Fred, I think were saying the same thing?

On 9/30/2010 8:13 PM, Fred Goldstein wrote:
At 9/30/2010 10:37 PM, Jack Unger wrote:
Fred,

I'm sorry to seem dense but I don't understand your explanation below. I'd appreciate it if you would re-explain. The FCC said:

"transmit antenna used with fixed devices may not be more than 30 meters above the ground. In addition, fixed devices may not be located at sites where the height above average terrain (HAAT) at ground level is more than 76 meters".

I'm trying to reconcile that with your statements. Could you please re-explain more clearly or by using better actual numbers (both HAAT at ground level and antenna height above ground)?

Thanks in advance,
                                   jack

Sure. In the Order itself, the FCC explained the origin of the 76 meter HAAT limit. They explained that they didn't want any antennas more than 106 meters AAT. That's the maximum antenna HAAT I referred to. Since antennas are allowed to be 30 meters above ground, they subtracted 30 from 106 and got 75. See paragraph 66 of the Order:

"We find that limiting the fixed device antenna HAAT to 106 meters (350 feet), as calculated by the TV bands database, provides an appropriate balance of these concerns. We will therefore restrict fixed TV bands devices from operating at locations where the HAAT of the ground is greater than 76 meters; this will allow use of an antenna at a height of up to 30 meters above ground level to provide an antenna HAAT of 106 meters. Accordingly, we are specifying that a fixed TV bands device antenna may not be located at a site where the ground HAAT is greater than 75 meters (246 feet)."

The Order cited an IEEE 802 Petitition http://fjallfoss.fcc.gov/ecfs/document/view?id=6520201311 which called for HAAT to be a factor. But they didn't call for a ban on operation above 75 meters; rather, they wanted co-channel separation to increase with height:

less than 3 meters | 6 km 0.1 km
3  Less than 10 meters*         6.9 km  0.256 km
10  Less than 30 meters         10.8 km         0.285 km
30  Less than 50 meters         13.6 km         0.309 km
50  Less than 75 meters         16.1 km         0.330 km
75  Less than 150 meters        22.6 km         0.372 km
150  Less than 300 meters       32 km   0.405 km
300  Less than 600 meters       45.7 km         0.419 km
600 meters or higher    68 km   0.426 km


That's rational. On the other hand I'd prefer allowing fixed devices at any ground elevation, to allow everyone to subscribe, so I'd suggest instead that they maximum ERP be decreased in order to limit interference to the same level. So maybe 6 dB from 76 to 150 meters and 10 dB to 300 meters, though that's a guess; I haven't run the calculations. And I'd allow directional antennas, professionally installed, to have ERP measured in the direction of the protected contour, with no reduction in ERP if it's clear to the distance the above chart.

I'm thinking about a petition to that effect. I have real subscriber sites in mind.


On 9/23/2010 4:48 PM, Fred Goldstein wrote:


The rules allow antenna heights up to 30 meters, around 100 feet. One problem with the maximum HAAT limit is that it applies to the ground height, based on having a 30 meter high antenna. In other words, the ruling assumed a maximum antenna HAAT, and then set the ground HAAT to be 30m below that. If somebody's house is >10m below the limit, then a 10m antenna should be legal. (The minimum antenna height went away, since sensing is no longer required. That frankly seems to be the only major improvement in the rules.)


Brian

*From:* wireless-boun...@wispa.org <mailto:wireless-boun...@wispa.org> [ mailto:wireless-boun...@wispa.org] *On Behalf Of *Tom DeReggi
*Sent:* Thursday, September 23, 2010 7:32 PM
*To:* WISPA General List
*Subject:* Re: [WISPA] Transmit Antenna Height

Yeah, that really sucks. Many areas needing served have thick forest/trees easilly 70ft tall. A 90ft height, just wouldn't allow enough of the signal to have open air, and the signal would be going through trees most of the full path. In 900Mhz, the difference between having the tower side over the tree line and below the tree line can be the difference between a quarter mile coverage and a 7 mile coverage in our market. All be it, 700Mhz does have better NLOS propogation characteristics than 900 does.

I would have liked to see that height doubled.

However, admittedly, it will allow much better spectrum re-use in areas that have a limited number of channels available.
Spectrum reuse is one of the best ways to serve more people.


Tom DeReggi
RapidDSL & Wireless, Inc
IntAirNet- Fixed Wireless Broadband

----- Original Message ----- From: Fred Goldstein <mailto:fgoldst...@ionary.com> To: WISPA General List <mailto:wireless@wispa.org> Sent: Thursday, September 23, 2010 4:36 PM Subject: Re: [WISPA] Transmit Antenna Height This item alone may be the show-stopper, the poison pill that
    makes it useless to WISPs in much of the country.
    In places where the routine variation in elevation is more than
    75 meters, there will be houses (subscribers) that are more
    than 76 meters AAT.  I notice this in the areas I'm studying,
    both in the east and in the upper midwest.
    In a place like Kansas, nobody is >75m AAT.  But in the woody
    Berkshires of Western Massachusetts, the UHF space is needed to
    get through the trees, and a significant share of houses are
    >75m AAT.  Also, if you want to cover a decent radius, the
    access point needs to be up the hill too.  75 meters isn't a
    mountaintop; it's just a little rise.

    It makes no sense to absolutely ban fixed use at a site that is
    100m AAT if the nearest protected-service contour is, say, 50
    miles away.  A more sensible rule would be to follow broadcast
    practice, and lower the ERP based on height, so that the
    distance to a given signal strength contour is held constant as
    the height rises.  Hence a Class A FM station is allowed up to
    15 miles, and if it is more than 300 feet AAT, then it is
    allowed less than the 3000 watts ERP that apply at lower heights.
    Maybe the lawyers want to have more petitions to argue over.
    At 9/23/2010 04:07 PM, Rich Harnish wrote:

    65. Decision. We decline to increase the maximum permitted
    transmit antenna height above ground for fixed TV bands
    devices. As the Commission stated in the Second Report and
    Order, the 30 meters above ground limit was established as a
    balance between the benefits of increasing TV bands device
    transmission range and the need to minimize the impact on
    licensed services.129 Consistent with the Commission's stated
    approach in the Second Report and Order of taking a
    conservative approach in protecting authorized services, we
    find the prudent course of action is to maintain the previously
    adopted height limit. If, in the future, experience with TV
    bands devices indicates that these devices could operate at
    higher transmit heights without causing interference, the
Commission could revisit the height limit. 66. While we expect that specifying a limit on antenna height
    above ground rather than above average terrain is satisfactory
    for controlling interference to authorized services in the
    majority of cases, we also recognize petitioners' concerns
    about the increased potential for interference in instances
    where a fixed TV bands device antenna is located on a local
    geographic high point such as a hill or mountain.130 In such
    cases, the distance at which a TV bands device signal could
    propagate would be significantly increased, thus increasing the
    potential for interference to authorized operations in the TV
    bands. We therefore conclude that it is necessary to modify our
    rules to limit the antenna HAAT of a fixed device as well as
    its antenna height above ground. In considering a limit for
    antenna HAAT, we need to balance the concerns for long range
    propagation from high points against the typical variability of
    ground height that occurs in areas where there are significant
    local high points -- we do not want to preclude fixed devices
    from a large number of sites in areas where there are rolling
    hills or a large number of relatively high points that do not
    generally provide open, line-of-sight paths for propagation
    over long distances. We find that limiting the fixed device
    antenna HAAT to 106 meters (350 feet), as calculated by the TV
    bands database, provides an appropriate balance of these
    concerns. We will therefore restrict fixed TV bands devices
    from operating at locations where the HAAT of the ground is
    greater than 76 meters; this will allow use of an antenna at a
    height of up to 30 meters above ground level to provide an
    antenna HAAT of 106 meters. Accordingly, we are specifying that
    a fixed TV bands device antenna may not be located at a site
    where the ground HAAT is greater than 75 meters (246 feet). The
    ground HAAT is to be calculated by the TV bands database using
    computational software employing the methodology in Section
    73.684(d) of the rules to ensure that fixed devices comply with
this requirement. 130 The antenna height above ground is the distance from the
    antenna center of radiation to the actual ground directly below
    the antenna. To calculate the antenna height above average
    terrain (HAAT), the average elevation of the surrounding
    terrain above mean sea level must be determined along at least
    8 evenly spaced radials at distances from 3 to 16 km from the
    transmitter site. The HAAT is the difference between the
    antenna height above mean sea level (the antenna height above
    ground plus the site elevation) and the average elevation of
the surrounding terrain. 67. In reexamining this issue, we also note that the rules
    currently do not indicate that fixed device antenna heights
    must be provided to the database for use in determining
    available channels. It was clearly the Commission's intent that
    fixed devices include their height when querying the database
    because the available channels for fixed devices cannot be
    determined without this information.131 We are therefore
    modifying Sections 15.711(b)(3) and 15.713(f)(3) to indicate
    that fixed devices must submit their antenna height above
ground to the database. 68. We continue to decline to establish height limits for
    personal/portable devices. As the Commission stated in the
    Second Report and Order, there is no practical way to enforce
    such limits, and such limits are not necessary due to the
    different technical and operational characteristics of
    personal/portable devices.
-- Fred Goldstein k1io fgoldstein "at" ionary.com ionary Consulting http://www.ionary.com/ +1 617 795 2701
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--
Jack Unger - President, Ask-Wi.Com, Inc.
Author - "Deploying License-Free Wireless Wide-Area Networks"
Serving the Broadband Wireless, Networking and Telecom Communities since
1993
www.ask-wi.com <http://www.ask-wi.com> 818-227-4220
jun...@ask-wi.com  <mailto:jun...@ask-wi.com>





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