Rick,

Thank you for emphasizing how important it is that WISPs help publicize 
and build support for our proposal to open up the Television White 
Spaces for fixed, licensed-lite access.

As WISPs write or talk about our proposal it is important that they 
remember to mention the following points.

1. WISPA is proposing "LICENSED-LITE" WISP operation. This is different 
from "unlicensed". "LICENSED-LITE" (like in 3650-3700 MHz band today) is 
"LICENSED". It is NOT "UNLICENSED". With "LICENSED-LITE", WISPs 
frequency-coordinate using an FCC database. "Unlicensed" does not do 
this today. It is important for every WISP to use the term 
"LICENSED-LITE" to clarify that we are not proposing "unlicensed".

2. Google/Microsoft/Intel and others are proposing pure "unlicensed" for 
everybody. This is NOT what we propose for WISP use because we propose 
"LICENSED-LITE" which is frequency-coordinated to eliminate interference 
between WISPs and TV broadcasters and (YES) even between WISP 
LICENSED-LITE operators and pure "unlicensed" operators.

3. Do we OPPOSE PURE UNLICENSED? NO, we do not. Our technical proposal 
to the FCC allows pure unlicensed (Google/Microsoft/etc.) to ALSO USE 
the WHITE SPACES but on a non-interfering basis with us. Our proposal 
suggests two power levels for pure unlicensed - 10 mW (10 milliwatts) 
and 500 mW (500 milliwatts). At boot-up time, unlicensed base stations 
with an Internet connection would obtain a clear frequency from the FCC 
geolocation database. They would authorize every station connected to 
them to use the same clear frequency. Pure unlicensed users thus would 
NOT INTERFERE WITH TV BROADCASTERS or WITH WISPS. What about the pure 
unlicensed devices WITHOUT Internet access who could not use the 
geolocation database to obtain a clear frequency? Our proposal limits 
them to 10 mW (10 milliwatts) of transmitter power. This is low enough 
that it is unlikely that they would cause interference to nearby 
television receivers or nearby WISPs.

As WISPs "talk up" our proposal (or those parts that they agree with) I 
hope they will remember to:

a) Use the term "LICENSED-LITE".

b) Use the term "GEOLOCATION DATABASE" to eliminates interference 
between TV broadcasters, LICENSED-LITE WISP operators and pure 
"unlicensed" wireless devices.

c) Mention that our proposal allows pure "unlicensed" operators to also 
operate without causing interference.

d) Mention that our proposal DOES NOT NEED OR USE "SENSING". Sensing is 
the technology that the FCC has been testing to see if it can allow 
unlicensed devices to operate without causing interference. Sensing is 
not technologically mature yet and so it can not be used currently as a 
reliable way to prevent interference.

Thank you again for your email Rick. I hope all WISPs will realize that 
we need their help to talk about and promote our LICENSED-LITE TV White 
Space proposal. Our proposal will help them survive as WISPs now and in 
the future.

Sincerely,

Jack Unger
Chair - WISPA FCC Committee



Rick Harnish wrote:
>
> Wispa Members and List Users,
>
>  
>
> Yesterday, WISPA filed our Ex Parte Comments for FCC Docket 04-186, 
> Unlicensed Operation in the TV Broadcast Bands Additional Spectrum for 
> unlicensed devices below 900 MHz and in the 3 GHz band.  The 
> submission can be found at 
> http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6520176838
>  
> <http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6520176838>.
>   
> Please review our comments first.  Jack Unger, Steve Coran of 
> Rini/Coran and the entire FCC Committee spent hours lobbying, 
> discussing, researching and writing these comments which encourage 
> unlicensed use of the TV Whitespaces which will be opened up in Feb. 
> 2009 due to the Digital TV transition.  We owe all of these people 
> many thanks and it is our responsibility to support their efforts by 
> submitting our support through individual comments.
>
>  
>
> While reviewing the comments on the FCC website this morning, it 
> became apparent to me that there is stiff competition from the AV 
> industry against this proposal.  I reviewed nearly 300 comments from 
> people all over the US in opposition to this FCC proposal.  I did see 
> several which supported the use of these bands for Wireless Broadband 
> but we are heavily outnumbered.  There are currently over 30,000 
> comments filed under this docket.  Others see how important this is, 
> our industry needs to understand it as well.
>
>  
>
> It is my responsibility to all of the WISP operators to encourage each 
> of you to file your comments in full support of the WISPA Ex Parte 
> Comments or at least partial support with clarification if you oppose 
> some part of our comments.  I will be filing my comments as soon as I 
> finish this email.  This is a huge opportunity for each of us to help 
> educate the FCC commissioners on the importance of opening up this 
> valuable spectrum to unlicensed (light licensed) operation for 
> wireless broadband.  You can review all comments at 
> http://fjallfoss.fcc.gov/cgi-bin/websql/prod/ecfs/comsrch_v2.hts?ws_mode=retrieve_list&id_proceeding=04-186
>  
> <http://fjallfoss.fcc.gov/cgi-bin/websql/prod/ecfs/comsrch_v2.hts?ws_mode=retrieve_list&id_proceeding=04-186>.
>   
>
>
>  
>
> Please go to 
> http://fjallfoss.fcc.gov/ecfs/Upload?hot_docket=1009000856|04-186|TV+White+Spaces&Send=Continue
>  
> <http://fjallfoss.fcc.gov/ecfs/Upload?hot_docket=1009000856%7C04-186%7CTV+White+Spaces&Send=Continue>
>  
> to file your comments today.  The deadline is quickly approaching with 
> the FCC Commissioners set to publicize the rules for these bands on 
> November 4^th .  It is essential that you take 5-10 minutes out of 
> your busy schedule today or tomorrow to write and file your comments.
>
>  
>
> Rick Harnish
>
> President
>
> WISPA
>
>  
>

-- 
Jack Unger - President, Ask-Wi.Com, Inc.
Serving the Broadband Wireless Industry Since 1993
Cisco Press Author - "Deploying License-Free Wireless WANs"
Read my new EBook-"Minimize Your Microwave Energy Exposure from Cellphones" 
http://www.lulu.com/content/4368917
FCC Lic. #PG-12-25133 LinkedIn Profile <http://www.linkedin.com/in/jackunger>
Phone 818-227-4220  Email <[EMAIL PROTECTED]>





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