Steve,
I see your reply comments to translate to a reason for support of unlicensed
use of the spectrum.
Which is better... To establish policy that creates the best odds that ...
1) Spectrum will be used.
2) Spectrum will be used most efficiently, when it is used.
3) Spectrum will without compromise work for a purpose that it was purchased
for.
4) Generates the most revenue, assumming, if someone will pay more, it must
have a grander need being solved, or at minimum an incentive to deploy to
get an ROI, and the finance to deploy if they can afford to win an auction.
I think many advocates push for solving issue 2, 3, and/or 4, and therefore
push for Licensed, most often to the highest bidder.
But the truth is, history shows, that that mentality does not always lead to
deployment of spectrum, nor best serving the public.
I think where the problem lies is people try to corolate the value of
spectrum to a business case, meaning the value of the service judged by what
people will pay for it. This is so not true. A perfect example are RUS
commiunity grants, where the governement justifies millions to be spent to
serve under 500 people, after considering all the econonmic development
needs solved by these grants and side effects of these grants. Another
example might be, serving the poor or the meduically handicapped, which may
need the service, but not be able to pay for it.
I'd argue, that its better for something to be used, and guarantee that that
benefit will occur, even if it trades away the ability to utilize the
spectrum optimally.
The one case study that is undisputable is that, Spectrum allocated to
unlicenced, will get used, because there is no barrier to entry in order to
use it. The cost justification goes away. It just gets used, until there is
nothing left of it to be used because interference prevents it. Whats best
is that this idea has been replicated 100% of the time in all case studies.
Starting out in 2.4Ghz, 5 years later in many places the noise floor is to
high for uts use, then 5.8Ghz comes, now saturated 5 years alter also, now
5.3G is on its way, etc, etc.
As much as I dream of Licensed 700 for WISPs, the reality of that is slim,
and its hard to support the licensed of it, on an auction basis. An Auction
basis, just reduces the chances that the spectrum will get used by the most
amount of people in the most amounts of usages. Its almost to the point
where I see no other option but to support exclusively Unlicensed use of
700Mhz. But then....
Efforts like, Scrivner's/WISPA's, that are fighting for auction rules that
give WISPs an actual real chance to get a peice of 700Mhz licensed Spectrum,
come along with clever ideas to give small WISPs a competitive advantage to
possible be able to win spectrum.
The possibility that there are actually 7-10 WISPs (that have joined the
700M committee), that are not telcos, that think the might have the
possibilty to win an auction in their rural area, is a start to that dream
becoming a reality. It is unquestionable, that if WISPs win rights to
unlicenced spectrum, they will deploy and use the spectrum, it is
inevitable.
More rules and policy need to be made that spreads out the spectrum netween
more people to enhance the chances spectrum will be used, and the closer
(layers deep) the spectrum comes to be reachable by the common man, the
larger number of potential users there are, thus raising the chance it will
be used. A WISP is the closest layer to the general public, but that is not
the general public, and has expertise to utilize the spectrum wisely. I'd
argue that finding ways to let WISPs win licensed is just about as good as
unlicenced use.
Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband
----- Original Message -----
From: "Steve Stroh" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Monday, July 09, 2007 11:55 AM
Subject: Re: [WISPA] 700 MHz - The Other View
Scriv:
I disagree your statement that "If they use [700 MHz] to sell
broadband wireless Internet then by definition those parties will then
become WISPs." I doubt that Verizon Communications (landlines) and
Verizon Wireless would consider themselves WISPs merely by acquiring
more spectrum - any more than they do now considering that they both
own considerable amounts of spectrum and both already offer Broadband
Wireless Internet Access. Do you consider Sprint / Nextel a WISP
(they're doing Broadband Wireless in 2.5 GHz)? Is AT&T a WISP (they're
doing BW in 2.3 GHz)? How about Clearwire? No... there's a very clear
stratification between WISPs and other players that isn't bridged by
the common use of Broadband Wireless Internet Access, or use of a
particular portion of spectrum.
The main thrust of the article... at least as I saw it... was to offer
caution to WISPs who are considering entering the bidding for 700 MHz
spectrum.
I wish it were the case that the existence of new spectrum such as 700
MHz results in new services. But unfortunately, that's not the way of
the world. We have ample precedent that those who acquire spectrum
largely DON'T use it; thus I remain skeptical that 700 MHz will
translate to "... a means of delivering broadband in rural areas... "
as you state. The main reason for this is, and it's a mild criticism
of the worldview of the average WISP, is that rural areas are not a
priority for large companies (that have the deep pockets to win
spectrum auctions). Simply, brutally put, rural areas aren't where the
money is. You don't need any better evidence of this than Verizon, one
of the biggest telecommunications companies (and a potential bidder
for 700 MHz) is DIVESTING itself of its operations in entire rural
states, such as Maine.
So... will 700 MHz licenses in rural areas be snapped up, probably by
large companies? Oh yes indeed! Does it follow that those new owners
of 700 MHz licenses will actually build out systems in rural areas?
No, largely because experience argues just the opposite - check out
how many systems Aloha Partners discusses having constructed,
considering that "Aloha currently owns 12MHz of spectrum covering 60%
of the United States - including all of the top 10 markets and 84% of
the population in the top 40 markets". Answer... none. Aloha Partners
is sitting on its spectrum, hoping it will appreciate, maybe that some
bigger player will buy it, and they'll end up with a tidy profit on
its investment. Or maybe they're just waiting for better, cheaper
systems to emerge. Or they're waiting for... whatever. The bottom line
is that there are no Broadband Systems being built with that
particular spectrum, and no new customers being served, no additional
competition for Broadband services being brought to bear.
But mostly I'm disappointed what you chose to focus in the article on
was my mild criticism of WISPA's participation in a "closed door"
collaboration with very large companies such as Intel, Microsoft,
Cisco, Google, etc. regarding television whitespaces. No, I wasn't
griping about being (individually) excluded from the discussions. My
criticism was much more broad - I felt that the entire WISPA
membership... and the WISP community as a whole, was excluded from the
discussions. This from an organization which prides itself on being
open, transparent, democratic, and "of, by, and for WISPs"? It didn't
seem that way to me, and that "closed door" mindset was, to me, a
worrisome development for WISPA. Even more worrisome is that WISPA's
leadership, reflected by your attitude, is defensive and apparently
proud of their "closed doors" participation in the television
whitespaces collaboration with Intel, etc.
But those are the comments of one WISP industry observer. If you
choose to "shoot the messenger" instead of addressing the actual
comments and criticisms, so be it.
Thanks,
Steve
On 7/8/07, John Scrivner <[EMAIL PROTECTED]> wrote:
Steve Stroh and I usually see things the same way. We have somewhat
varying views on the 700 MHz auction coming up. Here are his views on
the upcoming 700 MHz auction.
http://www.wispnews.net/2007/07/my-take-on-700-.html
It is important to note that part of what is going to happen is that
there will be new WISPs once this spectrum sells. Some of them will look
very different from the WISPs we generally see now. I have done my part
to attempt to make this opportunity available to WISPs who are in place
now through the formation of the 700 MHz Committee. I have little doubt
that many licenses will go to people who are not now WISPs. If they use
the spectrum to sell broadband wireless Internet then by definition
those parties will then become WISPs.
The future of 700 MHz use as a means of delivering broadband in rural
areas will bear fruit. How well it does this and how soon are primarily
a factor of how much money and work are put to work to make it happen. I
will not pretend to think I know what all will happen. I simply know
that the physics of this band make it ideal to serve rural broadband.
WISPA has aggressively worked toward the efforts of acquiring unlicensed
TV white spaces spectrum through the 04-186 NPRM comments and
legislative initiatives which we have all been a part of. I have been to
DC twice over this initiative myself. I know many here have worked hard
on this. I do not see how taking a position on how the auction is
managed plays any part in whether or not we will see access to
unlicensed spectrum in the TV "white spaces".
I must also say that combined work of the Intel / Microsoft / Cisco /
New America / Free Press / WISPA coalition to gain access to this
unlicensed use of spectrum was very positive toward this effort. In
those meetings we decided that building a test device and getting it to
the FCC for evaluation would be the best way to show them we can use the
band without messing it up. In Steve's article he says, "Yes, WISPA is
"involved" in the white spaces issue, but its efforts have been clouded
(nowhere near transparent) by its mysterious participation with
companies such as Microsoft and Intel.". I guess Steve sees Microsoft
or Intel as some sort of a threat to us. I really do not know what he is
insinuating. I feel Steve Stroh may have some sour grapes regarding that
work as he was not invited to oversee the work done there through a
list server owned and operated by Intel. We (Marlon and myself) were
invited to be a part of this effort and conversations there are not
public information. I know the public record of comments to the FCC and
the letters to congress that we all approved were done openly and
therefore I do not approve of Steve's comments. In short, just because
Steve did not get to be on the inside when something happened does not
automatically make that effort suspect. The public records tells the
tale.
I will let Marlon speak for the 3650 efforts to date. I think he and a
few others here have done all the work on that effort to date. Despite
my differences of opinion with Steve Stroh I still do consider him a
friend. I just happen to think he is wrong in his article on a few
points. Most notably in his "clouded" view of WISPA's work with other
industries and foundations during the white space lobbying work.
Scriv
--
Steve Stroh
425-939-0076 | [EMAIL PROTECTED] | www.stevestroh.com
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