18ghz links using a 4ft and 2ft dish going 32 miles and 
we experience rain-fade during our heavy rain storms... and 
considering we are technically in a desert climate, it makes me wonder 
about your links. (BTW, that's with my link running at the lowest 
modulation already, and they still drop out during the heavy storms).

Travis
Microserv

Scott Carullo wrote:
 Spending over 10K for a link (or anything for that matter) causes me to 
do 
 a bit more homework than usual when I'm dealing with something I am not 
 familiar with  So more questions...  Thanks ahead for your time I 
 appreciate any info provided.

 Looking for generic 11Ghz answers - not related specifically to any 
 manufacturer.

 Two links in question, one 20 miles and one 30 miles.  18db output 40.4 
db 
 dish (4ft)  900ft tower to 300ft tower both instances 900ft tower in 
middle 
 with one link east one west.  Calculations show just under 700 watts 
EIRP

 How much is the rain going to affect me...  I have no experience with 
11Ghz 
 and would really like a firm grasp on what happens to my link(s) when the 

 rain starts.  I understand the Trango Apex which I'm looking at can 
 dynamically adjust speeds to account for some fade - exactly how much I'm 

 not sure.  Any real world info would really help me at this point.  I 
guess 
 I'm looking for good news :) but I need to hear the bad as well if it is 

 reality.

 Next question is for temp inversions.  I have never had equipment higher 

 than about 350ft so the 900ft is a bit new for me.  I'm assuming that the 

 angle different from going from 300ft to 300ft vs. 900ft to 300ft would 
be 
 a small portion of a degree difference so I'm not expecting anything 
 different here.  Confirm this really won't make a difference for me as I 

 suspect...  I'm not going over much water, just St. Johns river mostly 
 marsh but it does cause differences in temp above the water.  Does 11Ghz 

 behave the same as 5Ghz for inversions?  Worse, better?  5Ghz around here 

 sways a lot actually if you look at RSSI graphs.

 Anything else I might want to know, understand, be warned about etc?  
 Remember back to your first 10K + link :)  That's me now... 

 Scott Carullo
 Brevard Wireless
 321-205-1100 x102




 


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Re: [WISPA] 5.8GHz Link Loss

2009-08-10 Thread michael mulcay
Guys,

I think you have a classic case of multipath fading. The things to check
are:

1. Is there enough fade margin to achieve the desired availability (99.98% -
99.998%)?

2. Is the first Fresnel Zone blocked 40% at K = 4/3?

3. Is the reflection point as close to one end as possible? Is it blocked?

If you send me the following I will do a path analysis for you.

Antenna gain at both ends, dBi
Cable loss at both ends, dB
Tx power output, dBm 
Rx sensitivity at BER = 10-6
Antenna height at both ends, AMSL in feet
Path length in miles

Mike
-Original Message-
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Marlon K. Schafer
Sent: Sunday, August 09, 2009 10:31 AM
To: WISPA General List
Subject: Re: [WISPA] 5.8GHz Link Loss

We're still guessing here.  He's never told us how LONG the links are.  If 
they are 10 miles apart it's probably not ducting.

marlon

- Original Message - 
From: Mike m...@aweiowa.com
To: WISPA General List wireless@wispa.org
Sent: Sunday, August 09, 2009 9:57 AM
Subject: Re: [WISPA] 5.8GHz Link Loss


 The way I understand it, and have worked to my advantage as a ham, is
 the layers stratify at fairly definite borders in tropospheric
 ducting.  The layer works more like a duct with a mirror like
 top.  The signals can be repeatedly reflected back down into the duct.

 I did some experiments during one tropo opening using some long
 circular polarized yagis at both vhf and uhf.  The signals appear to
 become more randomly polarized as the distance in the duct
 increases.  The signals coming from areas around the Gulf coming into
 SW Fl during the events had components of both vertical and
 horizontal polarization.

 Refraction is the deflection of a wave on passing obliquely from one
 transparent medium into a second medium in which its speed is different.

 So, both upon entering and leaving the duct the signal can also be
 subject to refraction?  Not sure.

 Mike


 At 10:52 AM 8/9/2009, you wrote:
That is correct. So my next question: Can refraction be caused by
thermal ducting? -RickG







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[WISPA] FCC Public Notice

2007-07-06 Thread michael mulcay
For those interested in WSI's request to the FCC for a declaratory
ruling, there is additional information on the web site
(www.wirelessstrategies.net http://www.wirelessstrategies.net/ ) under
FCC Public Notice.
 
Mike   
 

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RE: [WISPA] FCC Public Notice

2007-07-02 Thread michael mulcay
Tom/Charles

The whole objective is to increase the effective use of spectrum under
the existing rules.  NO WAIVERS, NO RULE CHANGES and NO INCREASED
INTERFERENCE. 

To maintain the existing frequency coordination efficiencies the path
antennas must meet CAT A (or B) and their size will be large. It is the
wasted side lobe radiation that can be put to productive use with
subordinated paths where the radiation from the Distributed Radiating
Elements (DREs) at the input to any victim receiver is always below the
coordinated interference or 6dB below the victim receiver's thermal
noise. The size shape etc of the DRE can be any size or shape (small)
providing all the network criteria is satisfied.

Mike

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Tom DeReggi
Sent: Sunday, July 01, 2007 9:52 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Public Notice

I'd also add, I'm not certain everyone wants the antenna beamwidth 
requirements waived on these protected bands.

I HIGHLY support NOT lowering the antenna size requirement for 11Ghz, as

anything smaller than its at today, just compromises long haul backhaul 
applications, in which WISPs do not have many option for long haul. At
8-10 
miles, a couple extra Degrees of beamwidth is capable of interfering
with a 
much wide length of area in the city effected.  Although, I'd like to
see 
6Ghz lowered to 4 ft dishes.  There isn't a landlord in their right mind

that would allow a 6 ft antenna installed on their roof.
Or maybe a nicely designed 3 ft model, possibly acceptable.

Not that I'm not for concurrent coordination.

Tom DeReggi
RapidDSL  Wireless, Inc
IntAirNet- Fixed Wireless Broadband


- Original Message - 
From: Charles Wu [EMAIL PROTECTED]
To: WISPA General List wireless@wispa.org
Sent: Sunday, July 01, 2007 1:03 PM
Subject: RE: [WISPA] FCC Public Notice


But what about the 36 / 38 dBi antenna rule for 4  6 GHz?  The SIA is
all over Fibertower's 2' request in 11 GHz...imagine 4 GHz, which could
knock out a lot of C-band downlinks (now, not being a satellite expert,
I'm not sure of the current usage of this channel, but being that the
SIA has tons of , I'm sure they'll raise up a storm)

That said, I think you need to get the antenna beamwidth requirements
waives / relaxed first...even if concurrent coordination passes, I don't
think anyone will want to be installing 6' dishes on people's houses...

-Charles


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-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of michael mulcay
Sent: Saturday, June 30, 2007 11:09 AM
To: 'WISPA General List'
Subject: RE: [WISPA] FCC Public Notice

Charles,

The request for a declaratory ruling applies to all frequency bands. The
bands of immediate interest are 3.7 to 4.2GHz and 5.9 to 6.4GHz (an easy
freq change for WiMax, 3.5GHz to 4GHz band and 5.8GHz to 6GHz band)where
the subordinated link antenna sizes drop from 8ft and 6ft to as low as
1ft flat panel.

Mike

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Charles Wu
Sent: Friday, June 29, 2007 5:51 PM
To: WISPA General List
Subject: RE: [WISPA] FCC Public Notice

Wouldn't you be better off lowering antenna size requirement for the 3.7
GHz band first?
No one (specifically WiMAX) is going to make anything cheap for 18 or 23
GHz

-Charles

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-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of michael mulcay
Sent: Thursday, June 28, 2007 12:12 PM
To: wireless@wispa.org
Subject: [WISPA] FCC Public Notice

Last week the FCC1 issued a Public Notice seeking comments on Wireless
Strategies request for a declaratory ruling regarding (concurrent)
coordination of microwave links under Part 101 of the Commission's
rules.

The amount of microwave spectrum is finite and it is in everyone's
interest to seek ways to increase the effective use the existing
spectrum. Unfortunately, there may be those who have a vested interest
in maintaining the status quo and who will attempt to stifle innovation.

Innovation is one of the few ways that small companies can compete with
large established companies and that is why we believe this is a one
time opportunity for WISPs to join the big league as regards the ability
to obtain licensed spectrum which can support low cost 802.16-based
(WiMax) equipment with small antenna elements to provide licensed
backhaul and broadband services to hundreds of additional subscribers,
through frequency reuse without causing any additional harmful
interference.

It would be a great help if WISPA as a group and individual WISPs file
comments in support of the request for a declaratory ruling, especially
as there is everything to gain and nothing to lose

[WISPA] FCC Public Notice

2007-06-28 Thread michael mulcay
Last week the FCC1 issued a Public Notice seeking comments on Wireless
Strategies request for a declaratory ruling regarding (concurrent)
coordination of microwave links under Part 101 of the Commission's
rules. 
 
The amount of microwave spectrum is finite and it is in everyone's
interest to seek ways to increase the effective use the existing
spectrum. Unfortunately, there may be those who have a vested interest
in maintaining the status quo and who will attempt to stifle innovation.
 
Innovation is one of the few ways that small companies can compete with
large established companies and that is why we believe this is a one
time opportunity for WISPs to join the big league as regards the ability
to obtain licensed spectrum which can support low cost 802.16-based
(WiMax) equipment with small antenna elements to provide licensed
backhaul and broadband services to hundreds of additional subscribers,
through frequency reuse without causing any additional harmful
interference. 
 
It would be a great help if WISPA as a group and individual WISPs file
comments in support of the request for a declaratory ruling, especially
as there is everything to gain and nothing to lose.
 
The Comment deadline is July 19, 2007. Comments can be filed via the
FCC's  ECFS or by regular mail. Details are on the FCC's web site.
 
Thanks in advance,
 
Mike
 
1. FCC links: 
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.txt 
 
 
 
 
 
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RE: [WISPA] FCC Public Notice

2007-06-28 Thread michael mulcay
Felix,

Yes, a Citizen at Large can provide comment and the concept of
public-private networks with WISPs would make a very powerful argument
in support.

Thanks

Mike

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Felix A. Lopez
Sent: Thursday, June 28, 2007 9:52 AM
To: WISPA General List
Subject: Re: [WISPA] FCC Public Notice

Mike - Can Citizens at Large provide comment too?  I
am involved in volunteer wireless project for a local
school district in my area.  The CTO is always seeking
ways to do wireless on a limited budget.  We already
have problems with interference in a confined urban
space and hypothesized a licenced 802.16 with a local
WiSP network would help define a public-private
network for the students.  It is just hypothetical but
I can see the reasoning in support of comments for
this declaration at the FCC.

Any thoughts apreciated.

Felix
Wireless Practioneer
--- michael mulcay [EMAIL PROTECTED]
wrote:

 Last week the FCC1 issued a Public Notice seeking
 comments on Wireless
 Strategies request for a declaratory ruling
 regarding (concurrent)
 coordination of microwave links under Part 101 of
 the Commission's
 rules. 
  
 The amount of microwave spectrum is finite and it is
 in everyone's
 interest to seek ways to increase the effective use
 the existing
 spectrum. Unfortunately, there may be those who have
 a vested interest
 in maintaining the status quo and who will attempt
 to stifle innovation.
  
 Innovation is one of the few ways that small
 companies can compete with
 large established companies and that is why we
 believe this is a one
 time opportunity for WISPs to join the big league as
 regards the ability
 to obtain licensed spectrum which can support low
 cost 802.16-based
 (WiMax) equipment with small antenna elements to
 provide licensed
 backhaul and broadband services to hundreds of
 additional subscribers,
 through frequency reuse without causing any
 additional harmful
 interference. 
  
 It would be a great help if WISPA as a group and
 individual WISPs file
 comments in support of the request for a declaratory
 ruling, especially
 as there is everything to gain and nothing to lose.
  
 The Comment deadline is July 19, 2007. Comments can
 be filed via the
 FCC's  ECFS or by regular mail. Details are on the
 FCC's web site.
  
 Thanks in advance,
  
 Mike
  
 1. FCC links: 

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.doc

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.pdf

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2697A1.txt
 
  
  
  
  
  
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RE: [WISPA] The Next Big Thing in Wireless

2007-05-16 Thread michael mulcay
John,

This is probably the only opportunity the small guys (WISPs) will have
to compete on an even playing field with the big guys for spectrum that
supports WiMax products.

The first step is a favorable ruling from the FCC and then the filing of
a standard application for a Part 101 license.  

 We are told that the equipment cost per subordinated path will be less
than $500 and FCC certified equipment will be available ninety days
after a favorable FCC ruling

WSI would be please to discuss technical details, business strategies
and the enormous opportunities of concurrent coordination with any WISP
off list.  

Mike

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of John Scrivner
Sent: Saturday, May 12, 2007 6:20 PM
To: WISPA General List
Subject: Re: [WISPA] The Next Big Thing in Wireless

Mike,
If we support your request for declaratory ruling what steps would be 
required for us to get our own licensed multipoint Part 101 based 
network deployment in our areas? What equipment is available now if any?

What are the costs? How do you make money on this type of deal? I want 
to understand the logistics of actually using this in my network if we 
get the go ahead to do so.
Many thanks,
John Scrivner


michael mulcay wrote:

Concurrently coordinated networks are Licensed Carrier Grade, which
means we no longer have to take second place to the big guys. Wireless
Strategies Inc (WSI) decided to focus on carrier grade backhaul where
we
believe the GPM is higher and the COS lower than for the home
subscriber
market. 

The $500 number was for 802.16 based CPE and was a conservative number.
My guess is that 802.16 product prices will end up similar to 802.11
prices.

We budget conservatively and plan for a Part 101 license to cost about
$2500 with another $2500 for the Prior Coordination. For this we have
enough spectrum (60MHz at 6GHz) to serve hundreds of clients. The
throughput is 134Mbps burstable to 268Mbps. 

I agree that asking the FCC for a rule change or a waiver would be
difficult, especially to get the FCC allow one foot antennas. That is
why NO RULE CHANGE OR WAIVER IS NEEDED. We engineered paths in a city
that could support legacy and concurrently coordinated networks,
applied
for and have received licenses. To remove any uncertainty that an
antenna system with radiating elements (it is the radiating elements
that can have any type or size of radiator), is allowed UNDER EXISTING
RULES, we sent a Request for a Declaratory Ruling to the FCC asking for
confirmation that any antenna system, and specifically an antenna
system
with radiating elements, that meets all the present regulations is
allowed. I would be pleased to send you individual copies of the
request.

Our concern is that the big guys will make a land grab for spectrum
before the small, and often under funded, operators have staked their
claim. For most investors to put money into network construction they
want all perceived regulatory uncertainty removed.
This is why we are asking the FCC to remove any uncertainty.
Mike
831-659-5618
[EMAIL PROTECTED]




-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Marlon K. Schafer (509) 982-2181
Sent: Friday, May 11, 2007 7:12 AM
To: WISPA General List
Subject: Re: [WISPA] The Next Big Thing in Wireless

I talked to Mike for quite a while the other day.

I think this idea warrants some discussion.

On the one hand, the idea that we can use the cheap, arguably
underutilized 
6 gig band for licensed ptmp links has some draw for me.  It's also an
idea 
that the FCC has already hinted at a year or three ago (SPTF maybe???).

On the other hand, any licensed bands seem to almost always wind up in
the 
hands of people that don't deploy with it.  At least not broadband.

And, as our tower sites get ever more loaded with the access points
needed 
to service customers, many of us will likely eventually move to
licensed

bands for backhaul.  It would be a shame to not have licensed ptp only 
spectrum available.  Well, it could easily become a shame

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since
1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: michael mulcay [EMAIL PROTECTED]
To: wireless@wispa.org
Sent: Thursday, May 10, 2007 2:23 PM
Subject: [WISPA] The Next Big Thing in Wireless


  

Guys,

As we wireless operators know, the costs of licensed networks
(equipment, antennas and licensing) makes providing services to the
majority of subscribers prohibitively expensive, and the cost at


auction
  

for spectrum (for WiMax and 4G products) is beyond the reach of most


of
  

us.

To overcome these problems, two years ago Wireless Strategies began
research into ways to use new technologies -- WiMAX and smart antennas
-- to reuse

RE: [WISPA] The Next Big Thing in Wireless

2007-05-12 Thread michael mulcay
Concurrently coordinated networks are Licensed Carrier Grade, which
means we no longer have to take second place to the big guys. Wireless
Strategies Inc (WSI) decided to focus on carrier grade backhaul where we
believe the GPM is higher and the COS lower than for the home subscriber
market. 

The $500 number was for 802.16 based CPE and was a conservative number.
My guess is that 802.16 product prices will end up similar to 802.11
prices.

We budget conservatively and plan for a Part 101 license to cost about
$2500 with another $2500 for the Prior Coordination. For this we have
enough spectrum (60MHz at 6GHz) to serve hundreds of clients. The
throughput is 134Mbps burstable to 268Mbps. 

I agree that asking the FCC for a rule change or a waiver would be
difficult, especially to get the FCC allow one foot antennas. That is
why NO RULE CHANGE OR WAIVER IS NEEDED. We engineered paths in a city
that could support legacy and concurrently coordinated networks, applied
for and have received licenses. To remove any uncertainty that an
antenna system with radiating elements (it is the radiating elements
that can have any type or size of radiator), is allowed UNDER EXISTING
RULES, we sent a Request for a Declaratory Ruling to the FCC asking for
confirmation that any antenna system, and specifically an antenna system
with radiating elements, that meets all the present regulations is
allowed. I would be pleased to send you individual copies of the
request.

Our concern is that the big guys will make a land grab for spectrum
before the small, and often under funded, operators have staked their
claim. For most investors to put money into network construction they
want all perceived regulatory uncertainty removed.
This is why we are asking the FCC to remove any uncertainty.
Mike
831-659-5618
[EMAIL PROTECTED]




-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Marlon K. Schafer (509) 982-2181
Sent: Friday, May 11, 2007 7:12 AM
To: WISPA General List
Subject: Re: [WISPA] The Next Big Thing in Wireless

I talked to Mike for quite a while the other day.

I think this idea warrants some discussion.

On the one hand, the idea that we can use the cheap, arguably
underutilized 
6 gig band for licensed ptmp links has some draw for me.  It's also an
idea 
that the FCC has already hinted at a year or three ago (SPTF maybe???).

On the other hand, any licensed bands seem to almost always wind up in
the 
hands of people that don't deploy with it.  At least not broadband.

And, as our tower sites get ever more loaded with the access points
needed 
to service customers, many of us will likely eventually move to licensed

bands for backhaul.  It would be a shame to not have licensed ptp only 
spectrum available.  Well, it could easily become a shame

laters,
Marlon
(509) 982-2181
(408) 907-6910 (Vonage)Consulting services
42846865 (icq)WISP Operator since
1999!
[EMAIL PROTECTED]
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



- Original Message - 
From: michael mulcay [EMAIL PROTECTED]
To: wireless@wispa.org
Sent: Thursday, May 10, 2007 2:23 PM
Subject: [WISPA] The Next Big Thing in Wireless


 Guys,

 As we wireless operators know, the costs of licensed networks
 (equipment, antennas and licensing) makes providing services to the
 majority of subscribers prohibitively expensive, and the cost at
auction
 for spectrum (for WiMax and 4G products) is beyond the reach of most
of
 us.

 To overcome these problems, two years ago Wireless Strategies began
 research into ways to use new technologies -- WiMAX and smart antennas
 -- to reuse side lobe radiation around sites of point-to-point 4GHz
and
 6GHz microwave links under the present FCC rules and without causing
 additional interference.

 Our finding is that networks can be designed to operate with smart
 antennas with distributed radiators and that the new paths can be
 concurrently coordinated, under existing FCC rules and without causing
 additional interference.

 We believe that concurrent coordination will be The Next Big Thing in
 Wireless, leveling the playing field by making it possible for WISPs
to
 obtain multipurpose licensed spectrum at pennies on the dollar
compared
 to obtaining it at auction. By making use of the formerly wasted side
 lobe radiation of 4GHz and 6GHz paths, WISPs will be able to use IEEE
 802.16-based (WiMAX) equipment with small antennas to provide licensed
 broadband services to hundreds of additional subscribers at a
 provisioning cost of only about $500 per link. We appreciate that some
 members of the industry may initially perceive any change to the
status
 quo as a threat, but we believe that concurrent coordination will
 provide extraordinary benefits to the entire industry, especially
WISPs.

 Due to the potential for unprecedented industry-wide changes from the
 use of antennas with distributed radiators to provide

[WISPA] The Next Big Thing in Wireless

2007-05-10 Thread michael mulcay
Guys,
 
As we wireless operators know, the costs of licensed networks
(equipment, antennas and licensing) makes providing services to the
majority of subscribers prohibitively expensive, and the cost at auction
for spectrum (for WiMax and 4G products) is beyond the reach of most of
us.
 
To overcome these problems, two years ago Wireless Strategies began
research into ways to use new technologies -- WiMAX and smart antennas
-- to reuse side lobe radiation around sites of point-to-point 4GHz and
6GHz microwave links under the present FCC rules and without causing
additional interference. 
 
Our finding is that networks can be designed to operate with smart
antennas with distributed radiators and that the new paths can be
concurrently coordinated, under existing FCC rules and without causing
additional interference.
 
 We believe that concurrent coordination will be The Next Big Thing in
Wireless, leveling the playing field by making it possible for WISPs to
obtain multipurpose licensed spectrum at pennies on the dollar compared
to obtaining it at auction. By making use of the formerly wasted side
lobe radiation of 4GHz and 6GHz paths, WISPs will be able to use IEEE
802.16-based (WiMAX) equipment with small antennas to provide licensed
broadband services to hundreds of additional subscribers at a
provisioning cost of only about $500 per link. We appreciate that some
members of the industry may initially perceive any change to the status
quo as a threat, but we believe that concurrent coordination will
provide extraordinary benefits to the entire industry, especially WISPs.
 
Due to the potential for unprecedented industry-wide changes from the
use of antennas with distributed radiators to provide multiple-path
low-cost broadband services under the existing FCC rules, Wireless
Strategies decided to remove any uncertainty for investors and service
providers by, on February 23, 2007, filing with the Federal
Communications Commission, a Request for a Declaratory Ruling on
Compliance of Fixed Microwave Antennas Having Distributed Radiating
Elements.
 
However, to date, the FCC has taken no action. We believe that emails of
support from the WISP community can help speed up the process, by
encouraging the FCC to either issue the requested declaratory ruling or
to issue a Public Notice for industry comment.
 
Therefore, if you would like a copy of our FCC filing and/or information
about the new concept of concurrent coordination, please contact me at
Wireless Strategies 831-659-5618 or [EMAIL PROTECTED] For
additional information you can also visit our web site at
www.wirelessstrategies.net. 
 
Thanks,
 
Mike
 
Michael Mulcay, CEO
Wireless Strategies, Inc.
 
-- 
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