----- Original Message ----- 
From: "John Scrivner" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Friday, October 24, 2008 8:42 AM
Subject: Re: [WISPA] Raining on the whitespaces parade


>I can tell you myself that I have personally spent hundreds of hours
> toward this effort, as has Marlon. As with any group effort there is
> no way to please everyone. After exhaustive discussions between
> everyone over 3 plus years our FCC committee worked together to
> develop a stance.

No we didn't.  The change from unlicensed to licensed lite was done by the 
FCC trip crew that did NO colaborating with the rest of the committee. 
Again, I'm not saying that licensed lite is a bad idea.  Not talking about 
it with the membership before adopting the stance is bad.

> I believe that within our committee Marlon is the
> only person who does not support the WISPA filing 100%.

Again, not quite right.  Tom has opposed much of this filing.  And Brian has 
had questions that weren't addressed.

>  There is no
> way to have a vote for everything and frankly we usually see low
> turnout for votes or surveys.

We didn't even vote for anything at the committee level!

> What we do is have open discussions with
> everyone and we try to develop a consensus.

No we didn't.  There was nothing on the committee mailing list about this 
latest conference call that was brought up.  And not everyone was even 
allowed to volunteer for the last conference call dealing with the "common 
ground" issue.

> This discussion has been
> taking place since the beginning of WISPA and nobody has been denied a
> chance to speak their wishes regarding this proposed filing.

That's not at all true.  This filing was NEVER floated to the membership. 
It was ramrodded through the committee with no votes taken there either. 
Alternate ideas that gave the same result were rejected outright.

>
> Please read the plan delivered in the WISPA filing and see what we
> have done. We have all developed a plan that EVERYONE except AT&T and
> Verizon will support.

Sure they will.  The broadcasters get 3 for 1 on spectrum out of this!  They 
have NOTHING to loose here.  And when they want some of the spectrum back? 
Just start up a new TV channel and take 3 more channels away from the 
licensed lite guys.  Much easier than trying to take spectrum from someone 
that paid top dollar in an auction.  The only thing better than the WISPA 
proposal from the broadcaster perspective would be no secondary use.

> The only people who cannot live with or should
> not support our filing are those who are only happy with having their
> own ideas supported exclusively every time.

OK, yeah I'll take that personally.  So be it.  It's not right but oh well.

> We cannot allow one
> person's ideas to control what we file as an organization. We have not
> done this with this filing. Our filing represents everyone's ideas as
> accurately and fairly  as anyone could have ever done.

Please re-read the last month's FCC committee posts John.  We did not have 
discussion of alternate ideas.  All we did was roll out the support of the 
broadcasters and/or iFiber (hope I remember that company right).  I think 
those are good goals, I'm just not happy about giving away the farm for it.

>
> I will never try to downplay Marlon's role, or my own for that matter,
> but to say this was not a joint consensus position, as Marlon has
> said, is just not right. Every part of this has been given lengthy
> discussion, thought and effort and it represents a real way for us to
> use this band efficiently and effectively to deliver broadband. It is
> superior to "wild west" unlicensed-only policy and has every other
> advantage of unlicensed supported. In fact it has provisions for pure
> unlicensed represented in the plan.

Again, please re-read the posts.  No alternative plans were talked through. 
You had me shouting from the mountain top that there were flaws with this 
proposal.  Tom saying that the WISPA adjacent channel proposal would leave 
him with no spectrum in his market and Brian asking why the alternatives 
that I'd tossed out where so bad.  Then WISPA filed, with nothing ever 
making it out to the membership until it was too late to change anything.

My biggest bitch here is that we've ended up with a trade association that 
doesn't give it's membership an input.  Again.

>
> When we get our policies supported in the final FCC Report and Order
> of the TV Whitespace then everyone here should know you all played a
> strong role in developing what was delivered to the FCC. You should
> know that with this policy WISPs will finally be represented fairly in
> spectrum policy.

I for one hope that most of the WISPA proposals do NOT make it into the 
regs.  There are far better ways to acheive the same goals.  We can 
accomodate the broadcasters and not have to give up the farm either.

>
> Please read our filing and let your own decision making process decide
> whether this filing deserves your support. I know it does even if many
> of my own ideas were not part of the final filing. It is the plan for
> our future and we should all support it fully.

I agree that people should make up their own minds.  But they should do so 
with all available information.

John, do you remember why we walked the plank in regards to p15?  We didn't 
like the idea that we were given no voice in what was done and said in our 
name.  Filings were made and meetings were had without our ability to do 
more than voice our objections.  We could talk all we wanted but we totally 
lacked the power to make changes.

This time, our members didn't even get the chance to talk about what WISPA 
was doing.

marlon

>
> If there are things you would like to see done differently then by all
> means speak your mind with your own filing. We have delivered the
> tools directly to you to allow you to speak your mind with the link to
> the comment reporting process and instructions on how to do so. Nobody
> is being denied a voice. I believe it is possible for all of us to say
> we like this in the WISPA filing and that in the WISPA filing but
> maybe we wanted to see this added or that changed or this removed. I
> see nothing to gain in us arguing amongst ourselves about the process
> which led us to this filing. It is the best filing we have ever made
> as an organization in form and content and we need to show our support
> for it.
>
> With sincerest respect for all,
> John Scrivner
>
>
>
> On Fri, Oct 24, 2008 at 9:44 AM, Mike Hammett <[EMAIL PROTECTED]> 
> wrote:
>> Isn't that what the elected are supposed to do?  Make decisions as to 
>> what
>> they feel their constituency wants without directly asking them every 
>> time?
>> If you don't like whomever was voted in, you vote someone in that will 
>> speak
>> more in line with what you desire.
>>
>> I would love to hear what others have to say on this issue before I file 
>> my
>> own comments.  I was going to file saying "Yup, I agree with WISPA" until
>> Marlons comments.  Now I want to know what others think.
>>
>>
>> ----------
>> Mike Hammett
>> Intelligent Computing Solutions
>> http://www.ics-il.com
>>
>>
>>
>> --------------------------------------------------
>> From: "Marlon K. Schafer" <[EMAIL PROTECTED]>
>> Sent: Friday, October 24, 2008 1:29 AM
>> To: "WISPA General List" <wireless@wispa.org>
>> Cc: <[EMAIL PROTECTED]>
>> Subject: [WISPA] Raining on the whitespaces parade
>>
>>> Hi All,
>>>
>>> As a member of the FCC committee and a long term DC participant (first
>>> went
>>> there as a WISP in 2001 or 2002) I feel I have to point out some 
>>> critical
>>> flaws in our proposals.  I said much of this at the committee level but 
>>> to
>>> no avail.
>>>
>>> First, let me say this though.  The filing is masterful.  It's a GREAT
>>> document.  My heartburn has nothing to do with the document it's self or
>>> the
>>> hard work that's gone into it.  My heartburn is content based.
>>>
>>> Well, most of it is anyway.  I have a problem with WISPA changing it's
>>> stance from unlicensed to licensed lite without having consulted with 
>>> the
>>> membership on this issue.  Our last team came back from DC and told us
>>> what
>>> our new position was.  That's NOT what I help found WISPA for.  I could
>>> have
>>> just stayed with a couple of the other associations that I've been a 
>>> part
>>> of
>>> and been man handled like that.
>>>
>>> Lest anyone take this the wrong way, I happen to LIKE the licensed lite
>>> concept.  I just don't like having a committee that will make a major
>>> change
>>> without discussion before hand.  If there was discussion that said we 
>>> were
>>> going to move from unlicensed to licensed lite and I missed it then I
>>> missed
>>> it.  I know there had been discussion about the idea but nothing voted 
>>> on
>>> by
>>> anyone when it came to an official stance.  Not the way to run this
>>> railroad
>>> in my, not so, humble opinion.
>>>
>>> Now, to the whitespaces issue.
>>>
>>> I have MAJOR problems with the stance on adjacent channels.  We give up 
>>> 3
>>> for 1 every time a TV channel, or microphone etc. fires up in our area. 
>>> A
>>> TV station goes live and we don't loose the channel that they are on, we
>>> loose it and 2 on each side.  This means that in any market that has as
>>> little as 1/3rd of the channels in use by licensed operators (TV 
>>> stations
>>> AND mics) will be totally useless for us.  Why not simply set the out of
>>> band emissions standards high enough that we CAN use adjacent channels? 
>>> I
>>> begged for that language, it satisfies both us and the broadcasters.  I
>>> know
>>> it's not technically possible today.  So what?  Just tonight as I was
>>> working on an AP I saw a customer connected at the 18meg speed with a
>>> signal
>>> level of -96.  Who'd have imagined that would be possible just a couple 
>>> of
>>> year ago?????
>>>
>>> Next, I HATE geolocation as the only mechanism.  I use circles on a map.
>>> I
>>> know how inaccurate they really are.  They also change dramatically as 
>>> the
>>> technology changes.  When I started my WISP in 2000 a 15 mile cell size
>>> was
>>> the max.  And if we got anywhere near 1 meg with a 4 watt EIRP system 
>>> that
>>> also amped the receive signal by 14ish dB we were oh so happy.  Now I 
>>> can
>>> go
>>> even further than that and get 2 to 3 megs with NO amp and an eirp of 1
>>> watt
>>> or so.  Same exact CPE units that were in place when we pulled the AP'd 
>>> ap
>>> system out.  Actual signal measurement is really the only way to
>>> accurately
>>> determine interference issues.  Well, OK, I guess one could just put a
>>> large
>>> enough exclusion zone around the broadcasters to make sure that there is
>>> no
>>> interference.  Unfortunately that also means we end up with even less
>>> market
>>> potential.
>>>
>>> Here is my idea for whitespaces.  This is what I'll be personally 
>>> filing.
>>> I'll fine tune it and likely add some ideas that slip my mind right now.
>>> I'm still more than a bit miffed that there wasn't even a vote on our
>>> filing
>>> (I know I'm whining, but I'm well and truly pissed).
>>>
>>> Geolocation should be used until such time as a sensing mechanism can be
>>> found that will work.  Lets be honest here guys.  NO one knows IF the 
>>> FCC
>>> will even allow white spaces use let alone with a sensing system.  Just
>>> how
>>> much R and D do you think was put into this project in this economy?
>>> Sensing works great on $60 WiFi cards for God's sake!  (Listen before
>>> talk,
>>> CSMAK.)  It'll work for TV channels as well.  It'll just take a little
>>> more
>>> time and effort.  Set a high standard, one that will protect the 
>>> licensed
>>> users and then let the market go to work on the problem.  Once sales
>>> opportunities actually exist people will start working on ways to make
>>> this
>>> happen.
>>>
>>> Licensed lite is a great idea.  There should be NO first in mechanism
>>> though.  This leads to those with all of the money getting all of the
>>> prime
>>> slots and the rest of us sucking hind teet again.  What we should do
>>> instead
>>> (and I floated this idea as well) is follow the Spectrum Policy Task
>>> Force's
>>> recommendation and implement time sharing too.  All AP's should require
>>> either GPS sync or some mechanism that they do among any other AP's that
>>> they can hear.  Each second should be cut into some number of parts. 
>>> 100,
>>> 200, 1000, whatever makes good technical sense.  Then, when all 
>>> available
>>> channels are used up AP's will have to start sharing time as well.
>>>
>>>    This will prevent outages from competitors.  It will encourage
>>> manufacturers to stuff as much data into as small of a time slot as
>>> possible
>>> (improving efficiencies) and best of all, will allow mics and other
>>> licensed
>>> devices to be built with cheap components and to be used automatically
>>> with
>>> existing networks with NO outages due to interference!  Just think about
>>> how
>>> many mics could cover the Indy 500 if they effectively had 1000 channels
>>> available in every 6 MHz TV channel!?!?
>>>
>>> Another proposal from the Spectrum Policy Task Force was to set receiver
>>> standards.  Today all the FCC looks at is how accurate a transmitter is.
>>> No
>>> one  cares about how accurate a receiver is.  Lets use this chance to 
>>> also
>>> set standards for TV receivers.  In the end that should also benefit the
>>> broadcasters as they'd be able to start using those adjacent channels
>>> instead of leaving them empty.  It's time to start setting standards 
>>> that
>>> drive technological advances.
>>>
>>> We also need to set max channel sizes.  No more of this 40mhz wide
>>> channel,
>>> always on gear.  There is plenty of ptp licensed spectrum available for
>>> those devices.  (Yeah I know that licensed ptp links don't normally use
>>> 40mhz, you know what I mean here, no more WMUx type gear.)  Perhaps we
>>> should also follow the FCC's own example for 2.4GHz.  The smaller your
>>> footprint the more power you can use.  You guys do know that with small
>>> enough sectors and proper routing you can run, what is it, 48dB at your
>>> base
>>> stations?  Yes we worked out that interpretation with the FCC long ago.
>>> You
>>> can use smart antenna technology OR routing.  I think most of us figured
>>> out
>>> that it's cheaper and easier to just build more sites closer to the
>>> customers but I've always wanted to see what ringing a tower with 24dB
>>> grids
>>> for the base station antennas would work like!
>>>
>>> Adjacent channels should be set to a specific OOB standard.  If your
>>> device
>>> meets that standard, use the adjacent channels.  If it doesn't, then 
>>> don't
>>> use them.  That addresses the problems for the broadcasters and also 
>>> opens
>>> up spectrum for us.  Given time and a market the manufacturers will find 
>>> a
>>> way to make it happen.
>>>
>>> I also think we need to hit the current spectrum shortage much harder.
>>> Heck, as far as the FCC is concerned they just gave us over 260mhz of 
>>> new
>>> spectrum!  (5.4ghz and 3650)  Never mind the fact that most of us that
>>> need
>>> the TV band's can't use the 5.4 band due to it's low power levels.  I 
>>> have
>>> ONE 5.4 gig link and it's a 2 mile backhaul.  Can't even think of using 
>>> it
>>> for any meaningful ptmp system out here.  At Ephrata Wa. just last week 
>>> I
>>> ran a scan on a new Mikrotik AP.  The antenna is a VPol Maxrad 45* unit.
>>> In
>>> about 1 minute I picked up 99, no that's not a typo, other AP's!  And it
>>> was
>>> still climbing!  Oh yeah, this AP is nearly 2 miles from the nearest 
>>> home
>>> or
>>> business.  If that'll happen at 2.4 just think of the mess we'll have at
>>> 600mhz!  Unlicensed whitespaces devices should ONLY be allowed to 
>>> connect
>>> to
>>> a registered base station.  It should be nearly impossible to use
>>> whitespaces for home/office WLANs.
>>>
>>>    If whitespaces are allowed to operate in an unlicensed way lets open 
>>> up
>>> the indoor only 5.1ghz band that no one uses for high powered outdoor 
>>> use.
>>>
>>> I know I'll think of a few other items sooner than later.  I'll add them
>>> to
>>> my filing with the FCC.  I just wish I had have of the talent that Jack
>>> and
>>> Steve have for writing these things.  It would be great to make my
>>> thoughts
>>> look as good as the WISPA filing does.
>>>
>>> laters,
>>> marlon
>>>
>>>
>>>
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>>
>>
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